Global Trade and Compliance Update: Are Your Docs, Data, and Suppliers 2026-Ready?

Regulatory changes aren’t new. But the enforcement behind them? That’s what’s different about 2026.

Customs agencies have shifted from warnings to action, and trade policy continues to change faster than most global trade and compliance teams can update their procedures.

If you’re moving freight internationally, your documents and supplier records are about to get pushed to their limits. Regulators want origin data. They want sustainability proof. They want it organized, accurate, and accessible ASAP.

So, we put together this update to help you figure out where you stand related to global trade and compliance as we kick off Q1 2026. What’s changed, what’s coming, and what your team should prioritize.

The De Minimis Free Pass Has Expired

For years, the de minimis exemption was a quiet workhorse. Small shipments under $800 sailed through with minimal paperwork and zero duties. Shippers loved it. So did e-commerce. Maybe a little too much.

On August 29, 2025, the agency ended the exemption globally and made clear that revenue collection and tighter controls are now the priority.

The free ride is over.

Why Mallory Customers Should Care

Your “routine” shipments just got a lot less routine.

Flows that used to breeze through now behave like formal imports. More data requirements. More visibility demands. More cost. Retail replenishment, parts orders, product samples, and warranty replacements — these categories feel the pinch first.

And it won’t stop at duties. CBP has signaled increased classification scrutiny, valuation questions, and documentation requests across the board. That sample shipment you used to send without a second thought? Someone’s going to ask for the HTS code, country of origin, and value methodology.

2026 Playbook: What to Do Now

* Start with Landed Cost Models: Duties, taxes, broker fees, and cycle time all need recalculating. The math has changed, and your margins depend on knowing the new numbers.
* Clean Your Item Master Data: Every SKU needs an accurate HTS code, country of origin, value method, and product description. Gaps here will cost you at the border.
* Prioritize Packaging and Consolidation: Think about packaging and consolidation strategies that reduce line counts and exceptions. Fewer individual entries mean fewer opportunities for delays.
* Build an Exception Lane SOP: When invoice data needs fixing (and it will), your team should know exactly who handles corrections, who approves rework, and who covers the fees. Confusion at that moment gets expensive fast.

UFLPA Enforcement Isn’t Slowing Down

If de minimis changes feel like a paperwork headache, forced labor compliance is the one that can stop your shipment cold.

The Uyghur Forced Labor Prevention Act (UFLPA) added 78 new entities to its blocked list over the past year, bringing the total to 144. CBP continues to broaden its enforcement posture and has clearly stated that if your goods get flagged, you need documentation ready.

Not next week. Not after a few emails to your supplier. Now.

Not to mention, that documentation better look like something your business created “in the ordinary course” of operations.

Why Mallory Customers Should Care

Certain industries face higher exposure than others, and the common thread is sourcing complexity.

Cotton and textiles carry a known forced labor risk, especially when raw materials pass through multiple hands before reaching your factory. Electronics run into component-level traceability challenges (good luck proving where every chip originated). Paper and consumer goods often undergo multicountry transformation.

If you’re like most shippers who don’t have visibility past their tier-1 suppliers, your work’s cut out for you. CBP expects you to go deeper.

2026 Playbook: What to Do Now

* Map Your Tier-2 and Tier-3 Suppliers: The factory you contract with is just the starting point. You need to know where they source materials and who supplies their suppliers, especially for high-risk SKUs.
* Build a Shipment-Ready Evidence Pack: Purchase orders, production records, material inputs, traceability documentation, and transport records should all live in one accessible place before a shipment ever leaves the origin.
* Establish a Detention Response Protocol: Know who responds to CBP, how fast they can move, and what evidence gets submitted first. Figure this out now, not when your container is sitting at the port.
* Audit Your Broker and Forwarder Data Handoffs: Your customs filings need to match your sourcing proof exactly. Discrepancies raise red flags, and red flags lead to delays you can’t afford.

Tariff Whiplash Is the New Normal

Just when you think you’ve got your duty costs figured out, the rules change again.

USTR extended 178 Section 301 exclusions in late 2025 that were set to expire, pushing the new deadline to November 10, 2026. Good news if your products qualify. But semiconductor-related actions remind us how quickly tariff policy can swing.

Delayed investigations tied to China chip sourcing remain active, and new duties could drop with little warning.

Why Mallory Customers Should Care

Your duty outcome now depends on three things working together: HTS precision, exclusion eligibility, and documented product specs. Get one wrong, and your costs jump.

The real danger lurks in mismatched classification. Your supplier uses one HTS code. Your broker files with another. Your ERP shows something different entirely. Nobody notices until an audit or a surprisingly expensive shipment lands.

These cost surprises hit hardest when margins are already tight.

2026 Playbook: What to Do Now

* Run a Top 50 SKU Tariff Review: Pull your highest-volume items and verify HTS codes, exclusion eligibility, country of origin, and current duty rates. Start with the products that move the most money.
* Align Classification Across All Parties: Your suppliers, brokers, and internal ERP systems should all reflect the same HTS codes. Discrepancies create audit risk and cost leakage you won’t see until it’s too late.
* Build Tariff Shock Language Into Contracts: Surcharge triggers, renegotiation rules, and cost-sharing provisions give you options when policy changes overnight. Get these terms in writing before you need them.
* Evaluate Duty Optimization Strategies: Drawback programs, bonded warehouse strategies, and smarter routing can reduce exposure for the right products. Not every SKU qualifies, so assess on a case-by-case basis.

Export Controls and Sanctions Now Touch Your Logistics

Export compliance used to feel like someone else’s problem. If you weren’t shipping military equipment or nuclear technology, you could mostly stay in your lane.

That’s changed. Your freight now moves through a system that regulators are watching more closely than ever.

U.S. export controls on advanced semiconductors and related tech keep evolving, with restrictions on China-related authorizations having rolled out throughout 2025. OFAC also published updated guidance for shipping and maritime stakeholders on detecting Iranian oil sanctions evasion.

Why Mallory Customers Should Care

When regulators start writing guidance for logistics providers, it means enforcement is moving downstream.

Electronics exporters and importers face the most obvious exposure. Screening requirements have tightened, and licensing risks have grown as semiconductor controls expand.

That said, you don’t have to ship sanctioned goods to have a sanctions problem. Your counterparties matter. Your routing matters. Vessel behavior matters. An unusual intermediary, a ship that recently visited a restricted port, incomplete buyer information: any of these can create global trade and compliance exposure.

The regulators have made clear they expect shippers to know who they’re doing business with and how their goods are moving.

2026 Playbook: What to Do Now

* Tighten Party Screening and End-Use Checks: Screen every transaction against current restricted party lists, verify end-use declarations, and document the results. If you can’t prove you checked, you didn’t check.
* Add ECCN Flags to Your Item Master Data: Sensitive products need controlled-technology identifiers built into your systems. You can’t manage export risk on items you haven’t classified.
* Build Stop-Ship Triggers for Red Flags: Routing anomalies, unusual intermediaries, and incomplete buyer data should automatically pause a shipment until someone reviews it. Catching problems before goods move is infinitely cheaper than catching them after.
* Train Teams on Escalation Protocols: Everyone involved needs to know exactly who gets notified (global trade compliance, legal, your forwarder) before goods ship. Confusion at decision time creates liability.

The EU Wants Your Data (And They Want It Structured)

Shipping to the EU has always involved paperwork. But 2026 brings a different kind of requirement: data that’s structured, standardized, and audit-ready before your goods arrive.

The EU’s ICS2 rollout continues expanding safety and security filing requirements across transport modes, with key deadlines hitting in early 2026. Filers need to implement updated message standards now, not later.

Meanwhile, the EU Deforestation Regulation (EUDR) application date lands on December 30, 2026, for large and medium operators (June 30, 2027, for smaller ones).

That sounds far away until you realize how much traceability work sits between here and there.

Why Mallory Customers Should Care

Lumber and paper shippers face the most direct EUDR impact. You’ll need traceability documentation proving your products didn’t contribute to deforestation. Supplier attestations, origin details, auditable evidence — all of it needs to exist and check out.

Moreover, even if you’re selling to an EU buyer, they’ll push these data requirements upstream to you. Your customer’s compliance problem becomes your data problem. And ICS2 affects anyone moving goods into the EU, regardless of product category. Security filing data needs to be complete, accurate, and submitted on tighter timelines.

2026 Playbook: What to Do Now

* Clarify Filing Responsibilities: Confirm who files what across your carrier, forwarder, and house filer relationships. Assumptions here lead to missed filings and delays at the border.
* Validate Commercial Document Data Elements: Your docs need to capture exact shipper/consignee details, goods descriptions, and other required fields. Close enough won’t cut it with ICS2.
* Pressure-Test Your Data-to-Filing Timeline: Late bookings with incomplete data will miss filing windows. Know how tight your margins really are before peak season hits.
* Start Capturing Traceability Inputs Now: Supplier attestations, origin documentation, and auditable sourcing evidence take time to collect. Waiting until Q4 puts your December shipments at risk.

Your Freight Is Only as Fast as Your Compliance

Moving freight has never been the hard part. But moving compliant freight? That’s a whole beast of its own in 2026. Treat global trade and compliance as a core operating discipline, and you’ll protect your margins and keep goods moving. Treat it as a last-minute fix, and you’ll find yourself in a quagmire of damage control.

Mallory Alexander International Logistics helps you build that discipline into your operations. Our team connects ocean and air forwarding, customs brokerage, compliance consulting, warehousing, and domestic transportation so your data, filings, and physical moves stay aligned from origin to destination. Fewer holds. Fewer surprises. Fewer late-night emails asking why a shipment is stuck at the port.

Contact us to review your 2026 trade readiness and build a compliance game plan before the next wave of enforcement hits.