IEEPA Refund

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 May 7, 2026, the United States Court of International Trade (“CIT” or “Court”) invalidated Proclamation No. 11012 in The State of Oregon, et al. v. United States, et al. and Burlap and Barrel, Inc., et al. v. United States, et al., holding that the President exceeded his statutory authority in imposing a temporary

IEEPA Refund Updates: CBP Targets May 11 for First IEEPA Duty Refunds

On April 28, 2026, Judge Richard K. Eaton of the U.S. Court of International Trade issued an Order in Euro-Notions Florida, Inc. v. United States, et al. (Court No. 25-00595) addressing early implementation progress for CBP’s new Automated Commercial Environment (“ACE”) functionality designed to refund International Emergency Economic Powers Act (“IEEPA”) duties, including interest. The order follows CBP’s rollout of Phase 1 of its Consolidated Administration and Processing of Entries (“CAPE”) tool on April 20, 2026, and reflects issues raised during a closed conference held on April 28 regarding access, usability, and the treatment of certain categories of entries.