Simply Trade

Host: Lalo Solorzano
Guest(s): N/A
Published: September 25, 2026
Length: N/A
Presented by: Global Training Center

Summary
The writing has been on the wall for a while. This week, some of those warnings turned into dates, duty rates, filing requirements, and even an import prohibition.

With Cindy Allen traveling for the NCBFAA GAC conference, Lalo Solorzano takes over the weekly trade update — swapping Taylor Swift for Iron Maiden and looking at several developments that trade professionals can no longer leave in the “watching” category.

At the top of the list are new restrictions affecting certain Canadian goods. Beginning September 29, covered packaged alcoholic beverages, dairy products, and motorcycles face exclusion from importation into the United States under Section 338 — moving the conversation beyond the earlier 50% additional duties.

Lalo also covers CBP’s upcoming electronic export manifest test for truck cargo, important AD/CVD developments involving products from China, Mexico, and India, and the October 6 launch date for Phase 3 of CBP’s CAPE process for certain finally liquidated IEEPA entries.

The message for trade professionals is straightforward: go back to your watch list. Yesterday’s developing issue may now have a deadline, a rate, a filing requirement, or a direct impact on whether goods can enter the country.

Main Topic / Discussion
This week’s developments demonstrate how quickly trade issues can move from proposals and preliminary actions into operational requirements.

Canadian Imports and Section 338
Beginning September 29, certain Canadian packaged alcoholic beverages, dairy products, and motorcycles will be excluded from importation into the United States. The exact product coverage and HTS classification matter, and goods imported before the effective date may receive different treatment under the earlier 50% Section 338 duty.

For importers, this creates immediate questions around classification, shipment timing, entry status, sourcing, and product eligibility.

Electronic Export Manifests for Trucks
CBP will begin a roughly two-year electronic export manifest test for truck cargo on October 23, initially involving nine carriers.

Participating carriers will provide certain export-manifest information through ACE at least 24 hours before departure, with the complete manifest due no later than two hours before arrival at the final port of export.

The test reinforces a broader direction: CBP wants export information earlier, potentially requiring carriers, forwarders, USPPIs, and other parties to adjust their processes.

AD/CVD Developments
Commerce preliminarily determined that certain compacted graphite iron brake drums from China constitute later-developed merchandise circumventing existing AD/CVD orders.

Other developments include a preliminary 56.43% dumping margin in the administrative review of seamless refined copper pipe and tube from Mexico and final affirmative ITC injury determinations involving oleoresin paprika from India.

The lesson: AD/CVD exposure is not static. Product scope, rates, circumvention findings, and cases can change after a sourcing decision has been made.

IEEPA Refunds and CAPE Phase 3
CBP says CAPE Phase 3 is scheduled to open October 6 for certain finally liquidated entries tied to litigation.

This does not apply broadly to every importer with finally liquidated IEEPA entries. According to the episode, the phase currently applies to importers that filed their own lawsuit and have a court order permitting those entries to be reliquidated.

Affected companies should review entry coverage, importer-of-record information, and ACH refund information.

Key Takeaways
• Review Canadian imports now if your company handles products potentially covered by the September 29 Section 338 prohibition.

• Prepare for an environment where CBP increasingly expects export information earlier in the shipment process.

• Monitor AD/CVD cases continuously — product coverage, circumvention decisions, duty rates, and sourcing economics can change.

• Revisit your company’s compliance “watch list.” Developing issues may now have firm dates, rates, requirements, or restrictions requiring action.

Resources & Mentions
• Global Training Center

• U.S. Customs and Border Protection (CBP)

• U.S. Department of Commerce

• U.S. International Trade Commission (ITC)

• Automated Commercial Environment (ACE)

• Customs Automated Processing of Entries (CAPE)

Credits
Host:
Lalo Solorzano

Guest(s):
N/A

Producer:
Lalo Solorzano

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Host: Lalo Solorzano & Andy Shiles
Guest(s): Humberto Caballero
Published: September 24, 2026
Length: ~33 minutes
Presented by: Global Training Center

Summary
CBP has put 64 questions before the trade community—but are they really just questions, or a preview of where U.S. import compliance is headed?

In this episode, Lalo Solorzano and Andy Shiles sit down with licensed customs broker Humberto Caballero of XP Logistics & Trade to unpack what these questions could mean for importers, customs brokers, manufacturers, and trade compliance teams.

Drawing on his experience with both U.S. and Mexican customs, Humberto boils the discussion down to three critical concepts: right to make entry, traceability, and accountability.

The conversation explores why CBP may increasingly expect importers to understand what happens before goods reach the U.S. border—including foreign export documentation, transaction values, supplier information, manufacturer identification, sourcing, and payment records.

The team also digs into the challenges surrounding Manufacturer Identification Numbers (MIDs), supplier due diligence, CTPAT, and the growing need for trade compliance professionals to have a seat at the table before sourcing and purchasing decisions are finalized.

The message for importers is clear: start preparing now rather than waiting for new requirements to arrive.

Main Topic / Discussion
CBP's 64 questions point toward a potentially significant evolution in how importers document, verify, and demonstrate compliance.

Humberto organizes the underlying issues into three areas: right to make entry, traceability, and accountability. Importers may need greater visibility into their foreign suppliers, export documentation, transaction history, sourcing, manufacturer information, and the parties receiving the economic benefit of a transaction.

The discussion also highlights the increasing importance of aligning trade compliance with purchasing, sourcing, logistics, and foreign operations. Instead of bringing compliance professionals in after a problem occurs, companies should involve them before suppliers are approved and transactions begin.

Particular attention is given to foreign documentation and Manufacturer Identification Numbers (MIDs). Inconsistent manufacturer information can create complications when companies, customs brokers, and government programs are trying to establish who actually manufactured or exported merchandise.

The episode also examines how U.S. compliance expectations appear to be moving toward greater traceability and how those expectations compare with practices Humberto has experienced in Mexico.

Key Takeaways
• Humberto summarizes the themes behind CBP's 64 questions as right to make entry, traceability, and accountability.

• Importers should understand not only what they are importing, but also who they are doing business with and how their suppliers source materials.

• Foreign export documentation, purchase orders, invoices, payment records, transaction values, and manufacturer information could become increasingly important parts of demonstrating traceability.

• Manufacturer Identification Numbers can become inconsistent when different parties construct an MID differently or use different addresses for the same company.

• Supplier due diligence should involve trade compliance—not just sourcing and purchasing.

• Companies should consider maintaining reliable supplier data such as foreign tax IDs, DUNS information, manufacturer details, and applicable MIDs in their internal systems.

• CTPAT continues to evolve beyond its original security focus, making traceability and trade compliance increasingly important considerations for participating companies.

• A strong trade compliance function can be a competitive advantage, particularly when compliance professionals are involved before transactions occur rather than being asked to fix problems afterward.

Resources & Mentions
• Global Training Center

• Humberto Caballero on LinkedIn

• CBP's 64 questions and proposed import disclosure concepts discussed during the episode

• CTPAT and evolving trade compliance expectations

• Executive Order 14411, as discussed during the episode

Credits
Host:
Lalo Solorzano
Andy Shiles

Guest(s):
Humberto Caballero - LinkedIn

Producer:
Lalo Solorzano

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Host: Lalo Solorzano
Guest(s): Arthur O’Meara
Published: September 22,2026
Length: ~8 minutes
Presented by: Global Training Center

Summary
Recordkeeping may not be the most exciting part of trade compliance, but Arthur O’Meara has one word for what can happen when companies get it wrong: draconian.

In Episode 3 of this Simply Trade Tips series, host Lalo Solorzano and Arthur tackle an often-overlooked part of import compliance: keeping the records you may need when Customs comes asking. Arthur explains why the A1A recordkeeping list can initially seem intimidating—and why compliance doesn't necessarily mean copying every document into one massive entry file. Instead, companies should understand what records are required, know exactly where those records are maintained, and periodically verify that they remain accessible.

The conversation also addresses a practical challenge facing trade professionals: when tariffs, classification changes, and other urgent issues consume your time, routine compliance tasks can slip down the priority list.

Arthur's recommendation? Make recordkeeping part of your annual compliance goals. It's a manageable exercise that can help protect the company before a CBP request puts your records to the test.

Main Topic / Discussion
This episode focuses on establishing a practical and sustainable approach to trade recordkeeping.

Arthur explains that companies don't necessarily need to duplicate every required document and store everything alongside their entry records. Using purchase orders as an example, he suggests documenting where the records are maintained—such as within purchasing or procurement—and periodically confirming that the responsible department continues to retain them.

The important question is whether the company can produce the required records when they're requested.

Arthur also discusses what can happen when CBP sends a CBP Form 28 Request for Information. At that point, the trade compliance professional may suddenly need to locate marketing literature, transaction documentation, or other records while working against a response deadline.

His preferred approach is proactive: periodically review the company's recordkeeping practices before a government request arrives.

Key Takeaways
• Don't let the A1A list overwhelm you: Understand which records actually apply to your transactions rather than assuming every item on the list belongs in every file.

• Know where your records live: A document doesn't necessarily have to be duplicated into one centralized file if you can identify where it's maintained and retrieve it when necessary.

• Periodically verify accessibility: Don't assume another department is still retaining a record simply because it was there the last time you checked.

• Prepare before a CBP Form 28 arrives: A request for information is not the ideal time to discover gaps in your recordkeeping process.

• Make recordkeeping an annual goal: Arthur describes it as an “easy win” that doesn't have to consume significant time but can help protect the company.

Resources & Mentions
• Global Training Center

• Lalo Solorzano

Guest(s):
Arthur O’Meara - LinkedIn

Producer:
Lalo Solorzano

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Host: Cindy Allen
Published: September 18, 2026
Presented by: Global Training Center

Summary
International trade keeps changing—but are businesses, policymakers, and trade professionals changing with it?

In this episode of Simply Trade Cindy’s Version, Cindy Allen uses Taylor Swift’s “Right Where You Left Me” as the lens for a packed week in international trade. Cindy covers developments ranging from CBP refund processing and importer-of-record enforcement to the Jones Act, rail export manifests, trucking challenges at the southern border, ocean freight congestion, and ongoing uncertainty surrounding global shipping.

She also turns to the bigger question facing the trade community: Are we still approaching tariffs and trade policy as if the world hasn’t changed?

Cindy shares her perspective on when tariffs may serve a strategic purpose, including national security and critical supply chains, while questioning whether broad tariffs by themselves can accomplish larger policy objectives. Her message for businesses is straightforward: regardless of where the policy debate goes next, companies need to prepare for an international trade environment that looks very different from the one they knew a decade ago.

The challenge isn’t just keeping up with the latest regulation. It’s recognizing when the assumptions behind your trade strategy need to change.

This Week in Trade
• CBP refund processing, CAPE Phase 3, and ACE refund account challenges
• Importer-of-record enforcement and the importance of accurate CBP Form 5106 information
• Ocean freight congestion, global shipping risks, and approaching Golden Week pressures
• Tariffs, critical supply chains, and adapting business strategy to the evolving trade environment

Main Topic / Discussion
The central question this week is whether the trade community is “right where you left me”—holding onto assumptions about tariffs, sourcing, supply chains, and trade policy that were formed in a very different environment.

Cindy discusses her view that tariffs can be one tool for addressing specific national security, health, and supply-chain concerns, but argues that tariffs alone cannot create domestic manufacturing capacity or solve broader economic challenges.

Using pharmaceuticals and metals as examples, she explains why incentives, investment, production capacity, and long-term strategy need to work alongside trade policy.

The broader takeaway for importers and trade professionals: the operating environment has changed. Rather than waiting for international trade to return to an earlier version of “normal,” companies should evaluate what the current environment means for compliance, sourcing, investment, and long-term planning.

Key Takeaways
• Importers should review the information associated with their importer-of-record numbers and ensure their CBP records are accurate and current.

• Refund processing can still create operational challenges, particularly when importers do not have the necessary ACE refund information established.

• Global logistics remain exposed to congestion and geopolitical disruption, making continued supply-chain monitoring important.

• Trade strategy should focus not only on individual tariff actions, but also on the larger business objective: what problem needs to be solved, and what combination of tools can address it?

Resources & Mentions
• Global Training Center
• World Trade Report 2026
• U.S. Customs and Border Protection — ACE, importer-of-record records, and refund processing discussed in the episode

Credits
Host:
Cindy Allen

Guest(s):
N/A

Producer:
Lalo Solorzano

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Host: Lalo Solorzano and Andy Shiles
Guest(s): Hal Berman and John Petitte
Published: September 17, 2026
Length: 38:47
Presented by: Global Training Center

Summary
Tariff engineering isn’t just a compliance exercise—it can become a powerful strategy for reducing landed costs, improving sourcing decisions, and strengthening profitability.

In this episode of Simply Trade, Lalo Solorzano and Andy Shiles welcome back Hal Berman and John Petitte of Trade Insight for a practical discussion about how companies can approach tariff engineering as a cross-functional business initiative.

The conversation explores why successful duty optimization requires much more than finding a different tariff classification. Engineering, sourcing, procurement, finance, operations, tax, supply chain, and compliance may all hold pieces of the information needed to determine whether a change actually makes financial sense.

Hal and John share examples involving product design, component sourcing, final assembly, free trade agreements, and duty exposure to illustrate how relatively small changes can potentially produce meaningful savings. They also discuss the role of AI as a research and productivity tool for trained trade professionals—not as a replacement for human judgment.

The bigger lesson: companies can get more value when trade considerations enter the product lifecycle earlier, rather than waiting until goods reach the border.

Main Topic / Discussion
Tariff engineering is the process of evaluating how legitimate changes to a product's design, materials, sourcing, manufacturing, assembly, or supply chain can affect tariff treatment and overall landed cost.

The discussion emphasizes that effective tariff engineering requires a holistic view. A lower duty rate alone doesn't necessarily make a change worthwhile. Companies must consider supplier agreements, manufacturing costs, labor, logistics, tax implications, compliance requirements, and other costs before determining the actual return on investment.

Build a Cross-Functional Team
Compliance may help lead the analysis, but the necessary information often lives throughout the organization. Engineering understands product design. Procurement and sourcing understand suppliers and contracts. Finance can evaluate ROI. Operations and supply chain understand manufacturing and logistics constraints.

Executive sponsorship can help these groups work toward the same objective instead of leaving compliance to pursue optimization opportunities alone.

Start Small and Build a Repeatable Process
Rather than reviewing every SKU at once, the conversation suggests identifying products associated with significant duty spend and evaluating specific opportunities.

Even when the first project doesn't uncover savings, the exercise can establish a repeatable framework: which questions need to be asked, who owns the information, what constraints matter, and which stakeholders need to participate.

Over time, tariff considerations can move earlier in the product lifecycle and potentially become part of product and supply-chain design.

AI as a Trade Professional's Tool
AI and technology can help trade professionals research classifications and analyze much larger product libraries, but the episode stresses the importance of human involvement and transparent reasoning.

The objective is to give trained professionals better tools, clearer supporting rationale, and greater capacity—not simply automate away the compliance function.

Key Takeaways
• Tariff engineering goes beyond finding a lower duty rate; companies should evaluate total landed cost and overall ROI.

• The strongest opportunities can involve product design, materials, sourcing, manufacturing location, final assembly, free trade agreements, and other special tariff provisions.

• Compliance cannot effectively execute tariff optimization alone. Engineering, finance, sourcing, procurement, operations, supply chain, tax, and other stakeholders may need to participate.

• Executive sponsorship can help transform tariff optimization from an isolated compliance project into an ongoing cross-functional business process.

• Starting with high-duty products can create a manageable pilot project and establish a framework that can later be repeated across additional SKUs.

• Bringing trade considerations into the product-development process earlier can give engineers and sourcing teams additional information when making design and supplier decisions.

• AI can expand research and classification capacity, but trained trade professionals and human judgment remain central to defensible compliance decisions.

Resources & Mentions
• Global Training Center
• Hal Berman on LinkedIn
• John Petitte on LinkedIn

Credits
Host:
Lalo Solorzano
Andy Shiles

Guest(s):
Hal Berman - LinkedIn
John Petitte - LinkedIn

Producer:
Lalo Solorzano

📢 Subscribe & Follow
Stay connected with the Simply Trade community and never miss an episode that helps you trade smarter.

🎧 Listen on:

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💬 Connect with us:

• Simply Trade
• Global Training Center
• Trade Geeks Community

Don't forget to rate, review, and share with your fellow trade geeks!

Want to be on the show or have topic suggestions?
SimplyTrade@GlobalTrainingCenter.com