ITC Strawberry Imports Ruling, OFAC License, USTR Investigation, FMC Rules
Summary
The FCC reported on an ITC ruling finding injury from Mexican strawberry imports and an OFAC general license authorizing certain transactions related to Russian oil. It also noted a USTR investigation and FMC rules concerning ocean carriers.
What changed
This update covers several regulatory actions. The International Trade Commission (ITC) determined on March 12, 2026, that fresh winter strawberry imports from Mexico are harming the U.S. domestic industry, with a further investigation phase to be announced. The Office of Foreign Assets Control (OFAC) issued General License 134, effective March 12, 2026, through April 11, 2026, authorizing specific transactions related to the sale of Russian-origin crude oil and petroleum products, including those from sanctioned entities.
Regulated entities involved in international trade, particularly those dealing with agricultural imports from Mexico or petroleum products originating from Russia, should review these developments. Importers of strawberries should prepare for potential further ITC actions. Companies engaging in transactions related to Russian oil must adhere to the specific conditions and timeframe outlined in OFAC's General License 134 to avoid violations. The USTR investigation and FMC rules also warrant attention for relevant parties in the transportation and trade sectors.
What to do next
- Review ITC's determination regarding Mexican strawberry imports and prepare for the final investigation phase.
- Ensure all transactions related to Russian-origin crude oil and petroleum products comply with OFAC General License 134 by April 11, 2026.
- Monitor USTR investigation and FMC rules for potential impacts on trade operations.
Source document (simplified)
March 16, 2026
Week in Review (March 9, 2026)
Husch Blackwell LLP + Follow Contact LinkedIn Facebook X Send Embed ITC Finds Strawberry Imports from Mexico Harming US On March 12, 2026, the International Trade Commission (“ITC”) determined that imports of fresh winter strawberries from Mexico, under Harmonized Tariff Schedule 0810.10.40, are injuring the U.S. domestic industry. The ITC will issue a further update announcing the final phase of the investigation via a scheduling notice published in the Federal Register. Interested parties who have not yet filed an appearance may do so after publication of the notice of commencement of the final phase of this investigation.
OFAC Issues General License Authorizing Certain Transactions Related to Sale of Crude Oil and Petroleum Products
On March 12, 2026, the Office of Foreign Assets Control (“OFAC”) issued General License 134 authorizing all transactions “ordinarily incident and necessary to the sale, delivery, or loading of crude oil or petroleum products of Russian Federation origin loaded on any vessel, including vessels blocked…on or before 12:01 a.m. eastern daylight time, March 12, 2026…through 12:01 a.m. eastern daylight time, April 11, 2026.”
According to GL 134, transactions that are ordinarily incident and necessary include:
- Transactions for the safe docking and anchoring of vessels carrying crude oil or petroleum products;
- Preservation of health and safety of the crew of such vessels;
- Emergency repairs or environmental mitigation or protection activities related to any such vessels; and
- Services such as vessel management, crewing, bunkering, piloting, registration, flagging, insurance, classification, and salvage. The GL also specifies that the Russian Federation-origin crude oil and petroleum products include those products produced by entities sanctioned under the Russian Harmful Foreign Activities Sanctions Regulations (31 C.F.R. part 587) or the Ukraine/Russia-Related Sanctions Regulations (31 C.F.R. part 589)
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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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