According to dimerco.com, the U.S. government has enacted a series of coordinated trade policy actions between February and March 2026 — significantly reshaping compliance, refund eligibility, and supply chain risk management for global importers.
IEEPA Tariff Refund Scope Expanded to All Entries
Judge Eaton issued an amended order directing that all entries subject to IEEPA duties — including fully liquidated entries — must be reliquidated without those duties. This overturns prior assumptions that refund eligibility required entries to remain open and protests to be filed within 180 days of liquidation. The ruling now suggests refund eligibility may apply broadly, regardless of liquidation status:
- Unliquidated entries must be liquidated without IEEPA duties
- Liquidated but non-final entries must be reliquidated
- Fully liquidated (final) entries may also be subject to reliquidation and refund
Industry consultants suggest the ruling could eliminate the need to file protests on liquidated entries — though this interpretation remains subject to further clarification and potential appeal. Despite the favorable ruling, implementation is not immediate: the Court has suspended immediate enforcement, and U.S. Customs and Border Protection (CBP) is not yet required to act. Operational guidance from CBP is still pending, and the timeline for refund processing remains uncertain.
FCC Adds Foreign-Produced Routers to Covered List
As of March 26, 2026, the U.S. Federal Communications Commission (FCC) added foreign-produced routers to its Covered List, citing national security risks including cyber espionage, data exfiltration, botnet attacks, and critical infrastructure disruption. Unlike earlier company-based restrictions, this marks a shift to product-origin controls: the restriction applies to routers manufactured outside the U.S., irrespective of country of origin. Covered equipment cannot obtain FCC authorization or enter the U.S. market. Importers must certify products are not covered equipment. A conditional limited exemption — up to 18 months — may be granted upon submission of supply chain transparency documentation, ownership disclosure, a U.S. manufacturing/onshoring plan, and risk mitigation measures.
USTR Launches 60 Forced Labor Investigations Under Section 301
As of March 15, 2026, the Office of the U.S. Trade Representative (USTR) has initiated 60 new Section 301 investigations into major trading partners regarding failures to address forced labor risks within global supply chains. These investigations are currently in the early review stage but may lead to new Section 301 tariffs, import restrictions on affected goods, or expanded compliance and documentation requirements. According to the source, this represents one of the largest coordinated Section 301 investigations to date and signals increasing U.S. enforcement on forced labor compliance across global supply chains.
USTR Opens Overcapacity Investigation Across 16 Trading Partners
The USTR has also launched a Section 301 investigation under the Trade Act of 1974 to assess whether foreign government policies — including state subsidies and industrial policies — are contributing to structural excess manufacturing capacity that burdens or restricts U.S. commerce. The investigation covers 16 major trading partners, explicitly noting it is not limited to China and includes several key electronics and industrial manufacturing hubs. While no tariffs have been announced, potential outcomes later in late 2026 include additional Section 301 tariffs, import restrictions, or other trade remedies following public consultation. Industries potentially affected include electronics and semiconductors, automotive and EV components, batteries and energy equipment, machinery and industrial equipment, and metals and raw materials.
Section 122 Temporary Import Duty (Up to 150 Days)
A temporary duty under Section 122 was expected to take effect on February 24, 2026. However, formal implementation details remain pending — including the Executive Order, Federal Register notice, and CBP CSMS guidance. Exemption scope, operational procedures, and HTS programming will only be confirmed after official issuance. Until then, shippers should avoid assumptions on applicability or exclusions and prepare for potential near-term disruptions.
Practical Implications for Supply Chain Professionals
Dimerco recommends maintaining a conservative approach until CBP issues formal guidance. Key recommended actions include: continuing to file protests to protect eligibility while guidance is pending; preparing for ACE refund processing by ensuring ACE portal accounts are active, ACH refund setup is completed, and cross-account access with Dimerco is established to support CAPE refund submissions; and reviewing historical entries — including previously liquidated entries and those beyond 180 days — as these may now become recoverable refund opportunities.
Source: dimerco.com
Compiled from international media by the SCI.AI editorial team.
