U.S. Trade Policy and Tariff Actions
- CAPE Phase 2 launched 29 June: On 23 June, CBP issued CSMS #69035485 confirming that CAPE Phase 2 will launch on 29 June, expanding eligibility to entries flagged for reconciliation (Entry Types 01, 02, 06) for which the reconciliation entry (Entry Type 09) has not yet been filed. Consistent with Phase 1 parameters, Phase 2 is limited to unliquidated entries and entries within 80 days of liquidation. Entries flagged for reconciliation that already have a reconciliation entry on file are not covered in this phase. Please note, the DOJ continues to contest CBP's authority to refund finally liquidated entries, CAPE Phase 3, and entries without individual court orders.
- EU-US Framework Agreement receives final approval: On 25 June, the EU Council gave final approval to the two regulations implementing the EU's tariff commitments under the Framework Agreement, completing the ratification process ahead of President Trump's 4 July deadline. The regulations will be published in the EU's Official Journal and will enter into force the following day. Once entered into force, the 1.7% MFN tariff on U.S.-origin food processing and packaging machinery of 8422 and 8438 imported into the EU is eliminated. Under the regulations adopted, the EU may:
- Suspend tariff preferences if the U.S. continues to apply tariffs above 15% on EU steel and aluminum derivatives.
- Reimpose tariffs if U.S. imports surge and threaten EU industry under a safeguard mechanism.
- The agreement sets an expiration date on 31 December 2029 under a sunset clause, unless renewed.
- CBP formalizes de-minimis exemption suspension via interim final rule: On 24 June, CBP published an interim final rule in the Federal Register, which is effective immediately, implementing an indefinite regulatory suspension of the $800 de-minimis administrative exemption for all merchandise arriving via non-postal modes of entry. The rule codifies in CBP regulations the suspension that has been in effect since August 2025. Please note that this interim regulatory change will be made permanent 1 July 2027 under provisions of the One Big Beautiful Bill Act. The de-minimis exemptions allow imports valued under $800 to be imported duty-free. While the suspension/elimination of the de-minimis exemption does not impact most machinery imports, which are above the $800 threshold, imports of lower valued parts or components may now be subject to imports tariffs.
