Tariff Updates

CAPE Phase 1

The Consolidated Administration & Processing of Entries (CAPE) system goes live on Monday, April 20^th, and is only accessible via the ACE Portal. CAPE is still quite limited in scope, but it 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.

IEEPA Tariff Refunds: Support Available for ACH Refund

Although refund procedures have not been announced, importers should ensure their ACH refund accounts are properly configured with CBP. Having ACH refund capability in place will help prevent delays if/when refunds are authorized.

Because the refund process is still uncertain, filing a protest with U.S. Customs & Border Protection (CBP) is the best way to preserve your right to a refund. If you have not yet established or confirmed your ACH refund setup, we strongly recommend doing so as a proactive measure. 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)

Supreme Court Rejects IEEPA Tariffs

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.

In-Transit Provision: U.S. Customs and Border Protection (CBP) provided guidance on its IEEPA webpage concerning the applicability of the in-transit provision. The in-transit provisions for reciprocal tariffs only apply to the vessel mode of transportation and do not apply to other modes of transportation, such as air, rail, truck, etc.

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.

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. 

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

On October 30^th, the U.S. agreed to delay the imposition of higher tariffs against 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.

As of August 7^th, 2025, the U.S. has 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.