Advisories

Phase 3 of the Consolidated Administration and Processing of Entries (CAPE) system will allow eligible plaintiffs to seek refunds on finally liquidated entries covered by court-ordered reliquidation.

Importers that provided a valid importer of record number to U.S. Customs & Border Protection (CBP) by July 30^th, 2026, can begin filing Phase 3 declarations on that date. CBP is expected to provide further guidance soon.

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In response to the Trump Administration’s 50% tariffs on >$27B of Canadian goods, Canada retaliated with its own counter-tariffs ranging from 15% to 50%.

• The full list of affected products can be found here.
• These new countermeasures will be effective as of 12:01 a.m. on September 8^th, 2026.

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In a filing with the U.S. Court of International Trade (CIT), U.S. Customs & Border Protection (CBP) said that it has “temporarily delayed the deployment of CAPE Phase 3, which covers finally liquidated entries filed by plaintiffs for which the Court has ordered reliquidation,” adding that this delay is “necessary for CBP to build new validations that ensure no other duty adjustments are made to finally liquidated entries outside of the IEEPA duty refunds.”

• So far, U.S. Customs has accepted 26.4M entries for processing, accounting for approximately $132.5B in both potential and certified refunds.

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The United States Trade Representative (USTR) will impose an additional 25% ad valorem duty on certain imports from Brazil following its Section 301 investigation into Brazil’s acts, policies, and practices affecting U.S. commerce.

• The investigation examined Brazilian policies related to digital trade and electronic payment services, preferential tariffs, anti-corruption enforcement, intellectual property protection, ethanol market access and illegal deforestation.

• The additional tariffs will apply to products identified by USTR, with specific tariff classifications and implementation details outlined in the official notice. Importers should review affected HTS classifications and assess potential duty impacts on goods of Brazilian origin.

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The United States Trade Representative (USTR) will enact a 10-12.5% ad valorem duty rate on 60 countries for their failure to stop goods from being produced and/or shipped using forced labor. A country-by-country list can be found here.

• The new levies counter the expiration of a temporary 10% global tariff under Section 122, which was installed after the Supreme Court rejected duties previously imposed under the International Emergency Economic Powers Act (IEEPA).
• For countries with Most-Favored Nation (MFN) rates, such as the EU, Japan and South Korea, the tariff charged will be net of the MFN duty.

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