Recent Tariff Developments – Status of IEEPA Refunds and Fresh Tariffs Proposed by the Trump Administration

As U.S. Customs and Border Protection (CBP) begins issuing billions in IEEPA tariff refunds, new and expanded tariff proposals from the Trump administration are reshaping the trade landscape and introducing additional compliance considerations for importers.

Latest CBP Filing Declares $20.6 Billion of Tariff Refunds on the Way to Importers

About $20.6 billion in tariff refunds are now on their way to importers in the U.S., according to the latest filing by the CBP before the Court of International Trade (CIT) on Tuesday, May 26. Here’s what you need to know about this latest filing:

CBP declared that these payments are in the final stages of processing and have already been transferred to the U.S. Treasury. From there, they would go out to the importers through direct bank transfers.
CBP also mentioned that these payments include interest and are being sent to importers who successfully filed claims through its new Consolidated Administration and Processing of Entries (CAPE) system launched on April 20, 2026.
According to this latest update, nearly 16 million entries with IEEPA duties imposed had been accepted in the first phase of the refund effort, and 8.5 million of those have been reprocessed without the duties and certified for repayment to importers.

Overall, CBP is in the process of issuing refunds to importers who paid as much as $166 billion across more than 53 million import entries with IEEPA duties imposed.

New 25% Tariff Proposed on Brazilian Goods Under Section 301

On Monday, June 1, 2026, the Trump administration proposed 25% tariffs on Brazilian goods under Section 301, determining that the South American nation had engaged in practices that “are unreasonable and burden or restrict U.S. commerce.”

United States Trade Representative (USTR) Jamieson Greer said in a news release that an investigation under Section 301 was launched at the direction of U.S. President Donald Trump, which found that Brazil had failed to adequately enforce intellectual property rights and had not taken sufficient measures to combat corruption, bribery, ethanol market access and illegal deforestation.

Here’s what the proposal covers:

The proposed tariffs would exempt some products, including beef, coffee, rare earth metals, aircraft equipment and certain fruits and vegetables.
Being a punitive duty proposed by the USTR after investigation, the proposed 25% tariff on Brazilian imports is intended to be applied in addition to Section 232 national security tariffs (covering steel, aluminum and copper imports) and Section 122 global tariff surcharge.

Note that this additional 25% duty is currently under review, with the USTR accepting public comments until July 1, 2026, and a final decision expected by mid-July.

President Trump Signs a Proclamation Amending Tariffs on Steel, Aluminum and Copper Imports

On Monday, June 1, 2026, U.S. President Donald Trump signed a proclamation amending Section 232 ‌national security tariffs on some aluminum, steel and copper imports. It includes the following:

The proclamation lowers tariffs on some steel and aluminum derivative products, including certain types of agricultural machinery and residential heating, air conditioning and ventilation equipment⁠, to 15% from 25% previously.
The order also allows foreign companies to qualify for a 10% tariff if “their capital equipment includes at least 85% U.S. melted ‌and ⁠poured or smelted and cast steel or aluminum by weight.”
The order adds two new categories of steel and aluminum derivative import products that will be subject to 25% duties: ⁠steel racks and aluminum lithographic plates.
These adjustments became effective for goods imported or withdrawn from bonded warehouses after 12:01 ⁠a.m. EDT on Monday, June 8, 2026.
The changes will remain in place until December 31, 2027, “to spur near–term investments ⁠that will rebuild the Nation’s industrial base,” the White House said.

Fresh Tariffs Proposed on 60 Countries Under Section 301 Over Forced Labor Trade Practices

On Tuesday, June 2, 2026, the Office of USTR Jamieson Greer issued a press release proposing fresh tariffs under Section 301. These tariffs would impact imports from 60 economies, including China, the European Union and Japan, for failing to ban forced labor goods.

USTR has proposed a 10% duty rate for economies that have adopted a full or partial prohibition on forced labor trade, and 12.5% for all other economies.
USTR also proposed a separate textile mechanism that would allow for a certain volume of apparel and textile imports from some economies to enter the U.S. at reduced rates.
Being a punitive duty proposed by the USTR after investigation, the proposed tariff on imports from these 60 countries is intended to be applied in addition to Section 232 national security tariffs and Section 122 global tariff surcharge.
Written comments for the proposal are due by July 6, with public hearings scheduled on July 7, according to USTR’s press release.

Withum’s Global Transfer Pricing Services Team is here to support. Feel free to reach out with questions on the IEEPA tariff refund process, Section 122 tariffs, the expanding Section 232 or 301 tariffs, or any new tariffs under consideration. It’s a great time for a complimentary 30-minute health check on transfer pricing and tariff mitigation strategies that may be available for your business. We are assisting multinationals to ensure they are declaring the correct dutiable customs value to CBP, which includes only product-related (along with Assists) costs.