News

April 2, 2026 — Section 232 Tariffs on Pharmaceuticals & APIs

Summary:

The Administration issued a Section 232 proclamation expanding national security tariffs into the healthcare sector. The action targets patented pharmaceuticals and active pharmaceutical ingredients (APIs), introducing tariffs of up to 100%, with reduced rates tied to domestic production commitments.

Key Details:

• Legal Authority:
o Section 232 of the Trade Expansion Act of 1962

• Tariff Structure:
o Up to 100% ad valorem tariff
o 20% tariff available for firms with approved onshoring plans
o Escalation to 100% if commitments are not met

• Scope:
o Covers:
 Patented (branded) pharmaceuticals
 APIs and key starting materials
o Excludes:
 Generics and biosimilars

• Policy Objective:
o Reduce reliance on foreign pharmaceutical supply chains
o Strengthen domestic manufacturing capacity
o Expand national security tariff framework beyond industrial goods

Government Source:

• White House Proclamation
https://www.whitehouse.gov/presidential-actions/2026/04/adjusting-imports-of-pharmaceuticals-and-pharmaceutical-ingredients-into-the-united-states/

CBP CSMS Source:
• Not yet issued (implementation guidance pending)
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April 3, 2026 — Section 232 Duties on Imports of Aluminum, Steel, and Copper (CSMS #68253075)

Summary:

CBP issued comprehensive implementation guidance under CSMS #68253075 following the President’s April 2 proclamation, “Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper into the United States.” The action substantially restructures the Section 232 metals tariff framework by expanding tariffs to apply to the full customs value of covered articles and derivatives, while consolidating administration of steel, aluminum, and copper tariff programs into a unified regime.
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Key Details:
• Effective Date:
o April 6, 2026

• Tariff Rates:
o 50% duty on articles made entirely or almost entirely of steel, aluminum, or copper
o 25% duty on derivative articles substantially made of covered metals
o 15% temporary rate for certain metal-intensive industrial and electrical grid equipment through 2027
o 10% rate for derivatives made entirely from U.S.-origin metals
o 200% duty remains applicable to certain Russia-related aluminum imports

• Major Structural Change:
o Tariffs now apply to the full customs value of covered products, not merely the metal content value

• Product Scope / Exclusions:
o Goods containing ≤15% aggregate covered metal content generally excluded (outside Chapters 72, 73, 74, 76)
o Annex II removes certain products from Section 232 coverage entirely
o Products containing multiple covered metals subject to only one Section 232 duty layer

• Operational & Compliance Requirements:
o Requires updated:
 HTS classification logic
 Chapter 99 sequencing
 ERP / broker tariff calculations
o FTZ entries must generally be admitted under:
 Privileged Foreign Status
o Manufacturing drawback remains available for qualifying claims

• Future Expansion Authority:
o USTR and Commerce authorized to add:
 Additional derivative products
 Filled metal containers
o Existing country-specific arrangements (UK, EU, Japan, Korea) remain in effect unless modified
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Government Sources:
• White House — Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper Into the United States
https://www.whitehouse.gov/presidential-actions/2026/04/strengthening-actions-taken-to-adjust-imports-of-aluminum-steel-and-copper-into-the-united-states/
• Federal Register (implementation publication pending / associated proclamation publication)
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CBP CSMS Source:
• CSMS #68253075 — GUIDANCE: Section 232 Duties on Imports of Aluminum, Steel, and Copper
https://content.govdelivery.com/accounts/USDHSCBP/bulletins/4117593

April 12, 2026 — Section 122 Tariff Enforcement Continues

Summary:

CBP continues strict enforcement of the 10% global tariff under Section 122, with emphasis on correct entry filing and tariff stacking compliance.

Key Details:
• HTS 9903.03.01 remains active
• Applies broadly across imported goods
• Must be reported prior to HTS classification
• Continues to stack with:
o Section 301 tariffs
o MFN duties

Government Sources:
• White House Proclamation
https://www.whitehouse.gov/presidential-actions/2026/02/imposing-a-temporary-import-surcharge-to-address-fundamental-international-payments-problems/

• Federal Register Notice
https://www.federalregister.gov/documents/2026/02/25/2026-03824/imposing-a-temporary-import-surcharge-to-address-fundamental-international-payments-problems

CBP CSMS Source:
• CSMS #67844987
https://content.govdelivery.com/accounts/USDHSCBP/bulletins/40b3b7b
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April 20, 2026 — CAPE Deployment for IEEPA Refund Processing (CSMS #68340863)

Summary:

CBP announced the deployment of the CAPE (Consolidated Administration and Processing of Entries) system to operationalize refunds of duties previously collected under IEEPA tariff programs. This marks the transition from manual and litigation-driven processes to a centralized, ACE-integrated refund mechanism, enabling importers to begin submitting claims at scale.
The deployment follows oversight by the U.S. Court of International Trade and represents a critical step in resolving the financial impact of invalidated IEEPA tariffs.

• System Deployment:
o CAPE portal is now live within ACE
o Enables electronic submission of:
 Refund claims
 Entry-level data (via structured upload)

• Scope of Refunds:
o Applies to duties collected under:
 IEEPA-based tariff programs (now invalidated)
o Includes:
 Country-specific tariffs
 Energy / reciprocal tariff frameworks

• Submission Mechanics:
o Importers or brokers must:
 Submit claims via ACE interface / file upload
 Provide:
 Entry summary data
 Duty payment records
o System supports bulk claim processing

• Refund Processing Workflow:
o CBP will:
 Remove applicable Chapter 99 tariff lines
 Recalculate duties
 Initiate liquidation / reliquidation
 Issue refunds via ACH

• Eligibility & Limitations:
o Initial deployment excludes:
 AD/CVD entries
 Suspended entries
 FTZ / bonded warehouse entries
 Drawback claims
o Separate processes may apply for these categories

• Critical Compliance Considerations:
o Refunds are not automatic
o Importers must:
 Actively file claims
 Monitor liquidation status
o Protest deadlines (19 U.S.C. §1514) remain relevant for certain entries

Government Sources:

• U.S. Court of International Trade oversight of refund process implementation
• Related to Supreme Court ruling invalidating IEEPA tariff authority

CBP CSMS Sources:

• CSMS #68340863 — CAPE Deployment for IEEPA Refunds
https://content.govdelivery.com/accounts/USDHSCBP/bulletins/40f7b7f
• CSMS #67834313 — Termination of IEEPA Tariff Collection
https://content.govdelivery.com/accounts/USDHSCBP/bulletins/40b11c9

April 30, 2026 — Partial Government Shutdown Ends (DHS Funding Restored)

Summary:

Congress passed, and the President signed, legislation restoring funding for most of the Department of Homeland Security (DHS), formally ending a partial government shutdown that lasted from February 14 to April 30, 2026—the longest agency-specific shutdown in U.S. history.
The agreement resolves immediate operational disruptions across key federal security functions, though it excludes immigration enforcement agencies (ICE and CBP), which will be funded through separate legislative action.
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Key Details:
• Duration of Shutdown:
o February 14 → April 30, 2026 (~75–76 days)
o Longest shutdown affecting a single federal department

• Scope of Impact:
o Affected agencies included:
 Transportation Security Administration (TSA)
 U.S. Coast Guard
 Federal Emergency Management Agency (FEMA)
 Cybersecurity and Infrastructure Security Agency (CISA)

• Operational Disruptions:
o TSA staffing shortages and resignations
o Delays in airport security processing
o Strain on federal payroll systems and contingency funding

• Legislative Resolution:
o Bipartisan bill passed by Congress
o Signed into law on April 30, 2026
o Provides funding through end of FY2026 (September 30, 2026)

• Notable Exclusions:
o Immigration enforcement agencies:
 ICE (Immigration and Customs Enforcement)
 CBP (Customs and Border Protection)
o These agencies to be funded separately via:
 Budget reconciliation or future appropriations

• Policy Context:
o Shutdown driven by disputes over:
 Immigration enforcement policy
 Scope of federal authority and funding priorities