Importers are facing another significant shift in the trade landscape as new Section 301 tariffs have taken effect and the IEEPA refund process continues to evolve through CBP’s CAPE system.
Effective July 24, 2026, the temporary 10% Section 122 tariffs expired and were replaced by new Section 301 tariffs on imports from multiple countries. Depending on the country of origin, the new Section 301 duties range from 10% to 12.5%, while imports from Brazil are now subject to additional Section 301 duties, bringing the total Section 301 tariff rate on many Brazilian products to 37.5%. Certain products remain exempt, and limited in-transit provisions may apply. Importers should carefully review how these changes affect their supply chains and landed costs.
At the same time, the IEEPA refund process continues to move forward. CAPE Phases I and II remain active, allowing eligible importers to submit refund declarations for qualifying entries. CBP has stated that accepted claims continue to be processed, with refunds generally issued by the U.S. Treasury within 60 to 90 days after acceptance.
Looking ahead, CAPE Phase III is expected to expand the refund process to additional categories of entries, although implementation details and eligibility requirements continue to develop. Recent activity before the Court of International Trade also signals continued progress, but ongoing litigation means certain aspects of the refund process remain subject to future court decisions and CBP guidance.
As these developments unfold, importers should also verify that their ACH Refund Authorization is correctly established within the ACE Portal. Because CBP now issues refunds electronically, accurate account information is essential to avoid unnecessary delays.
At 721 Logistics, we continue to monitor these rapidly evolving tariff and refund developments and provide timely guidance to our clients. If your business may be affected by the new Section 301 tariffs or the ongoing IEEPA refund process, our team is here to help you understand what these changes could mean for your imports.
For current clients: We encourage you to review the detailed compliance updates distributed by our Compliance team, which include more comprehensive guidance regarding eligibility, filing considerations, and upcoming CAPE developments. If you need those communications resent, please contact your 721 representative or e-mail info@721logistics.com