Trade Advisory Notices

In March 2026, the U.S. Court of International Trade ordered CBP to remove tariffs imposed under IEEPA, following a Supreme Court ruling that the statute does not authorize tariffs. CBP must liquidate and reliquidate affected entries nationwide without IEEPA duties. While CBP has acknowledged its obligation, refunds will be phased due to system limitations. Importers should review impacted entries, confirm electronic refund enrollment, and coordinate with advisors as implementation guidance develops.

In March 2026, the U.S. Court of International Trade ordered U.S. Customs and Border Protection to remove tariffs imposed under the International Emergency Economic Powers Act. The decision follows a U.S. Supreme Court ruling that found the IEEPA tariffs unlawful. CBP must liquidate or re‑liquidate affected entries without applying these duties. Importers with unfinalized entries may be entitled to refunds and should review their import records promptly.

On February 23, 2026, President Donald J. Trump issued a Proclamation invoking Section 122 of the Trade Act of 1974 to impose a temporary 10 percent ad valorem duty on most imported articles. The measure, effective February 24, 2026, will remain in force for up to 150 days unless modified or terminated earlier. While Section 122 permits duties of up to 15 percent, the only legally effective rate at present is 10 percent, and any increase would require further formal Presidential action. The duty applies broadly, subject to defined country‑based, product‑based, and trade‑agreement exclusions, including USMCA‑compliant goods and certain critical inputs, agricultural products, pharmaceuticals, and energy‑related items. De minimis shipments are also subject to the surcharge following a related Executive Order suspending duty‑free treatment. Importers should expect immediate cost impacts and reassess tariff classifications, origin determinations, and landed‑cost assumptions amid the potential for further trade enforcement actions.

On February 20, 2026, the President issued an Executive Order titled “Ending Certain Tariff Actions,” terminating the collection of additional ad valorem duties imposed under the International Emergency Economic Powers Act (IEEPA). U.S. Customs and Border Protection (CBP), through CSMS #67834313, confirmed that IEEPA duties will no longer be collected on qualifying entries effective 12:00 a.m. Eastern Time on February 24, 2026. The termination applies to IEEPA-based duties imposed under several Executive Orders, including those related to border security, synthetic opioid supply chains, reciprocal trade deficit measures, and imports involving specific countries such as Venezuela, Brazil, and the Russian Federation. CBP will update ACE programming to deactivate HTSUS numbers associated with IEEPA tariffs, and importers should not expect these duties to be assessed on qualifying entries filed on or after the effective date. Importantly, this action applies only to tariffs imposed under IEEPA. Duties imposed under other authorities, including Sections 232 and 301, remain in effect unless separately modified. In light of recent Court of International Trade rulings affirming the potential for reliquidation and refunds if IEEPA tariffs are ultimately deemed unlawful, importers are encouraged to proactively review impacted entries, ensure documentation readiness, confirm record retention compliance, and verify enrollment in the ACH refund process.

The United States Supreme Court has ruled that the President exceeded statutory authority by imposing certain tariffs under the International Emergency Economic Powers Act (IEEPA), holding that the law does not permit the use of emergency powers to enact broad trade measures. As a result, the Court invalidated country‑by‑country “reciprocal” tariffs and tariffs on imports from Canada, China, and Mexico that were justified on fentanyl‑related grounds. The decision leaves other tariffs unaffected, including those imposed under separate statutory authorities such as Section 232 tariffs on steel and aluminum. Notably, the Court did not address whether the federal government must refund the billions of dollars in duties already collected under the invalidated IEEPA tariffs. In a related December 15, 2025 ruling, the U.S. Court of International Trade confirmed its authority to order reliquidation and refunds if the tariffs were ultimately found unlawful, noting that the government has acknowledged this authority and would not oppose such relief if ordered. Additional guidance on implementation and potential refunds is expected from the courts and relevant federal agencies.

On February 6, 2026, the White House issued a Presidential Executive Order removing the additional 25% ad valorem duty on certain imports from India that had been imposed under Executive Order 14329. The change took effect at 12:01 a.m. EST on February 7, 2026, and applies to goods entered for consumption or withdrawn from warehouse for consumption on or after that date. U.S. Customs and Border Protection will process refunds for qualifying entries that paid the additional duty on or after the effective date. The United States–India Joint Statement also indicates the U.S. intent to apply an 18% reciprocal tariff under Executive Order 14257; however, this tariff is not yet in effect and will be implemented only after publication in the Federal Register. The statement further notes that, subject to the successful conclusion of an interim agreement, the United States may remove reciprocal tariffs on a range of Indian-origin goods listed in the applicable annex, including generic pharmaceuticals, gems and diamonds, and aircraft parts. The United States and India will establish rules of origin to ensure that the benefits of the agreement accrue predominantly to both countries. The U.S. government will continue monitoring India’s trade activity related to Russian-origin oil and may consider reimposing duties if necessary. Tariffs imposed under Section 232 of the Trade Expansion Act of 1962 remain unchanged.

Two new Presidential Proclamations under Section 232—one targeting processed critical minerals and the other focused on semiconductors and semiconductor manufacturing equipment—will be published on January 20, 2026, bringing significant implications for U.S. manufacturers and import‑reliant industries. Proclamation 11001 highlights national security vulnerabilities tied to U.S. dependence on foreign sources for critical minerals. It launches a 180‑day negotiation period for new supply‑chain agreements and enables future tariffs, import price floors, quotas, or other trade remedies if agreements are unsuccessful. Importers should anticipate increased origin scrutiny and potential cost volatility across industries dependent on batteries, magnets, catalysts, and advanced materials. Proclamation 11002 immediately imposes a 25% tariff (effective January 15, 2026) on select advanced chips and semiconductor‑related products not contributing to U.S. supply‑chain development. Key provisions include no drawback, privileged foreign status for FTZ entries, and limited end‑use exemptions. Commerce also outlines a two‑phase strategy that could expand tariffs or drive new international agreements. Importers should move quickly to review HTS classifications, evaluate tariff exposure, reinforce supplier documentation, and monitor forthcoming CBP and Commerce guidance. Trade Consulting and Customs Brokerage teams stand ready to support classification reviews, tariff mitigation strategies, and compliance planning as Section 232 actions evolve.

On January 17, 2026, President Donald Trump announced plans to impose new tariffs on several European nations—Denmark, Norway, Sweden, France, Germany, the United Kingdom, the Netherlands, and Finland—in retaliation for their opposition to U.S. efforts to acquire Greenland. The proposal calls for a 10% tariff beginning February 1, escalating to 25% on June 1, and remaining in place until a “complete and total purchase of Greenland” is agreed. No formal Executive Order, Federal Register notice, or CBP implementation guidance has been issued, meaning these tariffs are not yet enforceable. All information is based solely on public statements and verified media reporting. Crane Worldwide continues to monitor official sources in real time, including the White House, USTR, OFAC, Treasury, and CBP. The dispute has triggered strong reactions across the EU and NATO, with European leaders condemning the tariff threats and convening an emergency summit to coordinate a response. The eight affected nations issued a joint statement rejecting tariff‑based pressure and affirming support for Greenland’s sovereignty. If enacted, the tariffs would affect all goods from the targeted countries, significantly impacting industries including automotive, machinery, pharmaceuticals, metals, chemicals, and consumer goods. Importers should begin evaluating HTS classifications, assessing sourcing alternatives, modeling landed cost impacts at both 10% and 25%, and preparing for potential EU retaliation. Crane Worldwide’s Trade Consulting and Customs Brokerage teams are ready to support clients with tariff modeling, compliance readiness, classification review, operational planning, real‑time entry support, and immediate regulatory monitoring once official directives are released.

Canada's Fighting Against Forced Labor and Child Labor in Supply Chains Act, effective January 1, 2024, imposes mandatory reporting obligations on businesses and government institutions. Organizations producing or importing goods into Canada must disclose measures taken to prevent and reduce the risk of forced or child labor in their supply chains.

On January 14, 2026, the White House issued a Section 232 Proclamation targeting vulnerabilities in the U.S. semiconductor supply chain. The action establishes a 25% tariff on select advanced high‑performance AI chips—including NVIDIA’s H200 and AMD’s MI325X—due to heavy reliance on foreign imports and related national security risks. The tariff includes exemptions for imports that directly support U.S. semiconductor manufacturing expansion. The administration also signaled that broader semiconductor‑related duties and a potential tariff‑offset incentive program may follow. The Section 232 findings highlight insufficient domestic production capacity for chips and key manufacturing equipment, creating strategic dependencies that affect defense, critical infrastructure, and AI innovation. Companies importing advanced computing chips should prepare for immediate cost impacts, evaluate country‑of‑origin exposure, revisit supply chain strategies, and assess whether current imports qualify for exemptions. With the possibility of additional tariffs on semiconductor components and downstream products, organizations are encouraged to conduct tariff exposure assessments, model cost scenarios, explore mitigation options, and monitor ongoing U.S. trade and export control developments.