Tariff Updates

IEEPA Tariff Refunds: ACH Support Available

Importers must ensure their ACH refund accounts are properly configured with CBP. If you have not yet established or confirmed your ACH refund setup, we strongly recommend doing so. Filing a protest:

• Preserves your refund rights
• Protects you if CBP requires protests as part of the refund process
• Ensures your claim remains active while litigation continues

Failing to file a protest within 180 days of the liquidation date could jeopardize your ability to recover any paid duties. Learn more about the liquidation process here.

OIA Global can help in several ways:

• Review your entry data to identify eligible IEEPA-affected shipments
• Track liquidation dates to ensure deadlines are met
• Prepare and file protests on your behalf
• Submit protests in batches to improve efficiency
• Coordinate with your legal counsel (If applicable)

CAPE Phase 2

July 7^th, 2026: CBP officially launched Phase 2 of the CAPE rollout, expanding refund eligibility to include certain reconciliation-flagged entries. Importers with eligible entries that were previously excluded should review their records, as additional refunds may now be available. There is still no mechanism for entries that have already liquidated and are beyond the 80-day Phase 1 filing deadline.

CAPE Phase 1

April 20^th, 2026: Phase 1 of the Consolidated Administration & Processing of Entries (CAPE) system went live via U.S. Customs & Border Protection’s (CBP) ACE Portal. Although still limited in scope, CAPE does allow importers to reclaim IEEPA duties and interest. Importers should continue to monitor entry liquidation statuses, as the liquidation date is the deciding factor for use of the CAPE system.

Section 232 Metals

Key Changes (Effective April 6^th, 2026, 12:01 a.m. ET)

Tariffs will now be assessed based on the full value of imported goods—not reduced foreign pricing. 

• 50% tariff: Articles made entirely or almost entirely of steel, aluminum, or copper (e.g., coils, sheets).
• 25% tariff: Derivative products substantially made of these metals.
• 15% tariff (through 2027): Certain metal-intensive industrial and electrical grid equipment to support U.S. industrial expansion.
• 10% tariff: Products manufactured abroad using entirely U.S.-origin metals.

Exemption: Goods containing 15% or less of these metals are no longer subject to Section 232 tariffs.

June 1, 2026: The U.S. made temporary adjustments to Section 232 tariffs on steel, aluminum, and copper imports, targeting specific types of agricultural and industrial goods. 

• Agricultural equipment (combines, harvesters, etc.) reduced to 15% tariff rate (previously 25%) 

• Aluminum lithographic plates and steel racks have been added to the list of derivative products that qualify for the 25% tariff rate.  

The changes will stay in effect until Dec. 31^st, 2027. 

Section 232 Pharmaceuticals

100% tariff on patented pharmaceutical products and ingredients. Effective in 120 days for large companies (July 31^st, 2026) and 180 days for smaller companies (September 29^th, 2026).

Reduced tariffs (15%) apply for certain places: EU, Japan, Korea, Switzerland, Liechtenstein, and the United Kingdom (per recent agreement).

0% tariff available through Jan. 20^th, 2029, for companies entering Most Favored Nation (MFN) pricing agreements with the U.S. Department of Health and Human Services, and onshoring agreements with the Department of Commerce. 20% tariff applies if only onshoring agreements are executed.

July 30^th 2025, Executive Order: The U.S. suspended the duty-free de minimis classification for all countries, which applied to parcels valued <$800. The order took effect on August 29^th, 2025. 

March 4^th, 2026: the U.S. Court of International Trade ordered U.S. Customs and Border Protection (CBP) to liquidate certain unliquidated entries without applying IEEPA duties and to reliquidate entries that are not yet final, potentially paving the way for refunds.

March 6^th, 2026: CBP informed the court it is not yet ready to process refunds but expects it could develop the necessary functionality in the Automated Commercial Environment (ACE) within approximately 45 days. The anticipated process may require importers to identify affected entries, after which ACE would validate them, recalculate duties without IEEPA tariffs, and aggregate potential refunds and interest before payments are issued by the U.S. Treasury.

Supreme Court Rejects IEEPA Tariffs

February 20^th, 2026: Following a key Supreme Court decision that invalidated tariffs under the International Emergency Economic Powers Act (IEEPA), the Trump Administration implemented a new 10% global tariff under Section 122 of the 1974 Trade Act. This is a new tariff under a different legal authority and is not automatically affected by the Court’s ruling on IEEPA. Other tariffs under sections 301 and 232 remain unaffected.

Feb. 3^rd, 2026: The U.S. and India signed a trade deal, reducing India’s tariff rate from 25% to 18%.

October 30^th, 2025: the U.S. agreed to delay imposing higher tariffs on China for another year. As part of a consensus agreement, the U.S. lowered tariffs on imports from China to 10%, down from 20%. A variety of Section 301 and Section 232 tariffs remain in place, and goods from China will still face a duty burden of roughly 47%, according to U.S. Trade Representative Jamieson Greer.

August 7^th, 2025: the U.S. enacted sweeping reciprocal tariffs on imports from 60+ countries, with duties ranging from 10% to over 100%, depending on origin and sector. Additions like sector-specific penalties and anti-transshipment provisions further complicate the trade landscape. The impact on landed costs, sourcing strategies, and compliance protocols will be significant. 

• Mexico got a reprieve, and its current rates were extended for another 90 days.
• The EU delayed its countermeasures by 6 months.
• In an Executive Order, the U.S. imposed an additional 25% tariff on Indian products, effective on August 27, 2025.
• The U.S. will apply a 50% tariff to most Brazilian goods, as part of the Executive Order: Addressing Threats to the United States by the Government of Brazil.