Tariff Resource Center
Have questions or concerns about tariffs?
Latest Updates
Recommendations
- Understand the difference between entries that are and are not liquidated by US Customs and Border Protection, and how this may limit potential refund options.
- US importers are encouraged to enroll in the ACH program to streamline duty payments and for any potential duty refunds as this is required for refunds.
- US importers should review the potential duty impact and the effect on continuous bonding limits and single-entry bond amounts. Please note that if your assessed duty exceeds your bond amount, your goods will be rejected at the port of arrival.
- We encourage all importers to seek trade advice on topics such as USMCA/CUSMA/T-MEC Qualification review, valuation, supply chain audit, country of origin determination, tariff classification, and tariff relief to ensure successful outcomes.
Refunds
- With the US Supreme Court ruling that IEEPA tariffs were unlawful, many importers are looking for answers on a potential refund process.
- Refunds were not part of the Supreme Court ruling, and at present, the main pathway forward lies in a court filing. However, CBP has announced that it is developing the Consolidated Administration and Processing of Entries (CAPE) system and has been progressing through its development at a steady pace.
- In anticipation for the CAPE system, importers are encouraged to prepare details required. PCB can help with ensuring your 5106 is up to date, and can create a report of eligible entires broken down in the formats required for CAPE.
ACH
The CBP Automated Clearing House (ACH) is an electronic network that facilitates the direct payment of duties and taxes to CBP. It is also the only way that CBP will now process and disseminate refunds back to importers.
It is imperative that you register for ACH if you have not already done so. There are many benefits associated with the ability to make payments electronically, and one of them will be the return of tariff-related refunds when that system goes live.
However, it is worth noting that being set up for ACH for your duty payments DOES NOT automatically set you up for an ACH refund. A separate mandatory process is required for payments and refunds.
You are advised to register now, as we do not know when the refund system will go live, but when it does, there will almost certainly be a rush on registration.
US Trade Actions
Removal of De Minimis
Effective August 29th, 2025, the De Minimis exemption for importations into the US ended for all countries.
Section 122
What is Section 122?
Section 122 of the 1974 Trade Act allows the President to address “balance-of-payment” concerns, namely when importing drastically outweighs exporting, and as a result, money is flooding out of the economy. The maximum percentage tariff that can be levied is 15%. It also imposes a 150-day limit on these tariffs, unless Congress votes to extend them.
10%-15% Global tariff
FAQ Regarding Section 122:
Section 232
What is Section 232?
Section 232, as it is found in the Trade Expansion Act of 1962, allows the President to impose tariffs if importing that good could be deemed a national security risk.
These are commodity-specific tariffs. Determining this risk requires a formal investigation by the Commerce Department. By law, they have 270 days to present their findings to the president.
If it is determined that a specific import is a security risk, then the President can impose tariffs.
100% Patented Pharmaceuticals and ingredients
0-50% Aluminum, Steel and Copper
FAQ Regarding Section 232:
Section 301
What is Section 301?
Section 301 of the 1974 Trade Act allows for the investigation of “unjustifiable, unreasonable, or discriminatory” trade practices, or actions that violate previously established trade agreements.
This contrasts with section 232 in that 301 is concerned with countries, and 232 is concerned with specific goods.
Enacting a 301 tariff can be a lengthy process, with the upper ceiling of the investigation being 12 months, and it involves hearings and extensive evidence gathering.
25% Certain Products from China
FAQ Regarding Section 301:
Canadian Trade Actions
Surtax
What is a surtax?
A surtax is an additional Canadian duty that is imposed on imported goods above and beyond the regular Customs duty.
It differs from a tariff in its specificity. It is effectively an import penalty enacted for specific political or economic reasons.
Examples include responding to imposed tariffs or creating safeguards from sudden surges in cheap imports.
