Tariff Updates

Previous Updates

• July 27, 2026: Trade Compliance Update: USTR Announces New Tariffs Tied to Forced Labor Enforcement Policies

  The Office of the U.S. Trade Representative (USTR) has announced the final results of its Section 301 investigations concerning trading partners' adoption and enforcement of import prohibitions on goods produced with forced labor. As part of this action, additional tariffs of 10% or 12.5% will be imposed on imports from certain countries, with rates varying based on each country's commitments to establish and enforce forced labor import restrictions, on or after 12:01 a.m. ET on July 24.  Please see CSMS# 69326983 for additional information and complete list of new tariffs, which can be found here - CSMS # 69326983 - GUIDANCE: Section 301 Forced Labor Import Duties

  Takeaways for Importers

  • The action applies to 60 U.S. trading partners, representing the vast majority of U.S. imports.
  • Countries that have committed to implementing and enforcing forced labor import prohibitions will generally be subject to a 10% tariff.
  • Countries that have not adopted such prohibitions will generally be subject to a 12.5% tariff.
  • The tariffs are expected to apply to most imports from the covered countries, although several product categories are exempt.
  • This will apply in addition to current section 301.

  Exemptions to note

  The announced tariffs do not apply to certain categories of goods, including:

  • Informational materials, donations, and accompanied baggage
  • Products already subject to Section 232 tariffs
  • Certain raw materials and products where additional duties could create supply shortages, economic disruption, or where alternative sourcing is not readily available
  • Other products identified in the applicable Federal Register notice

  Compliance Considerations

  Importers should continue to monitor forced labor compliance requirements closely. U.S. Customs and Border Protection (CBP) continues to actively enforce U.S. forced labor laws through measures such as Withhold Release Orders (WROs) and importer due diligence expectations. Importers sourcing from affected countries should monitor future guidance from USTR and CBP.

  In light of these developments, importers should evaluate their current Customs bond to ensure it remains sufficient and compliant with CBP requirements. Customs bond requirements are primarily found in 19 CFR Part 113 (CBP Bonds).

  Source

  Office of the U.S. Trade Representative (USTR), Section 301 Investigations Relating to Failures to Take Action on Forced Labor, and related agency announcements regarding forced labor enforcement and tariff actions.

  Fact Sheet: USTR Section 301 Action in Response to the Failure of 60 Economies to Ban Imports Produced with Forced Labor

  See also - Section 301 of the Trade Act of 1974, effective July 24, 2026

  FLIP 301 Investigation Final Action FRN 7-23-26 FINAL.pdf

• April 3, 2026: Adjustments To Section 232 Tariffs On Metals; Announces Pharmaceutical Import Tariffs Announced

  Based on a CSMS message sent out Friday, U.S. Customs and Border Protection (CBP) will deploy Phase 1 of the Consolidated Administration and Processing of Entries (CAPE) tool on April 20 through the ACE Secure Data Portal. CAPE is designed to streamline International Emergency Economic Powers Act (IEEPA) duty refund requests that are authorized by court order and applicable statutory authority by providing an electronic submission process.

  CAPE allows CBP to consolidate IEEPA duty refunds—rather than processing refunds on an entry-by-entry basis. The tool will be implemented in phases, with additional functionality added over time to address more complex scenarios. Phase 1 will apply to certain unliquidated entries and certain entries that are within 80 days of liquidation.

  To request IEEPA duty refunds through CAPE, the following steps apply:

  • Importers of Record (IORs) and authorized customs brokers must have an active ACE Secure Data Portal account
  • Refund recipients must provide bank account information in the ACE Portal for ACH refunds
  • IORs or authorized brokers must submit CAPE Declarations through the ACE Portal

  The CAPE process begins when the IOR or authorized broker submits a CAPE Declaration. Once accepted, CBP will remove the IEEPA Harmonized Tariff Schedule number, recalculate duties without IEEPA, and update the entry version. CBP will then review and liquidate the entry. Refunds will be consolidated by IOR (or the party designated via CBP Form 4811) and liquidation date.

  CBP requires all Importers of Record planning to submit CAPE Declarations to confirm they have ACE Portal access and that their ACH refund banking information is up to date.

  Averitt can assist in filing entries for you

   

  We will gladly assist you in filing these entries; however, additional charges will apply. Please reach out to your coordinator if you would like to begin this process.

   

  Please note, if Averitt Customs Brokers files these on your behalf, it is still very important that the Importer of Record is set up with CBP on the ACE portal, as this is still required to receive payment.

   

  For additional information about ACE Portal access and ACH refunds visit the resources below: 

  • One Page Overview: ACH Refund Enrollment
  • Frequently Asked Questions: ACE Portal and ACH Refunds FAQs
  • Training Video: Applying for an ACE Portal Importer Account and Enrolling in ACH Refunds
  • Training Guide: ACE Portal Importer Account Application
  • Training Guide: ACH Refund Enrollment in the ACE Portal
  • Rejected ACH Refund Information: Replacement Refund Instructions
    

  To learn more about CAPE functionality in ACE, please see the CAPE Information Notice. For more information on the CAPE filing process, please see the CAPE Refund Quick Reference Guide. 

• March 9, 2026: CBP Preparing ACE Updates for IEEPA Tariff Refunds, but Processing Not Yet Ready

  On March 6, Customs and Border Protection (CBP) informed the Court of International Trade (CIT) that it is not yet able to process the court‑mandated refunds of IEEPA‑related tariffs. However, the agency noted that ACE programming necessary to carry out the refunds could be completed within approximately 45 days.

  According to the filing, signed by Brandon Lord, Executive Director of the CBP Office of Trade, the agency is required to "liquidate any and all unliquidated entries subject to IEEPA duties without regard to those duties, and reliquidate any liquidated but non‑final entries in the same manner."

  Lord also stated that CBP expects to build new ACE functionality that will allow refunds—including interest—to be consolidated by importer, rather than issuing over 53 million individual entry‑specific refunds. This consolidation is intended to make the refund process significantly more efficient.

  CBP outlined a tentative workflow for the new ACE process, noting that operational, legal, and technical factors may still require adjustments. The anticipated steps include:

  1. Importers submitting an ACE declaration listing entries on which IEEPA duties were paid.
  2. ACE performing validations and automatically recalculating duties excluding IEEPA tariffs (plus applicable interest).
  3. CBP reviewing and processing refunds as quickly as feasible.
  4. ACE automatically finalizing (liquidating or reliquidating) the entries.
  5. ACE aggregating refund amounts and interest by importer and liquidation date.
  6. CBP certifying the refund totals.
  7. The Department of the Treasury issuing the refunds electronically.

  While CBP is moving forward with preparations, the declaration suggests that completing refunds for all impacted importers could take several months or more.

  This follows the CIT's March 4 order directing CBP to liquidate unliquidated entries without IEEPA duties and to reliquidate eligible previously liquidated entries.

  Averitt is monitoring this situation very closely, and as soon as CBP issues guidance on any actions required from importers, we will reach out directly to those affected to ensure everything is properly addressed.

  At this time, you need to do the following in preparation:

  • Confirm you have your ACE portal set up and it is accessible
  • Ensure you are set up with CBP for ACH Refunds

  For more information on your ACE portal, please visit CBP Modernizes Electronic Refund Enrollment Process
  
  

• March 3, 2026: Update On IEEPA-Related Court Ruling & Section 122 Tariff Implementation

  We would like to provide an important update regarding the recent court ruling impacting IEEPA‑related tariffs and the subsequent implementation of Section 122.

  As you may be aware, the U.S. Supreme Court recently invalidated tariff actions previously imposed under the authority used for the IEEPA‑related measures, which has resulted in significant changes to the tariff structure. Following this ruling, the Administration immediately moved to implement a temporary global import surcharge under Section 122, effective February 24, 2026. This surcharge initially took effect at 10%.

   

  Refund Guidance Is Not Yet Available

  Although the ruling creates a basis for questions regarding possible refunds of previously paid IEEPA tariffs, there is currently no official guidance from U.S. Customs and Border Protection (CBP) regarding:

  • Whether refunds will be issued,
  • How refund claims should be filed, or
  • What documentation or entry status will be required.

  CBP has acknowledged that implementation details are still under review and that updates will follow once available.

   

  We want to assure you that:

  • We are actively monitoring all CBP communications, court developments, and Federal Register notices.
  • We are tracking all policy changes related to both the termination of the IEEPA tariff and the implementation of Section 122.
  • We understand the uncertainty this creates and are fully engaged in reviewing every update as it becomes available.

   

  Next Steps for Importers:

  At this time, no action is required on your part regarding previously paid IEEPA‑related tariffs.

  Once CBP releases official procedures on how to handle past payments—whether through protests, post‑entry corrections, or a new refund mechanism—we will:

  1. Review the guidance immediately,
  2. Assess impacts across affected entries, and
  3. Reach out directly to each importer with tailored next steps and required documentation.

  You have our full commitment that we will keep you informed at every stage. As soon as U.S. Customs publishes definitive instructions on handling IEEPA‑related tariff payments, we will promptly communicate the process to ensure you can take all necessary actions within required timelines.

• April 14, 2026: CBP Launches Phase 1 of CAPE for IEEPA Duty Refunds on April 20

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