USTR Proposes Section 301 Tariffs on Brazil
On June 1, 2026, the United States Trade Representative (“USTR”) proposed under Section 301 of the Trade Act of 1974 (“Section 301”) to impose tariffs on imports of goods from Brazil due to Brazil’s practices involving digital trade and electronic payment services, unfair and preferential tariffs, anti-corruption enforcement, intellectual property protection, ethanol market access, and illegal deforestation.
On June 1, 2026, President Trump issued a proclamation reducing tariff rates on certain agricultural equipment, mobile industrial equipment and machinery, and heating, ventilation and air conditioning (“HVAC”) equipment under Section 232 of the Trade Expansion Act of 1962 (“Section 232”). In the same proclamation, President Trump also added aluminum lithographic plates and steel racks to the list of aluminum and steel derivative products subject to Section 232 tariffs.
On June 3, 2026, President Trump issued an executive order (“EO”) directing U.S. Customs and Border Protection (“CBP”) to reform many of its enforcement provisions. Titled “Strengthening Customs Enforcement,” the EO targets preventing the importation of unlawful and dangerous goods, tightening eligibility and identification requirements for importers of record (“IORs”), and ensuring compliance with Federal laws and timely collection of duties.
On June 2, 2026, the United States Trade Representative (“USTR”) proposed tariffs under Section 301 of the Trade Act of 1974 (“Section 301”) on imports from 60 countries for their failure to enforce prohibitions related to forced labor. The USTR found that these failures are unreasonable and burden U.S. commerce. The proposed tariffs range from 10% to 12.5%, though they do contain several carveouts.
On June 1, 2026, President Trump issued a proclamation reducing tariff rates on certain agricultural equipment, mobile industrial equipment and machinery, and heating, ventilation and air conditioning (“HVAC”) equipment under Section 232 of the Trade Expansion Act of 1962 (“Section 232”). In the same proclamation, President Trump also added aluminum lithographic plates and steel racks
On May 29, 2026, the Office of the U.S. Trade Representative announced it initiated an investigation of Vietnam under Section 301 of the Trade Act of 1974 (“Section 301”) regarding the country’s intellectual property protection and enforcement.
The USTR had identified Vietnam as a “Priority Foreign Country” in its April 30, 2026 Special 301 Report
On May 29, 2026, the U.S. Department of Justice (“DOJ”) indicated that it will appeal the U.S. Court of International Trade’s (“CIT”) universal injunction ordering U.S. Customs and Border Protection (“CBP”) to reliquidate final entries (entries more than 90 days past liquidation) and refund duties paid under the International Economic Emergency Powers Act (“IEEPA”) by
On April 15, 2026, the U.S. Court of International Trade (“CIT”) ordered U.S. Customs and Border Protection (“CBP”) and the Commerce Department’s Bureau of Industry and Security (“BIS”) to sit for depositions in a case filed by an importer seeking refunds of tariffs imposed under Section 232 of the Trade Expansion Act of 1962 (“Section 232”).
This update covers three key developments this week: (1) U.S. Customs and Border Protection (“CBP”) filed its latest status update in Euro-Notions on April 14, 2025; (2) Judge Eaton thereafter issued another order; and (3) next steps / recommendations for importers.
[UPDATED: This post has been updated to incorporate CBP’s April 13, 2026 CSMS #68340863] U.S. Customs and Border Protection (“CBP”) issued guidance today explaining importers must utilize the Automated Commercial Environment (“ACE”) portal to request consolidated refunds of tariffs imposed under the International Emergency Economic Powers Act (“IEEPA”) which were found to be