STRIKES AND LABOR ACTION

France: Strikes Continue, Customs System Outage
France has been going through a chaotic period of national strikes, with work stoppages at French ports and terminals that started on November 5. Strike action continues on November 6, including a separate 24-hour strike by port tugboat crews. The “Yellow Vest” movement is calling for rolling strikes, especially around transport and infrastructure, and for mass demonstrations across the country on November 7. The movement has combined with students and various trade unions to protest the cost of living, teacher shortages, and austerity measures. Expect delays to container handling and vessel schedules, along with added congestion on top of the existing backlog at Le Havre.

On top of the strikes, French customs is also experiencing a system outage. Since Tuesday, November 3 at 3:00 pm, the national customs system (Delta IE) has been down, and the supplier customs system (GAMMA 2) has been disconnected. Customs had expected repairs within 24 hours, but that has not happened, and the emergency process has been overwhelmed by the volume of requests from suppliers and customs brokers. As a result, many containers may not be customs cleared and could be rolled to later sailings. We will share updates as they become available.

U.S. West Coast: ILWU Local 26 Contract Extended to November 6
ILWU Local 26 and the Pacific Maritime Association (PMA), which represents the ocean carriers and terminal operators that employ ILWU labor, have extended their contract negotiation deadline to midnight Pacific Time on Friday, November 6. This delays a possible strike at the Ports of Los Angeles and Long Beach. Local 26 represents about 250 watchmen with security duties, but the PMA has warned that other ILWU members would be expected to honor their picket lines, which could mean a massive stoppage or slowdown of cargo movement. The broader West Coast longshore contract is not affected and runs through 2028. Negotiations are continuing with help from the Federal Mediation and Conciliation Service. We continue to expect resolution without strike action but are keeping a close watch on the situation.

Chile: Truckers’ Strike Continues
The strike of independent truckers continues in Chile and is affecting cargo movement in the San Antonio port area. The truckers have been on strike since October 29 and have immobilized about 200 trucks. They are also blocking access to cargo depots, making it difficult to obtain empty containers. The port terminals remain operational, so the main issue is getting equipment and finding available trucks. The Port of Valparaíso is not blocked, and rerouting cargo there is a good option to keep goods moving. Note that two sailings on the direct service from San Antonio to the U.S. East Coast (ONE, CMA, and COSCO) are blank (canceled) this week and next. These omissions limit overall capacity, so please monitor your shipments closely.

Spain: General Strike on November 11
The 24-hour nationwide general strike in Spain is still scheduled for Wednesday, November 11. If you have Spanish pickups, deliveries, or cut-offs around that date, we recommend you check on any urgent shipments.

PORT AND SHIPPING UPDATES

Rhine: Water Levels Remain Critically Low
The Kaub gauge read about 21 cm on November 2, with no significant rain in the forecast. That is far below the 77 cm level at which barges can run at reasonable loads. Carriers are continuing to charge and revise low-water surcharges, with some increases for Rhine barge transport effective November 1. The situation is exacerbated by limited rail service to one of the key terminals in Rotterdam. With very limited barge service, the only option for delivery to the APM2 terminal is by truck. Continue to plan for additional time for any loads from the hinterland.

Hormuz: Attacks Continue and Fuel Costs Rise
Attacks on commercial shipping in and around the Strait of Hormuz continued this week. UKMTO reported at least five vessels with incidents beginning November 1, a pace similar to October, which saw 35 vessels hit, the most of any month of the war. Iran says several tankers struck mines on a southern route it has not authorized, though many of its claims are unverified. President Trump has warned of a possible “heavy hit” on Iran, and Qatar says the U.S. and Iran are reviewing proposals to narrow their differences. Expect continued upward pressure on fuel costs and war-risk insurance for Gulf-related routings.

TRADE, TARIFF, AND CBP UPDATES

Section 301 China Vessel Fees: Suspension Extended, Industry Pushes for Permanent Elimination
In October 2025, the administration imposed Section 301 fees on Chinese-built or -operated vessels. The fees were suspended until November 9, 2026, and the administration has now moved to extend the suspension to January 9, 2027, as negotiations with China on shipbuilding and maritime issues continue. A joint letter to USTR, signed by 250 trade associations including WSSA, supports the extension and urges that the fees be permanently eliminated. The letter notes that China-built vessels make up a meaningful share of global carrier capacity, so the fees would add another cost layer to supply chains that are already strained. Read the joint letter here.

Tariff Litigation Watch
We are keeping our eye on all of the open litigation regarding tariffs. On the Canada Section 338 tariffs, oral arguments are planned for January, with the plaintiffs arguing that this particular trade law should have been superseded by Section 301 and thus should not be applicable.

On IEEPA Phase 3, a consent motion was filed on November 5 by the lead plaintiff, a key procedural step in moving the class certification process to the next phase. Both sides must now submit proposals on how the potential class-wide refund process will work, with a due date of December 14. We will continue to monitor and update. We recommend that you continue to track any finally liquidated entries with IEEPA payments, since some individual filing deadlines begin as early as February 2027.

On the Section 301 forced-labor tariffs, briefs have been filed, but there has been no significant movement or update, and tariffs of 10% and 12.5% continue to be in place on goods from 60 trading partners. The CIT has requested lists of the specific countries that the plaintiffs import from, as the government has argued that the plaintiffs will lack standing to challenge tariffs on any country they do not source from.

AGOA (African Growth and Opportunity Act) Change
USTR announced on Tuesday, November 3 that the President intends to pull South Africa and Rwanda from the trade preferences under AGOA. AGOA was enacted to provide duty-free access for products from designated African countries imported into the U.S. South African wine was included in this program and will potentially lose its duty-free status as of January 1, 2027, at which point the normal MFN duty will apply on top of the 12.5% Section 301 tariff. There may be additional developments, as South Africa has expressed interest in addressing the concerns of the U.S. administration. We will keep you posted on any changes, but for now, expect to pay more duty on South African wine on January 1.

CBP Proposes New Requirements for Foreign Importers of Record; IOR Voiding Under Review
CBP will publish a Federal Register notice on November 6 that, beginning January 5, 2027, would require foreign importers of record to either use a CTPAT-participating broker or be CTPAT validated themselves. The notice is available now on the Federal Register public inspection site: 2026-22735. If you import through a foreign IOR arrangement or work with foreign suppliers that act as importer of record, please review it and reach out with questions.

Separately, some CTPAT-certified importers have received notices from CBP saying their IOR numbers will be voided unless their Form 5106 data is corrected, without specifying what needs correcting. We understand the trade has raised concerns, and CBP has agreed to review the initiative and may soon rescind the notices until it finds a better approach. If you received one, please double-check your 5106 data and let us know. We will share updates as they develop. Both topics will be covered in our November 17 webinar.

CBP Announces New Portal Test
CBP has announced a test of a new “Client Representative Technical Assistance Portal,” acronym CRTAP. The news was published in the Federal Register on November 4 under document 2026-22501 (91 FR 69566) and is a general notice of this new system to provide a secure method to communicate information and improve the stakeholder experience. The launch is scheduled for December 4, 2026, and will continue for 45 days, with potential extension. The test is open to customs brokers, self-filers, FTZ operators, AES users, and AMS users. If you are interested in participating, send an email to gmb.clientrepoutreach@cbp.dhs.gov with the subject line “Comments/Questions on CRTAP test.”

WSSA Webinar: The New Era of Customs Enforcement – November 17
Join us on Tuesday, November 17 at 3:00 pm ET (live on Zoom, 60 minutes with Q&A) to learn what Executive Order 14411 means for all importers. William Ferrara, Cofounder and President of Harbour Island Consulting and former Executive Assistant Commissioner of CBP’s Office of Field Operations, will cover how to stay an “importer in good standing,” the new importer of record (IOR) requirements and why CBP can now void your IOR number, new rules for foreign importers of record, CBP’s advance notice of proposed rulemaking on supply chain disclosures, what is driving the rise in customs exams, and how to manage CF29s and penalty notices. Key deadlines are close: November 30 for the IOR registry cleanup and December 1 for comments on the ANPRM. This event is free for WSSA members and $50 for non-members. To register, email info@wssa.com with your name, company, and email address, and include any questions for Mr. Ferrara.

New Export Code for American Single Malt Whiskey
The U.S. International Trade Commission has approved a new export code for bottled American Single Malt Whiskey, effective January 1, 2027. The request was led by DISCUS, with support from the American Single Malt Whiskey Commission and the American Whiskey Association. These exports have historically been reported within the broad “other whiskey” category, which made it impossible to track the category’s export growth. The new code will provide that visibility.LCL

Services from France, Italy, and Spain/Portugal
Space is available on November sailings, so you can get your urgent holiday orders moving in time. Bi-monthly departures continue from each of these countries for your small shipments, with a per-case rate from the point of pickup to the Alba Wine and Spirits warehouse in Edison, New Jersey. All containers continue to run as operating reefers, so your cargo stays protected from fall heat. Shipments from other European countries can be added to the mix, with pickups offered in most European countries. Please let us know if you need more information!