I. Sanctions: OFAC hits a Turkish bank under “Operation Economic Outcast”

On 4 September 2026, the Office of Foreign Assets Control designated the Turkish institution Golden Global Yatirim Bankasi Anonim Sirketi and its two Istanbul subsidiaries under Executive Order 13902 on the Iranian financial sector. The Treasury accuses the bank of providing correspondent banking services that allowed the Quds Force of the Islamic Revolutionary Guard Corps to repatriate oil revenue from China. Iran General License CC authorises the wind-down of ongoing transactions.

The measure is part of Operation Economic Outcast, announced on 24 August 2026, which expressly widens the exposure of foreign financial institutions dealing with Iran to secondary sanctions. On 4 September, the Treasury Secretary stated that the European Union had “officially joined” the campaign. At this stage, the statement from Brussels reflects political support, with no Council decision and no formal alignment on the US designations.

Business implications. The distinction is decisive in law. The Blocking Regulation (EC) No 2271/96 prohibits European operators from complying with US extraterritorial sanctions against Iran without authorisation from the Commission, even as their exposure to secondary sanctions grows. European banks, insurers and freight forwarders should review their counterparty screening and document their decisions.

II. US tariffs: Section 232 duties on drones take effect

The duties imposed by the proclamation of 13 August 2026 under Section 232 of the Trade Expansion Act of 1962 apply to unmanned aircraft systems and their components entered for consumption from 3 September 2026. The rate is 100% for aircraft over 25 kilograms, those fitted with thermal imagers, docking stations and certain critical components, and 25% for others. A 15% cap applies to products originating in the European Union, Japan, South Korea, Switzerland, Liechtenstein and Taiwan, and 10% for the United Kingdom. Equipment on the Blue UAS lists or the FCC conditional approval list as of 2 September benefits from a 180-day deferral.

Business implications. Tariff classification depends on technical criteria (take-off mass, thermal imaging) and not on the tariff nomenclature alone; product data sheets need reviewing.

III. Section 338: first modern use against Canada, and Ottawa responds

The 50% duties imposed by Proclamations Nos. 11046, 11047 and 11048 of 20 July 2026 under Section 338 of the Tariff Act of 1930 have applied since 22 August 2026 to Canadian alcoholic beverages, dairy products and motor vehicles. Recourse to this provision, a dead letter for nearly a century, extends the strategy of falling back on legal bases other than IEEPA. In response, Canada announced surcharges of 15, 25 and 50% on around 27.6 billion Canadian dollars of US imports, applicable from 8 September 2026. Section 232 duties on patented pharmaceuticals, capped at 15% for the European Union, will take effect on 29 September 2026 for companies not listed in Annex III to the proclamation of 2 April 2026.

IV. EU customs regulation: proof of the “melt and pour” country for steel

On 31 August 2026, the Commission adopted the implementing act (OJ L 2026/1963) setting out the evidence importers must provide to establish the country of melting and pouring of steel products covered by Regulation (EU) 2026/1384. Approved unanimously by the Member States on 19 August, it applies from 1 October 2026. The mill test certificate stating the country of melting and the heat number becomes the standard proof; invoices, delivery notes, quality certificates, long-term supplier declarations or customs documents from the exporting country may substitute for it until 1 October 2027, after which they will only be accepted as supporting evidence.

Business implications. The regime under Regulation (EU) 2026/1384 caps duty-free quotas at 18.3 million tonnes and raises the out-of-quota duty to 50%. Documentary traceability now conditions market access: supply clauses should be reviewed before 1 October.

V. Mercosur: Brazilian meat suspended and deadlock on quota allocation

From 3 September 2026, the European Union suspended imports of beef, poultry, eggs and honey from Brazil, as the Brazilian authorities had failed to show compliance with the EU ban on antibiotic growth promoters. The measure is based on the health rules applicable to all imports, not on a safeguard clause of the interim trade agreement. Brasília expressed its indignation and is considering reciprocal measures.

The day before, meeting in Montevideo, Mercosur ministers again failed to agree on the allocation of export quotas to the Union: Uruguay and Argentina argue for a key based on historical exports, Paraguay for an equal split and Brazil for a key based on world trade. The interim agreement has applied provisionally since 1 May 2026; ratification still awaits the opinion of the Court of Justice, requested by a European Parliament resolution of 21 January 2026 and expected at the end of 2026 at the earliest.

VI. Other points to watch

No notable decision of the Court of Justice or the General Court was handed down this week on international trade, sanctions or arbitration, given the judicial vacation. On CBAM, the tolerance allowing operators who applied for authorised declarant status before 31 March 2026 to continue importing under TARIC code Y238 ends in September 2026. In French customs law, no new text: references follow the numbering introduced by Ordinance No. 2026-265 of 8 April 2026, in force since 1 May 2026 (Articles L. 111-1 et seq.).

For advice on an international trade transaction or dispute, see our page on international trade law and, on this week’s topics, our pages on international sanctions and customs law, as well as those on foreign investment in France, international commercial litigation and enforcing a foreign judgment.

Previous edition: Weekly Digest: International Trade Law (24-30 August 2026)
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