Tariffs & Trade

On July 15, 2026, the Court of International Trade (“CIT”) issued an order which is the clearest indication of the next steps for addressing the status of finally liquidated entries where IEEPA tariffs were paid. Specifically, the CIT expects U.S. Customs and Border Protection (“Customs”) to launch Phase 3 of its CAPE platform for tariff

On July 9, 2026, President Donald Trump issued a proclamation titled Adjusting Imports of Commercial Aircraft, Jet Engines, and Aircraft and Engine Parts into the United States. The proclamation provides that tariffs under Section 232 of the Trade Expansion Act of 1962, as amended, 19 U.S.C. § 1862 (Section 232), will not be imposed on imports of commercial aircraft, jet engines, or related parts, notwithstanding allegations that such imports pose a threat to national security.

Companies importing consumer products into the United States now face a significant compliance change. As our colleagues on Product Perspective explain, effective July 8, the U.S. Consumer Product Safety Commission’s (CPSC) new eFiling requirement requires importers to electronically submit product safety certificate information at the time of entry.

On June 29, 2026, U.S. Customs and Border Protection (CBP) released CSMS # 69087399, providing guidance for the import adjustment offset program applicable to Section 232 duties on automobile and medium and heavy-duty vehicle (MHDV) parts. We summarize below the latest guidance from CBP and procedural steps for claiming offsets against Section 232 duties.

On June 11, 2026, the U.S. Court of Appeals for the Federal Circuit (CAFC) granted the federal government’s motion for a stay pending appeal, pausing enforcement of a U.S. Court of International Trade (CIT) injunction on the collection of Section 122 duties against the State of Washington and two private businesses – Burlap and Barrel, Inc. and Basic Fun, Inc.

The U.S. Government withdrew its petition for a writ of mandamus at the U.S. Court of Appeals for the Federal Circuit (“Federal Circuit”). On June 9, 2026, the Federal Circuit granted the Government’s request to withdraw the petition and dismissed the mandamus proceeding in In re United States, Fed. Cir. # 26-144, before Senior Judge Richard K. Eaton.

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.