July 14, 2026

New CIT Order may signal Imminent IEEPA Refund Orders

As previously reported, the Government has maintained that individual court orders will be required to obtain refunds of IEEPA duties on entries liquidated more than 80 days prior. Today, the Court of International Trade ("CIT") rescinded it's previous administrative order staying all new IEEPA litigation, which may signal that the CIT is preparing to issue such orders in the near term.

Recommended Action

Importers with entries on which IEEPA tariffs were paid, which were liquidated more than 80 days prior, and that have not yet submitted refund claims through earlier phases of the CAPE refund process should give serious consideration to filing an action at the CIT in the near term, given the accelerated litigation timeline we now anticipate.

Thought Leadership

USTR Imposes Section 301 Forced Labor Tariffs on Goods of 60 Economies, Effective July 24, 2026

July 24, 2026

On July 23, 2026, the Office of the United States Trade Representative (USTR) issued a notice of action concluding 60 parallel Section 301 investigations into the failure of various economies to impose and effectively enforce a prohibition on the importation of goods produced with forced labor. Acting under the specific direction of the President, the Trade Representative is imposing additional tariffs of 10 percent or 12.5 percent on all products of each of the 60 investigated economies, subject to enumerated exemptions. The additional duties apply to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on July 24, 2026.

Thought Leadership

President Trump Invokes Section 338 to Impose 50% Tariffs on Certain Canadian Goods

July 23, 2026

On July 20, 2026, President Trump signed three proclamations imposing an additional 50 percent ad valorem duty on specified baskets of Canadian-origin goods. The duties apply to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern time on August 19, 2026. The proclamations invoke Section 338 of the Tariff Act of 1930 (19 U.S.C. § 1338)—a long-dormant provision that never previously used to impose duties—together with 3 U.S.C. § 301 and Section 604 of the Trade Act of 1974 (19 U.S.C. § 2483).

Thought Leadership

New Section 232 Aluminum Tariff Incentive for U.S. Onshoring Projects

July 21, 2026

On July 20, 2026, the President issued a proclamation establishing a new incentive program under the Section 232 aluminum tariff regime. Companies that commit to building, expanding, or refurbishing U.S. primary aluminum production capacity may be eligible to import a corresponding volume of primary aluminum at half the otherwise-applicable Section 232 duty rate—25% instead of the current 50%.

Thought Leadership

DOJ and DHS Publish Joint Resource Guide to Trade Fraud Enforcement

July 17, 2026

In July 2026, the DOJ/DHS Trade Fraud Task Force published its first joint Resource Guide to Trade Fraud Enforcement. Although the Guide creates no new legal authority, it consolidates the government’s enforcement framework in a single public document and, in doing so, signals how DOJ and DHS intend to investigate, charge, and resolve trade fraud matters. Publications of this kind are infrequent and rarely incidental; the Guide should be read as a statement of enforcement intent.

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