AMD Trade
Consulting LLC
President Trump Tariffs 2.0
CBP, Imports, Tariff Information, and Trump Tariffs
July 21, 2026 - 50% Tariffs on Certain Goods From Canada
On July 20th, President Trump issued three Presidential Proclamations and a Fact Sheet imposing 50% Tariffs on imports of goods from Canada. These additional Tariffs are being imposed under Section 338, a seldom used statute, and are set to be implemented on August 19, 2026. Here is a link to the Fact Sheet, with links to the three individual Proclamations:
Contact adambrov@amdtradeconsulting.com for an initial consultation and a listing of the HTS codes that are subject to the tariffs and certain products that are excluded. These tariffs may also have an impact on the USMCA negotiations currently being conducted between the US, Mexico and Canada.
July 20, 2026 - Section 122 10% Tariffs
10% tariffs imposed under Section 122 of the Trade Act, can be applied for up to 150 days and are set to expire on July 24, 2026. Importers should review import data to determine the amount of Section 122 duties paid, monitor for liquidation, and consider recovery strategies given applicable Court decisions. Contact adambrov@amdtradeconsulting.com for a an initial consultation regarding this opportunity.
July 20, 2026 - 25% Tariff on Products from Brazil
Official Presidential Document published in the Federal Register and includes modifications to the Harmonized Tariff Schedule of the United States:
July 16, 2026 - 25% tariffs on products from Brazil
Effective July 22, 2026, a 25% tariff will be imposed on goods of Brazilian origin and imported to the US. This tariff covers most products although there are a few exemptions. Contact adambrov@amdtradeconsulting.com for a an advance copy of the Federal Register Notice before publication.
July 16, 2026 - DOJ reports collection of over $1B in recoveries since August 2025. The trade fraud task force has increased enforcement and utilizes the False Claims Act. The DOJ has been taking an aggressive and comprehensive approach to its work. The TFTF “has a nationwide mandate to investigate and prosecute trade fraud and related cases,” the DOJ stated. “ The primary areas of concern are:
• False country of origin declarations
• HTS classification errors and misrepresentations
• Undervaluation of imported merchandise
• AD/CVD evasion
• Forced labor-related compliance risks
• Drawback fraud and false export claims
• Free trade agreement fraud
• Shell company structures and customs broker misconduct
• Port shopping and other supply chain fraud schemes
This reporting emphasizes the new age of Customs enforcement and importers need to be more vigilant than ever with respect to their US imports and the information provided to Customs. Contact adambrov@amdtradeconsulting.com for assistance determining if your business is at risk for an enforcement action.
July 15, 2026 - New York Packaging II LLC doing business as Redi-Bag USA, a New York-based supplier of custom bags, liners, and packaging, along with the company’s CEO, Jeffrey Rabiea, have agreed to pay a total of $7.3 million to resolve allegations that they violated the False Claims Act by misrepresenting on customs entry forms the country of origin of polyethylene retail carrier bags (PRCBs), thereby evading antidumping duties owed to the United States. Businesses should be aware that there is a financial incentive for current and former employees to report known instances of Custom's violations or intentional Customs fraud. Contact adambrov@amdtradeconsulting.com for assistance determining if your business is at risk for a whistle blower action under the False Claims Act.
July 14, 2026 - IEEPA Refund Update
Trump Tariffs
On July 13, 2026, US Customs and Border Protection (CBP) provided the Court of International Trade (CIT) with a status report on the current status of IEEPA refunds being processed through the CAPE module in ACE (See, Euro Nations Florida v. United States, Court No. 25-00595, Document 45). Importantly CBP noted that 229,609 CAPE declarations have been submitted and almost 30% have failed the validation process. The main reasons these submissions failed are largely due to the following errors: (1) Mismatched importer of record numbers (2) Incorrect entry numbers and (3) the CSV format does match the template provided by CBP in the ACE portal.
These errors can easily be identified prior to submission and are examples of delays that can occur when an importer attempts to submit refund claims on their own without professional guidance. Contact adambrov@amdtradeconsulting.com for a copy of the status report and for assistance preparing your entry data for submission via the CAPE module in ACE.
July 13, 2026 – Trade Update
Trump Tariffs
301 Investigation Addressing Forced Labor - USTR Hearings Held July 7, 8 & 9
Several countries, trade associations, subject matter experts, and government officials appeared before the USTR to state arguments regarding the proposed tariffs of 10% and 12.5%.
Transcripts can be found here:
Day 3:
A final determination is due by November 29, 2026, but it is possible the final determination will be issued prior to that date.
Contact adambrov@amdtradeconsulting.com for country specific information and additional support.
Recent CBP Rulings – Country of Origin
Substantial Transformation
https://rulings.cbp.gov/ruling/H350728
Pharmaceutical Products
https://rulings.cbp.gov/ruling/N355022
https://rulings.cbp.gov/ruling/N357684
Contact adambrov@amdtradeconsulting.com for assistance with Country of Origin determinations and analysis.
July 10, 2026
Trump Tariffs- IEEPA Refund Update
CBP has implemented Phase 2 of the CAPE refund process in ACE and covering entries flagged for reconciliation. Many importers are struggling to obtain access to their Import records in ACE and CBP is experiencing a significant delay in processing importer requests to resolve ACE and CAPE issues including access and running import data reports. Importers should consider alternative import data sources while waiting for CBP action to resolve pending issues. Importers need to be mindful of time sensitive liquidation dates as it remains unclear how, and if, IEEPA refunds will be issued for entries that are finally liquidated.
Contact adambrov@amdtradeconsulting.com for assistance with to ensure maximum IEEPA refunds are realized and that no critical deadlines are missed.