Part 1: IEEPA Refund Update
On March 31, 2026, U.S. Customs and Border Protection (CBP) filed an updated declaration before the U.S. Court of International Trade in Atmus Filtration, Inc. v. United States (Court No. 26-01259), reporting on the latest progress in developing its IEEPA duty refund processing system, known as the Consolidated Administration and Processing of Entries (CAPE).
Latest Development Status
CBP reported the following completion percentages for each CAPE component as of March 30, 2026:
- Claim Portal – 85% complete
- Review and Liquidation/Reliquidation – 80% complete
- Refund – 75% complete
- Mass Processing – 60% complete
Key Updates Since Prior Declarations
- Expanded Phase 1 Scope. CBP has expanded the scope of CAPE Phase 1 beyond unliquidated entries to include entries with liquidation statuses of “Suspended,” “Extended,” or “Under Review,” as well as warehouse and warehouse withdrawal entries and entries liquidated within the preceding 80 days, specifically to ensure that processing can be completed and reliquidation accomplished within the 90-day voluntary reliquidation window under 19 U.S.C. Section 1501. Note that entries subject to an open protest will not be refunded in Phase 1.
For these entry categories, CBP will remove the applicable IEEPA Harmonized Tariff Schedule codes, with refunds to follow upon liquidation in the normal course.
- Court-Ordered Limitation on Finally Liquidated Entries. In response to the court’s amended order of March 20, 2026, CBP has advised that processing of finally liquidated entries, those more than 180 days past liquidation, will be addressed in a subsequent phase.
- Phase 1 Coverage. With these parameters, CBP estimates Phase 1 will be capable of processing approximately 63% of all entries for which IEEPA duties were paid or deposited within 45 days unless there is a compliance concern necessitating further review.
- Electronic Refund Enrollment Progress. As of March 26, 2026, 26,664 importers of record have completed enrollment to receive electronic refunds, representing 78% of entries subject to IEEPA duty payments, with a principal duty amount of approximately $120 billion.
- Next Refund Process Update. Pursuant to court order, CBP will submit an update on April 14.
Part 2: Metals — Steel, Aluminum, and Copper
On April 2, 2026, President Trump issued a proclamation restructuring U.S. import tariffs for steel, aluminum, and copper under Section 232 of the Trade Expansion Act of 1962. The executive action takes effect April 6, 2026, impacting metal tariff rates and valuation for derivative products. Derivative products include: specific machinery; window and door frames; kitchen sinks and stainless counter tops; household appliances and cookware; flatware and cutlery; hardware and fasteners; electrical conductors and conduit; wind turbine components; industrial machinery including cranes, excavators, and conveyors; agricultural equipment; motor vehicles, trailers, and railway equipment; intermodal shipping containers; pumps, compressors, and heat exchangers; and aluminum and steel tanks and storage vessels.
Overview
The April 2026 proclamation on metals consolidates all prior Section 232 actions on steel (Proclamation 9704), aluminum (Proclamation 9704, as amended), and related derivative articles into a single, unified tariff framework. All prior product-specific and country-specific exclusion mechanisms under the earlier regimes are eliminated and replaced by the structure described below. The new framework is effective for goods entered on or after April 6, 2026.
Steel
The proclamation subjects full steel mill products to a 50% ad valorem tariff on full customs value, regardless of origin. The derivative article framework is summarized below.
New Section 232 Tariff rates effective April 6, 2026
| Category | Rate | Key Harmonized Tariff Schedule (HTS) Headings / Examples |
|---|---|---|
| Steel mill products | 50% | 7206-7229, 7301-7306 (flat-rolled, alloy, stainless, tubes, pipes, wire, rails) |
| Derivative steel articles (standard) | 25% | 7321-7324 (appliances, sanitary ware), 8429-8433 (construction/agricultural machinery), 8482-8483 (bearings, transmission parts), 8501-8504 (motors, generators, transformers), 8601-8609 (railway equipment), 8701-8708 (tractors, motor vehicles), 8716 (trailers), 9406.20.00 (prefabricated steel buildings) |
| Derivative articles — U.S.-melted/poured steel (≥95%) | 10% | Same derivative headings as above, where ≥95% of steel content melted and poured in the U.S. |
| Derivative articles —Annex III(temporarily reduced) | Reduced until Dec. 31, 2027, then 25% | Metal-rolling mill rolls (8455), machining centers (8457), industrial robots (8428.70), injection molding machines (8477), large transformers >10,000 kVA (8504.23), molds and dies (8480) |
| Exempt articles —Annex II | 0% (removed from scope) | Certain engines and engine parts (8407-8409), motorcycles and parts (8711, 8714), armored vehicles (8710), fire extinguishers (8424.10), certain cast iron cookware (7323.91-7323.92), certain furniture and athletic equipment (9401, 9506) |
| Russian Federation steel/derivatives | 50% (mill products); additional duties on derivatives | Separate headings under 9903.82.14-9903.82.17 |
| United Kingdom steel/derivatives | 25% (mill products); 15% (derivatives) | Headings 9903.82.04-9903.82.05 |
Metal Content Threshold — Steel Derivatives
For derivative articles classified outside Chapters 72-76, the Section 232 derivative tariff applies only where steel constitutes at least 15% of the total weight of the imported article. Articles below this threshold are not subject to derivative duties. This threshold does not affect primary steel mill products (e.g., 7208, 7224), which are subject to the 50% rate in all cases.
In a significant shift from the previous iteration of Section 232 tariffs on steel derivative products, the tariff rates apply to 100% of the value of the product, not just the steel portion.
Elimination of Public Rulemaking for New Derivative Articles
The prior notice-and-comment process for adding new articles to the derivative list has been eliminated. Additional derivative articles may now be designated by joint determination of the Secretary of Commerce and the U.S. Trade Representative, without public rulemaking. Importers should monitor Federal Register notices.
Aluminum
The proclamation subjects full aluminum mill products to a 50% ad valorem tariff on full customs value, regardless of origin.
New Section 232 Tariff rates effective April 6, 2026
| Category | Rate | Key HTS Headings / Examples |
|---|---|---|
| Aluminum mill products | 50% | 7601 (unwrought), 7604 (bars/rods/profiles), 7605 (wire), 7606 (plates/sheets/strip), 7607 (foil), 7608 (tubes/pipes), 7609 (fittings), 7616.99.51.60 (castings), 7616.99.51.70 (forgings) |
| Derivative aluminum articles (standard) | 25% | 7610 (doors/windows), 7612-7613 (containers), 7614 (cables/wire), 7615 (cookware/household articles), 7616.99.51.30 (ladders), 7616.99.51.40 (venetian blinds), 8302 series (hardware/mountings), wind turbine components (8412.90, 8483.40, 8502.31), various electrical conductors (8544) |
| Derivative articles — U.S.-smelted/cast aluminum (≥95%) | 10% | Same derivative headings as above, where ≥95% of aluminum content smelted and cast in the U.S. |
| Derivative articles —Annex III(temporarily reduced) | Reduced until Dec. 31, 2027, then 25% | Heat exchange units (8419.50), certain transformer parts (8504.34, 8504.90), liquid crystal device parts (9013.90.80), certain spray/dispersing machinery (8424.89.90) |
| Exempt articles —Annex II | 0% (removed from scope) | Beer (2203), personal care preparations (3303-3307), paints and varnishes (3208-3209), certain sports equipment (9506), furniture (9403), fishing reels (9507), photographic plates (3701.30), semiconductor manufacturing equipment (8486.90) |
| Russian Federation —Annex I-A, Annex I-B, or Annex III | 200% (product of Russia or where any amount of primary aluminum used in the manufacture of these articles is smelted in Russia, or these aluminum articles are cast in Russia) | 7601 (unwrought), 7604 (bars/rods/profiles), 7605 (wire), 7606 (plates/sheets/strip), 7607 (foil), 7608 (tubes/pipes), 7609 (fittings), 7616.99.51.60 (castings), 7616.99.51.70 (forgings), 7610 (doors/windows), 7612-7613 (containers), 7614 (cables/wire), 7615 (cookware/household articles), 7616.99.51.30 (ladders), 7616.99.51.40 (venetian blinds), 8302 series (hardware/mountings), wind turbine components (8412.90, 8483.40, 8502.31), various electrical conductors (8544) |
| United Kingdom aluminum/derivatives | 25% (mill products); 15% (derivatives) | Headings 9903.82.04-9903.82.05 |
Metal Content Threshold — Aluminum Derivatives
For derivative articles classified outside Chapters 72-76, the Section 232 derivative tariff applies only where aluminum constitutes at least 15% of the total weight of the imported article. As mentioned above regarding steel derivative products, the tariff rate is applied to 100% of the value of the imported aluminum derivative product.
Elimination of Public Rulemaking for New Derivative Articles
Same as steel — new derivative aluminum articles may be added by joint Commerce/USTR determination without notice-and-comment rulemaking.
Copper
New Section 232 Tariff rates effective April 6, 2026
| Category | Rate | Key HTS Headings / Examples |
|---|---|---|
| Copper mill products | 50% | 7406 (powders/flakes), 7407 (bars/rods/profiles), 7408 (wire), 7409 (plates/sheets/strip), 7410 (foil), 7411 (tubes/pipes), 7412 (fittings), 7413 (cables/stranded wire), 7415 (nails/screws/bolts), 7418 (household articles), 7419 (other copper articles) |
| Derivative copper articles (insulated conductors) | 25% | 8544.42.10, 8544.42.20, 8544.42.90, 8544.49.10 (insulated electric conductors for telecommunications and general use, ≤1,000V) |
| Derivative articles — U.S.-smelted/cast copper (≥95%) | 10% | Same derivative copper headings where ≥95% of copper content smelted and cast in the U.S. |
| Russian Federation copper/derivatives | Additional duties apply | Headings 9903.82.14-9903.82.16 |
Metal Content Threshold — Copper Derivatives
For derivative articles classified outside Chapters 72-76, the Section 232 derivative tariff applies only where copper constitutes at least 15% of the total weight of the imported article. As mentioned above regarding steel and aluminum, the tariff rate applies to 100% of the value of the copper derivative product.
Key Structural Changes Applicable to All Three Metals
- No Country Exemptions. Unlike the prior regime, which provided country-specific exemptions and quota arrangements for certain trading partners, the new framework applies to all countries of origin, with narrow carve-outs only for the United Kingdom (at reduced rates) and the Russian Federation (at elevated rates).
- Stacking with Other Duties. Section 232 tariffs are imposed in addition to any applicable column 1 rates, antidumping duties, countervailing duties, and other charges, including the 10% Section 122 tariffs in effect until July 24, 2026. Free trade agreement preferential rates do not offset or eliminate the Section 232 duties.
