CBP will deploy Phase 3 of its CAPE tariff refund system on October 6, covering IEEPA entries that have reached final liquidation status. The catch: Phase 3 is only available to importers who are active plaintiffs in a pending case at the U.S. Court of International Trade. There is no administrative path for finally liquidated entries. No court order, no refund.
The CIT has been issuing reliquidation orders quickly — sometimes within a week of filing. But October 6 is approaching fast.
If you have finally liquidated IEEPA entries, contact trade counsel today.
CRITICAL NOTE: This filing will get you in line and protect your refund capability; it does not mean you will receive your refunds immediately. The filing deadline is February 2027 for the China IEEPA and April 2027 for all other IEEPA tariffs. Only companies that have filed 1581(i) by July 30th can start on October 6th. If a company filed 1581(i) after July 30th, they will have to wait until they receive their court order of eligibility to file in CAPE 3.
On July 24, 2026, new Section 301 forced-labor tariffs took effect on imports from 60 countries — covering most product categories and most of the world's major trading partners — at rates of 10% or 12.5%. Legal challenges followed almost immediately: 25 state attorneys general, two private importers, and a consumer advocacy group have now asked the Court of International Trade to invalidate or halt the tariffs.
The administration's answer is due October 2. But the tariffs are being collected today.
We broke down what's covered, what's exempt, and what importers should be doing while the courts catch up.
All 178 Section 301 product exclusions on Chinese-origin goods expire at 11:59 p.m. ET on November 9, 2026 — and as of now, USTR hasn't opened a new public comment period, which is typically the first signal that another extension is coming.
That doesn't mean an extension won't happen. But it does mean that importers relying on these exclusions shouldn't wait to find out.
We have written a 60-day action plan: how to confirm eligibility, model your duty exposure, and know what to watch for between now and November.
The forced-labor Section 301 tariffs — 10% to 12.5% on imports from 60 countries — are now in effect and being collected. A second wave of overcapacity tariffs targeting electronics, semiconductors, steel, batteries, and industrial goods across 16 economies is still pending. And the litigation clock is running alongside all of it.
Q4 is the window to get ahead of this. That means verifying your tariff tiers, checking exemptions at the line-item level, reviewing your customs bond, and mapping your exposure to the overcapacity investigation.
We put together a full action checklist for importers navigating the next 60 days.
California Prepares for a Potentially Historic El Niño
California has declared a state of emergency as officials prepare for an El Niño season forecast to be potentially historic in strength. The proclamation allows the state to stage flood-control supplies, prepare highways and critical infrastructure, and coordinate resources ahead of possible heavy rain, flooding, landslides, coastal impacts, and road closures. For importers and logistics teams moving freight through California, the announcement is an early reminder to build weather-related transportation disruptions and additional lead time into winter planning.
President Donald Trump welcomed Chinese President Xi Jinping to the White House on September 24 for a high-stakes state visit that includes meetings and a state dinner. While specific outcomes have yet to emerge, the talks are expected to draw close attention from businesses involved in U.S.-China trade. Importers should watch for any developments involving tariffs, market access, supply chains, or broader trade policy, while avoiding operational changes until specific measures and implementation details are announced.
