Tariff Updates

Previous Updates

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

  President Trump signed a proclamation on Thursday, April 2, modifying the Section 232 tariffs on steel, aluminum, and copper, and issued a separate executive order establishing new tariffs on pharmaceutical imports.

   

  According to a White House fact sheet, the proclamation revises how Section 232 metals tariffs are calculated to ensure they reflect the full value of imported steel, aluminum, and copper products, rather than values based on artificially low foreign pricing.

   

  The proclamation establishes the following tariff structure for covered metal products:

  • Articles made entirely or almost entirely of steel, aluminum, or copper — such as steel coils and aluminum sheet — will be subject to a 50% tariff on the full value of the product.
  • Derivative articles substantially made of steel, aluminum, or copper will be subject to a 25% tariff on the full value.
  • Certain metal‑intensive industrial equipment and electrical grid equipment will be subject to a 15% tariff through 2027, intended to support and accelerate ongoing U.S. industrial base expansion.
  • Products manufactured abroad using entirely U.S.-origin steel, aluminum, and copper will be subject to a reduced tariff of 10%.
  • Products containing 15% or less steel, aluminum, or copper will no longer be subject to Section 232 metals tariffs.

  The revised tariff rates for steel, aluminum, and copper will take effect at 12:01 a.m. ET on April 6. Additional product‑specific guidance is outlined in Annexes I‑A, I‑B, II, III, and IV to the proclamation.

   

  Pharmaceutical Import Tariffs

  In a separate Executive Order issued under Section 232, President Trump announced the imposition of a 100% tariff on patented pharmaceutical products and ingredients.

  • The tariffs will take effect in 120 days for certain large pharmaceutical companies and within 180 days for smaller companies.
  • Pharmaceutical products originating from the European Union, Japan, Korea, Switzerland, and Liechtenstein will instead be subject to a 15% tariff.
  • Pharmaceutical products from the United Kingdom will be subject to a lower tariff, consistent with the recently concluded UK pharmaceutical agreement.

  The Executive Order provides significant tariff relief for companies that enter into agreements with the U.S. government:

  • Companies that enter into both Most Favored Nation (MFN) pricing agreements with the Department of Health and Human Services (HHS) and onshoring agreements with the Department of Commerce will qualify for a 0% tariff through January 20, 2029.
  • Companies that enter into onshoring agreements only with the Department of Commerce will be subject to a 20% tariff.

  According to the White House fact sheet, the Department of Commerce and HHS will establish formal pathways for companies to participate in onshoring and MFN pricing arrangements.

   

  While we are still awaiting further guidance from U.S. Customs and Border Protection, we wanted to proactively alert you to anticipated changes that may impact upcoming shipments.

   

• 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.