U.S. tariff policy continues to evolve, with recent developments under Section 232 of the Trade Expansion Act of 1962 (Section 232) and important updates to the refund process for International Emergency Economic Powers Act (IEEPA) duties. This update provides a high-level overview of recent actions, highlighting what has changed and what companies should monitor as implementation continues.
Expansion of Section 232 tariffs
Recent presidential proclamations have made significant changes to Section 232 tariffs, affecting steel (Proclamation 9705), aluminum (Proclamation 9704), copper (Proclamation 10962), and pharmaceuticals (Proclamation 11020). These actions create new and adjust existing tariff rates, expand the scope of covered products, and increase the importance of content and country of origin. For manufacturers, the changes may affect import costs, supplier strategies, and margin assumptions, particularly for products containing meaningful metal content or imported equipment.
Metals: Expanded coverage and revised tariff calculations
The proclamations addressing steel, aluminum, and copper represent the most immediate change by expanding scope to the full value of the imported product, not just the metal portion — a meaningful change for manufacturers importing complex assemblies or equipment. These changes apply to:
- Articles made entirely or almost entirely of steel, aluminum, or copper (50% tariff).
- Products substantially made of these metals (25% tariff).
- Certain metal-intensive industrial and electrical grid equipment (temporary 15% tariff on certain metal-intensive industrial and grid equipment through Dec. 31, 2027).
Reduced rates apply in certain cases based on the origin of the metal content, including U.S.-origin or U.K.-origin material. Products containing more than one covered metal will generally be subject to only one Section 232 tariff. Note that the prior petition-based inclusion process has ended, and the commerce department and United States Trade Representative may now adjust product coverage on a rolling basis.
Certain products are removed from derivative coverage if they contain no or minimal metal content. White House guidance references a 15% or less metal content threshold, which may reduce tariff exposure for some complex assemblies.
Section 232 and pharmaceuticals
The administration announced new Section 232 tariffs on certain patented pharmaceuticals and pharmaceutical ingredients, citing national security concerns tied to import reliance. Unlike prior tariff actions, the pharmaceutical proclamation introduces a tiered tariff structure that varies based on:
- Product type.
- Country of origin.
- Company-specific commitments to onshoring.
- Pricing arrangements with the U.S. government.
Tariff rates range from 0% to 100%, depending on the circumstances. Generic pharmaceuticals and biosimilars are currently excluded but are subject to future review. While these measures apply narrowly today, they’re notable for introducing a more customized, company-specific application of Section 232.
Timing
- Metals changes apply to goods entered on or after April 6, 2026.
- Pharmaceutical tariffs generally begin July 31, 2026.
- Duty drawback remains available under certain conditions.
Recommended actions
The Section 232 changes may affect import costs, supplier strategies, and margin assumptions, particularly for products containing meaningful metal content or imported equipment. Given these changes manufacturers should proactively:
- Identify products with meaningful steel, aluminum, or copper content.
- Review supplier documentation related to metal origin.
- Evaluate potential cost and margin impacts.
- Monitor future changes to product coverage.
Because Section 232 outcomes are highly product- and fact-specific, companies should consult with their advisors to understand how these changes apply to their operations.
IEEPA tariff refunds: Filing begins 8:00 a.m. ET on Monday, April 20
U.S. Customs and Border Protection (CBP) continues to move forward with implementation of the refund process for tariffs collected under IEEPA.
Current status
On March 31, CBP filed an updated status report with the Court of International Trade indicating that development of its electronic refund system remains on track for mid-April deployment. CBP confirmed that refunds will be processed through a new electronic system — the Consolidated Administration and Processing of Entries (CAPE) tool — which is integrated into the Automated Commercial Environment (ACE) portal.
CBP has outlined a two-phase CAPE rollout for processing IEEPA refunds. Phase 1, the initial rollout, will accept refund claims for unliquidated entries and entries that are up to 80 days past their liquidation date. CBP estimates this phase will cover approximately 63% of entries for which IEEPA duties were paid or deposited.
For these entries:
- Duties will be recalculated as if IEEPA tariffs never applied.
- Refunds will reflect the difference between amounts paid and adjusted duties.
- Refunds (plus interest) will be consolidated and paid in a single lump sum, rather than entry by entry.
Phase 2 will cover liquidated entries beyond the voluntary liquidation period and entries that have reached final liquidation (i.e., no protest filed). CBP has indicated it intends to build functionality to process refunds for these entries, but no timeline has been provided for Phase 2 deployment.
Filing refund claims through CAPE
On April 13, CBP issued instructions allowing Importers of Record (IOR) and customs brokers to submit refund requests through CAPE, utilizing their existing ACE account. Importantly, only IOR and customs brokers who filed the entries are eligible to file CAPE refund claims. Key points to note:
- CAPE declarations may be submitted beginning 8:00 a.m. ET on Monday, April 20.
- Declarations will be validated before processing.
- Refunds and interest will be consolidated into one payment.
- Any outstanding debts owed to CBP will be offset against the refund.
According to CBP, valid Phase 1 refunds are expected within 60–90 days following acceptance of a CAPE declaration, unless compliance concerns trigger additional review.
For additional information refer to:
- CAPE guidance to file for refunds.
- CBP FAQ page on filing for refunds.
Operational considerations to be aware of
Refunds are electronic only — no paper checks will be issued. Refund recipients must set up ACH banking information within ACE — a separate step from filing the refund declaration. Given the evolving refund process, companies should take the following actions:
- Monitor liquidation timing for relevant entries.
- Confirm ACE registration and ACH setup are complete.
- Coordinate with your customs broker to verify status.
- Evaluate internal processes for receiving and allocating refunds.
Because eligibility and timing depend heavily on entry status and filing history, companies should validate their facts and circumstances to assess how the refund process may apply.
Considerations post-refund
Refunds will be issued to the IOR, and in many cases, this may not be the party that ultimately bears the economic burden of the tariff. Companies should consider how refunded amounts will flow internally or downstream, and allocation of refunded amounts may depend on commercial agreements, internal arrangements, and negotiation between parties. Companies should also consider the financial reporting and accounting implications flowing from the refunds.
The bottom line
As tariff rules and refund processes continue to develop, the potential impact will vary based on your company’s products, sourcing structure, and import activity. Review your exposure now, and coordinate with your advisors to understand how these developments apply to your specific facts and circumstances.
