According to www.chrobinson.com, U.S. trade policy entered a pivotal phase in April 2026 with the launch of two sweeping Section 301 investigations and the imposition of new tariffs on patented pharmaceuticals—marking a structural shift away from the invalidated International Emergency Economic Powers Act (IEEPA) tariffs.
IEEPA Refunds: System Under Development, No Payments Yet
Customs and Border Protection (CBP) continues building the automated Consolidated Administration and Processing of Entries (CAPE) system to process IEEPA tariff refunds following the Supreme Court’s ruling invalidating those tariffs. The Court of International Trade has paused immediate refunds while CBP finalizes CAPE but confirmed progress is satisfactory. Importers should expect refunds—plus interest—to be paid to the importer of record once the system goes live, likely in phases. CBP stated on March 6 it would need 45 days to complete the system, targeting April 20; however, the source states there are currently no penalties if CBP misses that timeline.
Section 122 Tariffs: A Temporary 10% Global Surcharge
The 10% global Section 122 tariff is now in effect and runs for 150 days—through late July—unless extended by Congress. This authority is intentionally limited and serves as a transitional measure before more durable tools take effect. According to the report, Section 122 is ‘a temporary bridge, not a long-term solution.’ Supply chain professionals are advised to:
- Do: Continue normal sourcing, pricing, and routing decisions; ensure proper application of exemptions (e.g., USMCA, Section 232 non-attacking, in-transit rules)
- Don’t: Restructure supply chains or make long-term commitments based solely on Section 122
Section 301 Investigations: The Legal Replacement for IEEPA
The U.S. Trade Representative launched two Section 301 investigations explicitly designed to replicate the IEEPA tariff regime on firmer legal footing:
- One on forced labor enforcement failures, covering 60 countries
- One on structural excess industrial capacity, covering 16 countries plus the EU
The report notes that ‘almost every trade deal negotiated includes language on enhanced screening for forced labor in the supply chain,’ linking these investigations directly to previously announced trade agreements. Key milestones include public comment deadlines in mid-April, investigative hearings in late April/early May, and potential remedies announced before Section 122 expires in late July.
Section 232 for Pharmaceuticals: 100% Baseline Tariff Effective July 31
Following a Section 232 investigation, the White House issued an Executive Order on April 2, 2026, imposing new tariffs on imports of patented pharmaceuticals and related ingredients. The administration cited concerns about U.S. healthcare supply chain vulnerability, noting that an estimated 54% of patented pharmaceuticals consumed domestically are produced abroad. The baseline tariff rate is set at 100%, with numerous company- and country-specific exclusions and rate reductions—including incentives for approved onshoring commitments. Tariffs will take effect on July 31, 2026, for companies listed in Annex III, and on September 29, 2026, for all others.
CBP Valuation Guidance Remains Informal and Non-Binding
CBP confirmed that informal guidance from its Base Metals Center of Excellence and Expertise (CEE) on valuing steel and aluminum content for Section 232 is advisory only and not binding. For binding determinations, importers must seek formal rulings via CBP’s eRulings portal. The most recent version of this informal guidance was circulated on March 15, 2026. Trade groups are urging CBP to issue formal, uniform guidance—and a lawsuit has been filed challenging the informal guidance on procedural grounds.
EU–U.S. Trade Deal Advances with Conditional Safeguards
The European Parliament voted to advance the EU–U.S. trade deal, improving near-term predictability and reducing escalation risk. The agreement would eliminate most tariffs on U.S. industrial goods and expand access for U.S. agriculture and seafood. However, lawmakers added three enforceable conditions:
- A ‘sunrise’ clause: EU tariff cuts are contingent on U.S. compliance, including keeping tariffs at or below 15% on certain EU goods
- A ‘suspension’ clause: Allows the EU to pause benefits if the U.S. raises tariffs or applies economic pressure
- A ‘sunset’ clause: Ends the agreement on March 31, 2028, unless renewed
The deal does not limit U.S. Section 301 authority, preserving some uncertainty. It now moves to trilogue negotiations with EU governments and the Commission—the final step before implementation.
USMCA Joint Review Begins July 1, 2026
The U.S.-Mexico-Canada Agreement (USMCA) remains intact, but the mandatory joint review begins on July 1, 2026, per the agreement’s terms.
Source: www.chrobinson.com
Compiled from international media by the SCI.AI editorial team.
