03/13/2026
CBP Provides Further Guidance on Refund Processing System for IEEPA Duties in ACE
Check out this week's Customs Corner to read about CBP's new CAPE refund processing system for IEEPA duties, the USTR's Section 301 investigations into manufacturing practices of 16 major trading partners, and more.
Trade and Customs Updates
1) CBP Provides Further Guidance on Refund Processing System for IEEPA Duties in ACE
Brandon Lord, Executive Director Trade Programs in the Office of Trade, CBP provided an update to his March 6, 2026, Declaration on CBP’s IEEPA duty refund plan. This initiative, called the Consolidated Administration and Processing of Entries (CAPE), is being developed within the Automated Commercial Environment (ACE), CBP’s primary system of record for imported merchandise.
Introducing CAPE: A Four-Part Solution
CAPE is structured around four integrated components:
- Claim Portal – A web-based entry point enabling importers and brokers to submit IEEPA refund requests (referred to as “CAPE Declarations”). A new tab will appear in ACE Portal accounts for both importers and brokers, allowing for the upload of CSV files listing relevant entry summaries. Once a submission is made, the system runs two sets of validations—checking file formatting, filer authorization, and entry eligibility. Importers and brokers will be notified of any errors to facilitate corrections and resubmissions.
- Status: As of March 11, 2026, the Claim Portal is 70% complete, with the user interface finished and validation programming in development.
- Mass Processing – This component will automatically remove IEEPA-specific Harmonized Tariff Schedule (HTS) numbers from validated entry summaries, then recalculate duties as if the IEEPA duties were never applied. This process mirrors existing ACE entry summary validations.
- Status: Currently 40% complete, with the focus on updating entry summaries and related validations.
- Review and Liquidation/Reliquidation – Following acceptance, this component schedules entry summaries for liquidation or reliquidation, updates total duties, and calculates interest. It also supports manual reviews if required and processes liquidations from Monday to Thursday each week.
- Status: Now 80% complete, with the liquidation function finished and performance testing underway.
- Refund – After entries reach their scheduled liquidation/reliquidation, this module consolidates refunds by date and importer of record (IOR), or their designated recipient. Refunds will be issued electronically to the appropriate bank account.
- Status: 60% complete, with CAPE-specific refund processing developed and performance testing ongoing.
Development Timeline and Next Steps
CBP is rolling out CAPE in phases, starting with core functionality that will allow the processing of most formal and informal entries subject to IEEPA duties. Certain entry types—such as those under antidumping or countervailing duty orders, entries with suspended or extended liquidation status, warehouse withdrawals, and drawback claims—will be addressed in later phases.
Detailed user guidance will be provided for each stage of implementation. CBP is also reviewing requirements to comply with the Paperwork Reduction Act as part of this initiative.
Looking Forward
Once fully operational, CAPE will provide a more efficient and transparent process for importers and brokers seeking IEEPA duty refunds, reflecting CBP’s ongoing commitment to modernization and customer service in trade processing.
GEODIS will continue to provide updates as they become available.
Reference:
2) USTR Initiates Section 301 Investigations into Manufacturing Practices of 16 Major Trading Partners
United States Trade Representative Jamieson Greer has announced the launch of new investigations under Section 301(b) of the Trade Act of 1974 into the acts, policies, and practices of 16 key global economies related to structural excess capacity and production in manufacturing sectors. The countries and regions under scrutiny include China, the European Union, Singapore, Switzerland, Norway, Indonesia, Malaysia, Cambodia, Thailand, Korea, Vietnam, Taiwan, Bangladesh, Mexico, Japan, and India.
Section 301 of the Trade Act empowers the USTR to address foreign government actions that are deemed unjustifiable, unreasonable, or discriminatory and that burden or restrict U.S. commerce. These investigations, initiated after advice from the inter-agency Section 301 Committee and consultations with relevant advisory groups, will assess whether the targeted practices meet these criteria.
As part of the process, the USTR has formally requested consultations with each of the named economies to discuss the concerns outlined in the investigation. To ensure transparency and public participation, a comment docket will open on March 17, 2026, and interested parties are invited to submit written comments and requests to testify by April 15, 2026. Public hearings regarding the investigations are scheduled to begin on May 5, 2026.
The docket for comments regarding the investigation will be available here.
The docket for requests to appear at the public hearing to be held in connection with this investigation will be available here.
References:
- USTR Initiates Section 301 Investigations Relating to Structural Excess Capacity and Production in Manufacturing Sectors | United States Trade Representative
- Fact Sheet: USTR Initiates Section 301 Investigations into Structural Excess Capacity and Production in Manufacturing Sectors | United States Trade Representative
- USTR 301 FRN Industrial Excess Capacity 3-11-26.pdf
3) U.S. Launches Section 301 Investigations into 60 Economies Over Forced Labor Concerns
The United States Trade Representative (USTR) has announced the initiation of wide-ranging investigations into the acts, policies, and practices of 60 of the nation’s largest trading partners under Section 301(b) of the Trade Act of 1974. These investigations will examine whether each economy’s failure to impose and enforce effective bans on the importation of goods produced with forced labor is unreasonable or discriminatory, and whether such failures burden or restrict U.S. commerce.
As part of the process, the USTR has formally requested consultations with the governments of the economies under review. Hearings related to these investigations are scheduled for April 28, 2026. The USTR is inviting interested parties to submit written comments and requests to participate in the hearings, along with summaries of their intended testimony, no later than April 15, 2026, to ensure their input is considered.
A docket for comments regarding the investigation will be available here.
A docket for requests to appear at the public hearing to be held in connection with this investigation will be available here.
Economies subject to these investigations:
1. Algeria
2. Angola
3. Argentina
4. Australia
5. The Bahamas
6. Bahrain
7. Bangladesh
8. Brazil
9. Cambodia
10. Canada
11. Chile
12. China, People’s Republic of
13. Colombia
14. Costa Rica
15. Dominican Republic
16. Ecuador
17. Egypt
18. El Salvador
19. European Union
20. Guatemala
21. Guyana
22. Honduras
23. Hong Kong, China
24. India
25. Indonesia
26. Iraq
27. Israel
28. Japan
29. Jordan
30. Kazakhstan
31. Kuwait
32. Libya
33. Malaysia
34. Mexico
35. Morocco
36. New Zealand
37. Nicaragua
38. Nigeria
39. Norway
40. Oman
41. Pakistan
42. Peru
43. Philippines
44. Qatar
45. Russia
46. Saudi Arabia
47. Singapore
48. South Africa
49. South Korea
50. Sri Lanka
51. Switzerland
52. Taiwan
53. Thailand
54. Trinidad and Tobago
55. Türkiye
56. United Arab Emirates
57. United Kingdom
58. Uruguay
59. Venezuela
60. Vietnam
References:
- USTR Initiates 60 Section 301 Investigations Relating to Failures to Take Action on Forced Labor | United States Trade Representative
- FRN - Forced Labor Import Ban 301 - FINAL.pdf
4) FMC Monitors Impact of Middle East Military Activity on Ocean Freight Through Strait of Hormuz
The Federal Maritime Commission (FMC) announced that it is "closely monitoring" how ongoing military operations in the Middle East are affecting ocean freight shipping through the critical Strait of Hormuz. In a statement to the industry, the FMC emphasized its statutory role in ensuring that any rate increases, charges, or changes to rules imposed by ocean common carriers in response to these threats remain compliant with the Shipping Act.
Under Commission regulations (46 CFR 520.8), carriers must provide at least 30 days’ notice before enacting tariff increases, unless they receive special permission from the FMC after demonstrating good cause. The Commission carefully reviews all Special Permission requests and determines effective dates for any expedited changes. Tariffs must be in effect at the time cargo is received, as required by federal regulations.
The FMC also reminded shippers to regularly review their carriers’ tariffs and ensure service contracts are filed accurately and on time. The Commission stressed that shippers have the exclusive right to file lawsuits for breach of service contracts, unless an alternative dispute resolution method is agreed upon. However, allegations of Shipping Act violations—such as unjust discrimination or unreasonable refusals to deal—can be brought before the FMC, which may investigate and impose penalties or award damages if violations are confirmed.
Shippers who suspect non-compliance with tariff regulations are encouraged to file complaints with the FMC or contact the Commission’s Consumer Affairs and Dispute Resolution Services office. The NCBFAA Transportation Committee and its legal counsel are actively tracking the FMC’s oversight as military activities continue to affect the region and will keep members informed of any significant developments.
Reference:
Commission Statement Regarding Strait of Hormuz Surcharges - Federal Maritime Commission
EVENT: NCSD's March & April Webinar Schedules
March 24, 2026 – April 9, 2026 | 1:30 PM ET | Webinar
U.S. Customs and Border Protection’s Office of Trade’s National Commodity Specialist Division (NCSD) is hosting the following webinars in the month of March and April as a part of the 2026 NCSD webinar series. These webinars are scheduled for 1:30 p.m. ET.
To register for these free webinars, click on the registration link for the coordinating webinar below. All registrants will receive the link for the webinar on their confirmation email, but entry into the webinar is on a first-come, first-served basis as seats are limited. After the live event, this and other previously recorded webinars will be available for replay at Trade Outreach Webinars | U.S. Customs and Border Protection (cbp.gov).
These webinars are a part of CBP’s Continuing Education program.
NCSD's March Webinar Schedule:
- Tuesday, March 24, 2026: Parts of General Use – The “Parts of General Use” is part of the 2026 Educations Commodity Specific Webinar Series hosted by the National Commodity Specialist Division, Regulations and Rulings, Office of Trade. This webinar is an overview of what is considered a part.
- Thursday, March 26, 2026: Stepping Forward in Smart Kicks – The “Stepping Forward in Smart Kicks” is part of the 2026 Educations Commodity Specific Webinar Series hosted by the National Commodity Specialist Division, Regulations and Rulings, Office of Trade. This webinar will explain the classification of smart footwear.
NCSD's April Webinar Schedule:
- Tuesday, April 7, 2026: The Classification of Steel Bars and Rods in Chapter 72– The “The Classification of Steel Bars and Rods in Chapter 72” is part of the 2026 Educations Commodity Specific Webinar Series hosted by the National Commodity Specialist Division, Regulations and Rulings, Office of Trade. This webinar will cover the tariff classification of chapter 72.
- Thursday, April 9, 2026: Plates, Sheets, Film, Foil & Strip of Plastics– The “Plates, Sheets, Film, Foil & Strip, of Plastics” is part of the 2026 Educations Commodity Specific Webinar Series hosted by the National Commodity Specialist Division, Regulations and Rulings, Office of Trade. This webinar will focus on the nuances of classification of plates, sheets, film, foil, and strip of plastics in headings 3920 and 3921 of the Harmonized Tariff Schedule of the United States. It will examine the applicable legal notes and Explanatory Notes.
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