U.S. Trade Policy and Tariff Actions
- President Trump issues Proclamation overhauling Section 232 tariffs on steel, aluminum, and copper (effective 6 April 2026): On 2 April, President Trump signed a Proclamation restructuring the implementation of Section 232 tariff regime for steel, aluminum, copper, and derivative products. As per the Proclamation and CBP CSMS guidance, imported steel, aluminum, and copper products will now be subject to a 25% tariff on their full value. This is a modification from the previous Section 232 tariff action which applied a 50% tariff on the value of non-U.S. origin metal. Food processing and packaging machinery continue to not be subject to Section 232 tariffs.
- This action is meant to simplify determinations and documentation of the percent of non-U.S. metal for U.S. importers while maintaining a relatively high tariff. This may mean that some imported goods may face higher tariff costs than under the initial Section 232 tariff, while other imported goods may face lower tariff costs, depending on the amount of non-U.S. steel in the good.
- Additionally, the Proclamation provides for lower Section 232 tariffs for metal products and derivative articles of UK origin or made entirely of U.S. origin metals. The quarterly derivative inclusions process, under which domestic producers could petition for additional products to be covered, has been removed. The Secretary of Commerce and US Trade Representative retain the ability to expand the scope of tariff action on a rolling basis.
- CBP provides update on IEEPA tariff refund system (CAPE) and clarifies refund timeline: On 31 March, CBP Executive Director Brandon Lord filed a declaration with the U.S. Court of International Trade (CIT) providing a detailed update on the development of the Consolidated Administration and Processing Entries (CAPE) system within ACE which will handle IEEPA tariff refunds. Key updates include:
- CAPE remains on pace to launch by mid-April to start accepting refund claims. A specific launch date has not been provided.
- CBP estimates that refund claims may take up to 45 days (from being accepted) to be reviewed and refunds to be processed electronically.
- CAPE will begin accepting refund claims in a phased approach, with first priority given to customs entries liquidated, or finalized, within the preceding 80 days and entries whose liquidation status has been suspended, extended, or under review.
- European Parliament leadership welcomes modification of Section 232 tariffs on steel, aluminum, and copper: On 4 April, European Parliament International Trade Committee Chair Bernd Lange issued a statement welcoming actions by the Trump Administration on 2 April to modify and simplify the implementation of Section 232 tariff action. Trade Committee Chair Lange noted that the tariff modification is a result of pressure by the European Parliament and brings the EU and United States closer to the full implementation of the EU-US Turnberry Framework Agreement. However, Lange added that additional steps are needed, including the first trilogue negotiations between the European Parliament and EU Member States are scheduled for 13 April. Please note that as part of the Turnberry Agreement the EU has committed to eliminating all tariffs on U.S. origin industrial goods, including the 1.7% tariffs implemented on imports of U.S. food processing and packaging machinery of HS 8422 and 8438.
Trade Policy Actions by Other Countries
- WTO group commits to refrain from e-commerce duties following moratorium lapse: On 2 April, the United States and 22 other WTO members committed to uphold the now-expired e-commerce moratorium, until the WTO's next General Council meeting, which could occur as early as May 2026. While USTR Ambassador Greer indicated that the U.S. has secured bilateral commitments from nearly all major trading partners not to impose duties on U.S. digital transmissions, the multilateral moratorium remains lapsed. As such, WTO member countries are no longer banned from implementing duties on e-commerce transactions which may impact PMMI members which provide digital services, software licensing, or remote technical support to customers in foreign markets.
