Summary of Changes (Effective July 31, 2026 for some companies; September 29, 2026 for others) 

Beginning on the applicable effective date, a baseline 100% ad valorem tariff will be imposed on imported patented pharmaceuticals, and associated pharmaceutical ingredients (including active pharmaceutical ingredients and key starting materials).

Lower tariff rates will apply to certain countries with U.S. trade agreements, and additional reduced or zero‑rate options are available for companies that commit to reshoring and, in some cases, MFN pricing.

Country‑Specific Rates (No Reshoring Requirement):

• 15% tariff: European Union, Japan, South Korea, Switzerland, and Liechtenstein

• 10% tariff: United Kingdom

A tiered, incentive‑based structure allows reduced or zero tariffs for companies that commit to onshoring U.S. production, and/or enter into Most‑Favored‑Nation (MFN) drug pricing agreements with the Department of Health and Human Services (HHS).

Reshoring Incentives:

• Companies that agree to reshore production will receive a temporary 20% tariff rate while U.S. facilities are under construction, increasing to 100% on April 2, 2030.

• Companies that reshore and agree to MFN (Most Favored Nation) drug pricing will qualify for a 0% tariff during construction.

Current Status:

• 17 pharmaceutical companies have committed to reshoring and MFN pricing

• 13 companies have executed agreements

• 4 companies remain in active negotiations

Generic pharmaceuticals, biosimilars, and associated ingredients will not be subject to tariffs at this time and will be reassessed in one year.

Orphan drugs, drugs for animal health, and certain other specialty pharmaceutical products will be exempt, if they are from trade deal countries or meet an urgent public health need.

You can read the full proclamation here: Adjusting Imports of Pharmaceuticals and Pharmaceutical Ingredients into the United States – The White House

Effective Monday, April 6, 2026

President Trump has issued a new Proclamation modifying the tariffs imposed under Section 232 on Steel, Aluminum, and Copper.

The Proclamation defines the way that tariffs are assessed, ensuring that they reflect the full value of imported steel, aluminum, and copper products.

The new Section 232 tariff rates for steel, aluminum, and copper will go into effect on Monday, April 6, 2026. Details on the affected metals and their corresponding tariff rates are provided below:

Metals:

• 50% tariff on the full value of certain steel, aluminum, copper goods classified in Chapter 72, 73, 74, and 76

• 25% tariff on the full value of certain steel, aluminum and copper derivatives listed in Annex I of the proclamation (no more splitting lines based on metal content value)

• A temporary 15% tariff, inclusive of Most Favored Nation (MFN) rate-based duty, on certain metal-intensive industrial equipment and electrical grid equipment through the end of 2027

• Removal of many steel/aluminum derivative items from lists of goods subject to tariffs. The inclusion process is also ended, but additional products may be added at the administration’s discretion, listed in Annex II (pg. 29) of the proclamation

• De minimis exemption for goods outside of Chapters 72, 73, 74 and 76 if the weight of the subject metal is less than 15% of the imported article. If the article is on more than one metal list, use the aggregate weight of the listed metals.

• 0% duty on motorcycle parts in Chapters 84, 85 or 87 when imported exclusively for use in the manufacturing of motorcycles

• If an item is listed as an article or derivative of more than one metal, it will be subject to only one duty assessment for 232 steel/aluminum/copper, even if it contains more than one metal.

• For derivative products manufactured abroad with 95% or more US steel/aluminum/copper the rate is now 10% instead of 0%. For some goods it is 10% additional, others 10% inclusive of MFN.

• Goods from the U.K. that would otherwise be subject to the 50% rate are subject to a 25% tariff rate, and goods subject to the 25% rate for derivatives will be subject to a 15% rate.

• Manufacturing drawback under 19 U.S.C. 1313(a) and (b) will be allowed for goods subject to the Section 232 tariffs on steel, aluminum and copper. But that applies only to goods from a "Trade Agreement Partner," currently the U.K., EU, Japan, South Korea, Mexico, Canada and "any trading partner with which the United States concludes a final Agreement on Reciprocal Trade."

  To qualify, the goods must also not be subject to antidumping or countervailing duties, and the aluminum, copper or steel must be entirely smelted and cast or melted and poured in a trade agreement partner country.

This latest Presidential Proclamation is very detailed, and Deringer recommends that U.S. importers review Metals-ANNEXES-I-A-I-B-II-III-IV.pdf for the applicability of the new tariff rates.

Only liquidated entries and entries within the 90-day voluntary reliquidation period will be processed in Phase 1

To comply with the Court of International Trade’s amended order dated March 20, 2026, CBP revised the development scope of CAPE Phase 1 to limit processing to entries that are either unliquidated or within the 90 day voluntary reliquidation period under 19 U.S.C. § 1501.

To meet the Phase 1 deployment timeline, CBP will continue development without including the finally liquidated entries.

CAPE Phase 1 will accept entries where the liquidation status is “Suspended,” “Extended,” or “Under Review,” as well as warehouse and warehouse withdrawal entries, but in these instances, refunds will be provided in the normal course upon liquidation, rather than immediately. This includes entries subject to AD/CVD.

CAPE Phase 1 Scope and Limitations

1. Eligible Entries

• CAPE Phase 1 will process only:

  • Unliquidated entries; and

  • Entries within the 90‑day voluntary reliquidation period under 19 U.S.C. § 1501.

2. Entries with Suspended, Extended, or Reviewed Liquidation Status

• Phase 1 will now accept CAPE Declarations containing entries whose liquidation status is suspended, extended, or under review.

• CAPE will not liquidate or process refunds of IEEPA duties for these entries. The entries will be liquidated (without IEEPA duties) through normal CBP processes, and IEEPA duties will be refunded upon liquidation.

• Entries subject to antidumping and/or countervailing duties (AD/CVD) are included if liquidation is suspended pending instructions from the U.S. Department of Commerce (DOC).

  • CBP will not liquidate or process IEEPA duty refunds until DOC issues instructions lifting the suspension and authorizing liquidation.

3. Warehouse Entries

• CAPE Phase 1 will also accept CAPE Declarations containing:

  • Warehouse entries and warehouse withdrawal entries.

  • Liquidation of warehouse entries will continue through CBP’s normal processes after all withdrawals have occurred and the entry is ready for liquidation, at which time CBP will process the refund of IEEPA duties.

Entries Not Accepted in CAPE Phase 1
The following categories of entries subject to IEEPA duties will not be accepted on a CAPE Declaration in Phase 1:

• Entries flagged for reconciliation, including Entry Type 09 – Reconciliation Summary;

• Entries designated on a drawback claim;

• Entries covered by an open protest;

• Entries not filed in ACE, or entries without a liquidation status in ACE; and

• Entries subject to AD/CVD for which DOC has issued liquidation instructions and that are pending liquidation under 19 U.S.C. § 1504(d).

Processing Timeframes

• CBP will take up to 45 days from acceptance of a CAPE Declaration to review and liquidate validated entry summaries, unless a compliance concern requires further review.

• CAPE Phase 1 will accept Declarations containing entries liquidated within the preceding 80 days, ensuring that reliquidation can be completed by the 90th day, consistent with 19 U.S.C. § 1501.

Refund Processing and Electronic Payments

• CBP continues to evaluate more complex refund scenarios to determine which additional CAPE capabilities are required.

• CBP systems allow refunds to be issued to:

  • The importer of record (IOR); or

  • A party designated by the IOR via CBP Form 4811.

• Effective February 6, 2026, CBP issues all refunds electronically, as required by Executive Order 14247.

• As of March 26, 2026, 26,664 IORs have completed electronic refund enrollment.

  • These IORs filed 78% of all entries for which IEEPA duties and/or duty deposits were paid.

  • Importers expecting refunds should ensure they are properly enrolled to receive ACH electronic refunds.

Planned CAPE Enhancements (Future Phases)

In subsequent phases, CBP expects to develop the following functionalities:

• Enhanced tools and validations to ensure compliance, facilitate entry summary processing, and expedite CBP review;

• Enhanced financial reporting and security tools;

• Tools to streamline revenue enforcement when outstanding bills for non IEEPA duties exist for entries on a CAPE Declaration;

• Capability to process entries flagged for reconciliation and entries designated on drawback claims, which present an increased risk of over refunding duties;

• Capability to process complex interest calculations involving multiple collection dates on a single entry summary;

• Capability to process finally liquidated entries; and

• Capability to process non Automated Broker Interface (ABI) entries where no entry summary lines exist.

CIT expands refund order to finally liquidated entries

On March 27, Judge Richard Eaton of the U.S. Court of International Trade (CIT) expanded his prior order directing U.S. Customs and Border Protection (CBP) to refund IEEPA tariffs. While the original order applied only to non–finally liquidated entries, the court has now clarified that it also applies to finally liquidated entries.

Specifically, the order states that “any liquidated entries for which liquidation is final shall be reliquidated without regard to the IEEPA duties.” However, the court continues to suspend the order to the extent it would require immediate compliance, meaning CBP is not yet obligated to take immediate action.

Although Judge Eaton’s ruling provides insight into a potential framework for the refund process, further challenges, changes, or delays remain possible. Refunds should not be expected to occur automatically.

Recommended Action:

Importers are advised to consult with counsel to evaluate whether proactive steps, such as filing protests with CBP and/or pursuing claims before the Court of International Trade, may be appropriate to preserve potential refund rights.

In addition, we highly recommend that importers enroll in ACE Refunds now, if not already enrolled. Registration ensures that refund payments can be processed electronically once CBP begins issuing refunds and helps avoid potential delays once implementation moves forward.

We will continue to monitor developments and provide updates as additional guidance becomes available. For questions regarding how this decision may affect your imports, please contact your Deringer representative.

Importers Responsible for Identifying and Claiming IEEPA Refunds.

On March 12, U.S. Customs & Border Protection (CBP) filed its status report to the Court of International Trade (CIT) regarding refunds of IEEPA tariffs. In this report, CBP announced they are developing a new capability within ACE to facilitate the IEEPA refund process called CAPE (Consolidated Administration and Processing of Entries).

What is CAPE?
CBP is proposing that importers will have to apply for a refund of IEEPA duties through CAPE. This implies CBP will not proactively issue IEEPA refunds.

The CAPE Claim Portal will be web-based and serve as the entry point for importers and brokers to submit IEEPA refund requests (“Cape Declaration”) to CBP.

CBP has not provided a target date for CAPE’s completion and launch. CAPE will contain four components, which are in various stages of completion:

• Claim Portal Component (70% complete according to CBP)

  • New tab in the ACE portal available to brokers and importers

  • Importers and Brokers will be able to submit IEEPA refund request (CAPE Declaration) to CBP as a CSV file containing a list of entry summaries for which they are requesting refunds

    • Filers will NOT use ABI to file in CAPE portal

    • ACE will conduct two validations:

      • File validation – verifies whether refund request contains all required information, whether the information is properly formatted, the submitter is the IOR or authorized broker, and whether CSV file is not corrupted).

        • ACE will reject if the submission fails any part of the file validation.

      • Entry validation (after successful file validation)

        • Confirms that entry number on CSV file exists in ACE.

        • That at least one IEEPA 99 number was declared on the entry.

        • If the entry summary fails the validation, ACE will remove that entry from CAPE declaration BUT will process remaining entries.

        • After validation, ACE will allow the filer to review the results and identify any rejected entries.

        • Filer might be able to correct entry specific errors on a separate CAPE Declaration upload.

• Mass Processing Component (40% complete)

  • Cape Mass Processing will automatically remove any applicable IEEPA HTS numbers from entry summaries submitted and validated by CLAIM.

  • Will run ACE duty calculation validations (normal ACE entry summary process in existence today, which automatically reviews all declared HTS numbers to confirm the correct duties owed are listed on the entry summary).

  • Mass processing will calculate duties as if IEEPA were not declared.

  • After that, the system will accept CAPE Declaration.

• Review and Liquidation/Reliquidation Component (80% complete)

  • This component will initiate the review and liquidation / reliquidation process for entries identified in the accepted CAPE declaration.

  • It will set entries to liquidate / reliquidate on a specific number of days from the acceptance date, allowing CBP to conduct a manual review as needed.

  • The review and Liquidation / Reliquidation component will update the underlying entry summaries to reflect the new total duties paid and will automatically calculate interest.

  • It will process liquidation / reliquidation of entries on a CAPE Declaration Monday through Thursday each week.

• Refund Component (60% complete)

  • ACE will direct entries to a refund process once the entry summaries in the accepted CAPE Declaration reach the schedule liquidation / reliquidation date.

  • The CAPE Refund component will consolidate refunds by liquidation / reliquidation date and IOR or a party IOR has designated to receive refunds on its behalf on a CBP Form 4811 (4811 designee party).

  • Refunds will be sent electronically to the designated bank account.

What will CAPE not cover?

CBP expects a phased development for CAPE. In the first phase, CAPE will have the ability to process a majority of formal and informal entries with IEEPA duties, other than:

• Unliquidated entries subject to AD/CVD.

• Entries for which liquidation status in ACE is “suspended”, “extended”, or “under review”.

• Other types of entries such as warehouse withdrawals and entries designated on a drawback claims.

What should importers do?

• Set up an ACE account immediately if you don’t already have one

  • ACE access is critical to receive these refunds. It is also important for entry audits and for receiving CBP communications.

• Ensure you can receive electronic refunds via ACH

  • This must be set up as soon as possible within the ACE portal.

• Continue to track your IEEPA duties

  • Understand how much you have paid in duties, so you can compare this to the refund once CBP issues one.

• File Protests on entries containing IEEPA duties, which are within 90-180 days after the liquidation. After an entry is liquidated, CBP has the statutory authority to reliquidate the entry only within 90 days of the original liquidation, therefore entries beyond the 90 days are at risk.

Deringer will continue to monitor CIT’s actions and other developments. In view of these events, we urge you to sign up for electronic refunds as soon as possible and consult with a Customs Attorney.

Deringer Customers: Get Started with Electronic Refunds Here

To let us know how we may best assist you, please complete our client form for IEEPA protests and electronic refunds. Go to the Form

Refund programming is coming, but full processing may take months

On March 6, U.S. Customs and Border Protection (CBP) informed the Court of International Trade (CIT) that it is not yet prepared to process the court‑ordered refunds of IEEPA‑related tariffs. CBP stated it expects to have the necessary ACE programming in place within approximately 45 days.

In its filing, CBP confirmed that all unliquidated entries subject to IEEPA duties must be liquidated without those duties, and any liquidated but non‑final entries must be reliquidated accordingly. The filing, signed by Brandon Lord, Executive Director of the CBP Office of Trade, notes that CBP is developing new ACE functionality to consolidate refunds and interest by importer, avoiding the need to issue more than 53 million separate entry‑level refunds.

Under CBP’s proposed process, importers would submit a declaration in ACE listing entries with IEEPA duties, after which ACE would validate entries, recalculate duties and interest, liquidate or reliquidate automatically, and aggregate refund amounts before Treasury issues payments. Because this process depends heavily on ACE, importers with active ACE accounts, and particularly ACE Refunds accounts, will be better positioned to receive refunds quickly if CBP adopts this approach.

CBP indicated that completing refunds for all affected importers could take months once the system is operational.

On March 4, the CIT ordered CBP to liquidate all unliquidated entries without IEEPA duties and to reliquidate any liquidated but not‑yet‑final entries.

Deringer Customers: Get Started with Electronic Refunds Here

To let us know how we may best assist you, please complete our client form for IEEPA protests and electronic refunds.

Go to the Form

Refund framework may move forward despite anticipated government challenge.

The U.S. Court of International Trade (CIT) issued an order on March 4, directing Customs and Border Protection (CBP) to liquidate all unliquidated entries without IEEPA‑based duties and to reliquidate any entries already liquidated but not yet final (within 90 days of initial liquidation). An appeal is anticipated, given concerns over the order’s procedural deficiencies and its broad, universal application.

CIT Judge Richard K. Eaton, who will oversee all related cases, scheduled a non‑public conference for Friday, March 6 to address next steps, including the structure of a potential refund process. Judge Eaton emphasized that refunds should be administered through CBP’s standard procedures and that importers should not be required to file additional lawsuits to obtain them. We expect to learn more in the upcoming days, but as of today, no refunds are being processed by CBP.

This order follows the March 2 U.S. Court of Appeals for the Federal Circuit (CAFC) action granting plaintiffs’ request, including Vintners Overseas Shipping Selections (V.O.S.), to immediately return the matter to the CIT for proceedings on final relief, which is expected to include refunds of IEEPA‑related tariffs.

The Department of Justice argued that importers should still be required to file suit to recover refunds for previously liquidated entries. However, it is unclear whether this position applies to liquidation or final liquidation. DOJ also moved to suspend the CIT order, which Judge Eaton denied.

This development comes in the wake of the Feb. 20 Supreme Court ruling invalidating the Administration’s use of IEEPA tariffs. The situation remains fluid, and additional challenges to the scope and validity of yesterday’s order are likely.
 
Deringer will continue to monitor CIT's actions and other developments.
 
In view of these events, we urge you to sign up for electronic refunds as soon as possible, and consult with a Customs Attorney.

Deringer Customers: Get Started with Electronic Refunds Here

To let us know how we may best assist you, please complete our client form for IEEPA protests and electronic refunds.

Go to the Form

On March 2, the U.S. Court of Appeals for the Federal Circuit (CAFC) granted the motion for immediate issuance of the mandates in the IEEPA tariff cases. This sends the matters back to the Court of International Trade (CIT) to determine how refunds will be handled. The court issued the mandates despite the U.S. government’s objections.

The Government had urged the CAFC to follow the standard timeline or to delay remand by 90 days to allow Congress time to consider potential legislative approaches to refunds. The CAFC declined both requests.

Government’s Position Remains Restrictive

As reflected in its February 27 filing, the Department of Justice continues to oppose a broad or rapid refund process. The DOJ argued that:

• There is no urgency, since Venable Overseas Services (V.O.S.) would receive refunds plus interest if ultimately entitled.

• V.O.S. cannot obtain relief for non‑party importers, signaling continued opposition to universal refunds.

• A 90‑day delay would give “the political branches” time to consider options.

The DOJ also referenced suggestions that refunds could be prospective only, indicating the Government may push for limited remedies as proceedings continue at the CIT.

Recommended Next Steps

• Continue monitoring liquidation activity and file protests as necessary.

• Given the Government’s posture and the possibility of extended litigation, importers may wish to consider filing an individual case under 28 U.S.C. § 1581(i) to preserve rights within the two year window from the first IEEPA duty payment.

A.N. Deringer Inc. will continue to closely follow these developments and provide further updates. For additional assistance or guidance, please contact your Deringer representative.

On February 20, 2026, the Supreme Court ruled that IEEPA does not confer any tariff-setting authority and effectively struck down all IEEPA duties.

The White House has issued an Executive Order that officially ends all IEEPA duties.

Subsequently, CBP issued CSMS # 67834313 - Ending Collection of International Emergency Economic Powers Act Duties declaring IEEPA no longer in effect as of February 24, 2026 at 12:00 am.

What does this mean to your company? Will you receive refunds of IEEPA duties?

The Court of International Trade (CIT) is tasked with deciding on the process to issue the IEEPA duty refunds. This will likely take several months.

Until then, we will not know what the process of obtaining refunds will be, nor what will be required from importers to secure their refunds.

Many trade attorneys urge importers to prepare for all eventualities and take every possible action to protect their potential refunds including filing protective protests on entries that are nearing the protest deadline.

It is unclear whether protests will be effective in protecting potential IEEPA refunds, but filing a protest may protect your refunds, if the CIT decides not to issue refunds on liquidated entries.

Once an entry finally liquidates (i.e,. generally 180 days beyond initial liquidation and is beyond the protest deadline, or approximately 480 days from date of entry), the only avenue for protecting your liquidated entry will be to file a lawsuit in the CIT under 28 U.S.C. 1581(i) jurisdiction.

If your company decides to proceed with a protective protest, Deringer can assist you with this service, for a fee. Please contact consulting@anderinger.com for further assistance. 

We recommend checking with a trade attorney to determine your company's best course of action to protect potential refunds.

Please note that Post Summary Correction (PSC) filings currently cannot be submitted for unliquidated entries that remove IEEPA tariffs.

Going Forward

We continue to advise importers to monitor transactions and liquidation status where IEEPA duties have been paid, as well as the amount of IEEPA duties paid.

If you don’t have an ACE account, we recommend that you establish an ACE account immediately.

• You need an ACE account to pull ACE reports to identify entries with IEEPA duties and monitor the liquidation status of these entries.

As of February 6th, 2026, CBP now issues any and all types of refunds electronically via ACH.

• We strongly recommend that importers sign up for the electronic ACH refund option, in preparation for potential IEEPA refunds. Consult Deringer’s website for detailed information on how to set up your ACH refund: Electronic Refunds Effective February 6, 2026.Please note that CBP will reject any refunds if the importer or the importer’s designated Customs Broker is not able to accept electronic refunds through ACH.

[Webinar] Friday, February 27, 2026, at 1pm EST

2026 Tariff Turbulence: What Importers Need to Know Following the End of IEEPA

Many uncertainties remain following the Supreme Court’s February 2026 ruling that brought the IEEPA tariffs to an immediate end, followed by the introduction of new Section 122 tariffs.

Join us for a critical, real‑time briefing where Michael Roll, partner at Roll & Harris LLP and a leading international trade attorney, will break down what we know now, what’s still uncertain, and how importers can prepare for this rapid regulatory transition. 

 This event has passed. Watch the recording here