A Key Development Amid the Tariff War: CBP and Commerce Join Forces

Core judgment. In discussions of the tariff conflict, merchants usually watch rate schedules and lists of additional duties. Two developments around late September 2026 point to a different U.S. effort. The Department of Commerce made an affirmative preliminary circumvention finding concerning steel wire hangers finished in Cambodia, while Customs and Border Protection (CBP) and Commerce appeared together for their first joint webinar on antidumping and countervailing duties (AD/CVD) and the Enforce and Protect Act (EAPA). Together, they signal tighter scrutiny of routes that rely on changing the declared origin or finishing goods in a third country, and a more visible invitation for the trade community to report evasion. Joint action by CBP and Commerce is a development that should not be overlooked amid the tariff conflict.

1. Recent development: preliminary circumvention finding on hangers finished in Cambodia

Around September 22, 2026, Commerce published an affirmative preliminary determination in the Federal Register in a circumvention inquiry involving AD/CVD measures on steel wire hangers from China and Vietnam (Federal Register document 2026-19376). Hangers finished in Cambodia with wire or other inputs from China or Vietnam may still fall within a circumvention finding relating to the orders on those two countries.

The operational signal is equally clear. Commerce instructed CBP to suspend liquidation and collect cash deposits on relevant unliquidated entries dating from approximately August 12, 2025. It also established two certification routes requiring the import chain to account for third-country finishing and the origin of inputs. The measure applies from around September 22, 2026.

The important point is not the hanger itself but the logic of the rule: a “finished in a third country” label does not automatically remove a product from an order’s reach. U.S. authorities are examining where inputs came from, how much processing took place, and whether the arrangement circumvents an existing AD/CVD order. That is a significant signal for supply chains accustomed to finishing goods elsewhere before exporting them to the United States.

2. A first joint CBP–Commerce webinar

The interagency step the day before deserves attention as well. At 2:00 p.m. Eastern Time on September 21, 2026, CBP and Commerce held a joint webinar titled Combating Unfair Trade: Understanding New AD/CVD Orders and Reporting Evasion to CBP (CSMS #69536147). The agencies described it as a first-of-its-kind joint session.

Its agenda covered new AD/CVD orders, how to report evasion to CBP, and the allegation process under EAPA. In other words, the public message joined the “wall” of trade-remedy orders with the mechanisms for reporting and opening an evasion case.

At the rule level, the EAPA process includes:

• Initiation review: usually no more than 15 business days.
• Interim measures where reasonable suspicion exists: usually within 90 calendar days.
• Evasion determination: usually within 300 calendar days, or approximately 360 days in complex cases.
• Reporting channels: relevant TVR/EAPA portals and e-Allegations.
• Moiety awards: after verification, a reporting party may receive up to 25% of net recovered proceeds, capped at $250,000 per case.

In a public notice around July 2026, CBP reported recoveries under EAPA exceeding the $1 billion mark.

3. Three signals

Signal one: third-country finishing and transshipment are under scrutiny — changing the origin does not mean safety

The affirmative preliminary finding on Cambodian hangers places processing in a third country followed by export to the United States squarely within the circumvention lens. The origin of inputs, including Chinese or Vietnamese wire, is examined separately from the finishing location. A country-of-origin label may change while the reach of an AD/CVD order does not. This is a clear risk signal for supply chains that treat finishing in another country as an automatic way outside an order.

Signal two: the agencies are bringing EAPA and reporting to the trade community — enforcement tools move to the front

CBP administers the border and entry process; Commerce handles AD/CVD investigations and the scope of orders. Their roles already connect along the trade-remedy chain. The significance of the first joint webinar is not simply that another meeting occurred. The agencies publicly packaged an explanation of new orders with instructions for reporting evasion to CBP and using EAPA. They are inviting outside participants to help identify suspected violations, rather than leaving enforcement as an internal agency process.

Signal three: orders, circumvention findings, and awards compound the risk — routes become costlier and more fragile

Existing AD/CVD orders already create a barrier. Add circumvention findings—including the third-country finishing example—and a reporting mechanism with financial awards, and an import strategy based only on low prices and a changed route becomes more costly and fragile. Cash deposits, suspended liquidation, and the 15/90/300-day case timeline can all reshape cash flow and delivery expectations. These are different levers in the same tariff conflict, beyond the increases and decreases shown on a rate schedule.

4. Conclusion and implications

Taken together, the two developments support the central judgment: CBP and Commerce are acting jointly in ways that matter amid the tariff conflict.

Commerce is using a circumvention inquiry to bring “finished in a third country” claims back to the governing text. CBP and Commerce are jointly explaining new AD/CVD orders and EAPA reporting to the trade community. Tariff rates, order scope, origin, border execution, and third-party reports are increasingly part of one enforcement picture.

For merchants and brands focused on the U.S. market, the practical implication is direct. Track interagency circumvention enforcement as closely as tariff increases and negotiation headlines. The issue extends beyond one hanger shipment or one webinar: it shows how the United States is moving trade remedies from rates on paper into ordinary processes that can be enforced, reported, and attributed to responsible parties.

Sources and disclaimer

1. Preliminary affirmative circumvention finding on steel wire hangers finished in Cambodia: Federal Register, document path including 2026-19376 (around September 22, 2026).

2. Joint webinar: CBP CSMS #69536147.

3. For EAPA timelines and moiety awards, consult CBP and the applicable public regulations.

4. This article is provided for business judgment and is not legal advice.