🟢 Section 338 In Effect Section 338's 50% Canada duties took effect Aug 22 after a 3-day pause and collapsed talks — CBP's Aug 25 filing: $132.5B accepted, $106.6B sent to Treasury — class certification rulings still pending
WIRE 💰 AUG 25 CBP FILING: $132.5B accepted for processing in CAPE — approximately $106.6B in duties plus interest certified and sent to Treasury for disbursement (Lord Decl., data as of 3pm ET Aug 21) ⚠️ STUCK REFUNDS: 22,170 refunds totaling ~$1.7B have NOT been transmitted to Treasury — no ACH account information from the importer of record or its Form 4811 designee. That was 19,726 two weeks ago 🔴 CAPE PHASE 3 PORTAL FUNCTION STILL NOT LIVE — CBP's Aug 25 report confirms Phase 3 remains delayed while it builds additional system validations, with no new deployment date given ⚖️ JULY 17 CIT ORDER: Judge Eaton ordered CBP to reliquidate finally liquidated entries — a case-linked path for the ~3,700 filed CIT plaintiffs only, with counsel supplying importer IDs 📌 SECTION 338 CANADA NOW IN EFFECT: 50% additional duties took effect 12:01 AM ET Aug 22 after a 3-day pause — talks with Canada collapsed Aug 21. No USMCA carve-out. No expiration date ⚑ FTZ TRAP: covered Canadian goods admitted to a foreign trade zone on or after Aug 22 must enter under privileged foreign status (19 C.F.R. 146.41) — otherwise they pick up the 50% on consumption entry 🚩 CBP REPORTEDLY OFFSETTING IEEPA REFUNDS against disputed and non-fixed debts, and reapplying full Section 232 duty rates on some entries — per multiple attorneys, Aug 28 ❓ JUDGE EATON ASKS CBP whether it deleted entry information tied to IEEPA duties — no substantive answer filed yet as of Aug 28 ⚖️ BOTH CLASS CERTIFICATION ARGUMENTS NOW HEARD — V.O.S. Selections (Aug 6) and Freestyle World (Aug 19) — neither ruling has issued as of Aug 28 ⚖️ NEW LEGAL FRONT: importers led by Learning Resources challenge the Section 301 forced-labor tariffs themselves as exceeding USTR's statutory authority — filed Aug 24 📋 AGS Company Automotive Solutions withdraws from Federal Circuit appeal proceedings (No. 2026-1897) — Aug 24; the consolidated appeal itself continues 📊 CAPE VOLUME as of July 31 (historical): 252,496 declarations submitted • 178,213 passed file validation • 25.1M entries accepted — see the Aug 25 filing above for the current $132.5B / 26.4M total ✅ JULY 28: Fed. Cir. dismissed Appeal No. 2026-1898 (Euro-Notions) on the government's own motion — Nos. 2026-1895 (lead), -1897, -1899 remain consolidated and active 📅 DOJ's Federal Circuit opening brief was due August 3, 2026 — still not confirmed filed on the docket as of August 28, 2026 📌 Freestyle World, Inc. v. United States (1:26-cv-01088) is the lead IEEPA refund case — oral argument was held Aug 19; a ruling is still pending ⚠️ JULY 24: Section 122 expired — replaced same-day by new Section 301 forced-labor tariffs (10–12.5%) on 60 countries, now themselves under legal challenge (see above) 📈 Don't assume the announced rate is what you paid — rates shifted repeatedly across the IEEPA period. Pull ACE report ES-003 for your actual duties assessed before estimating a refund ⚖️ Liberty Justice Center is fighting on two fronts: a CIT class certification motion for importers stuck outside CAPE, and a separate challenge to the Section 301 forced-labor tariffs 📅 Class certification motion (Rule 23(b)(2), V.O.S./Terry Precision) filed June 4, 2026 — class defined by CURRENT CAPE ineligibility, not final liquidation alone ⚔️ 90-day §1501 statutory liquidation-finality window vs. 80-day practical CAPE cutoff — these are not the same date, ask which one applies to you ⚖️ SCOTUS 6-3 Feb 20: Learning Resources v. Trump — IEEPA tariffs ruled unlawful • $166B+ refundable across ~53M entries and ~330,000 importers of record (CIT court filings) WIRE 💰 AUG 25 CBP FILING: $132.5B accepted for processing in CAPE — approximately $106.6B in duties plus interest certified and sent to Treasury for disbursement (Lord Decl., data as of 3pm ET Aug 21) ⚠️ STUCK REFUNDS: 22,170 refunds totaling ~$1.7B have NOT been transmitted to Treasury — no ACH account information from the importer of record or its Form 4811 designee. That was 19,726 two weeks ago 🔴 CAPE PHASE 3 PORTAL FUNCTION STILL NOT LIVE — CBP's Aug 25 report confirms Phase 3 remains delayed while it builds additional system validations, with no new deployment date given ⚖️ JULY 17 CIT ORDER: Judge Eaton ordered CBP to reliquidate finally liquidated entries — a case-linked path for the ~3,700 filed CIT plaintiffs only, with counsel supplying importer IDs 📌 SECTION 338 CANADA NOW IN EFFECT: 50% additional duties took effect 12:01 AM ET Aug 22 after a 3-day pause — talks with Canada collapsed Aug 21. No USMCA carve-out. No expiration date ⚑ FTZ TRAP: covered Canadian goods admitted to a foreign trade zone on or after Aug 22 must enter under privileged foreign status (19 C.F.R. 146.41) — otherwise they pick up the 50% on consumption entry 🚩 CBP REPORTEDLY OFFSETTING IEEPA REFUNDS against disputed and non-fixed debts, and reapplying full Section 232 duty rates on some entries — per multiple attorneys, Aug 28 ❓ JUDGE EATON ASKS CBP whether it deleted entry information tied to IEEPA duties — no substantive answer filed yet as of Aug 28 ⚖️ BOTH CLASS CERTIFICATION ARGUMENTS NOW HEARD — V.O.S. Selections (Aug 6) and Freestyle World (Aug 19) — neither ruling has issued as of Aug 28 ⚖️ NEW LEGAL FRONT: importers led by Learning Resources challenge the Section 301 forced-labor tariffs themselves as exceeding USTR's statutory authority — filed Aug 24 📋 AGS Company Automotive Solutions withdraws from Federal Circuit appeal proceedings (No. 2026-1897) — Aug 24; the consolidated appeal itself continues 📊 CAPE VOLUME as of July 31 (historical): 252,496 declarations submitted • 178,213 passed file validation • 25.1M entries accepted — see the Aug 25 filing above for the current $132.5B / 26.4M total ✅ JULY 28: Fed. Cir. dismissed Appeal No. 2026-1898 (Euro-Notions) on the government's own motion — Nos. 2026-1895 (lead), -1897, -1899 remain consolidated and active 📅 DOJ's Federal Circuit opening brief was due August 3, 2026 — still not confirmed filed on the docket as of August 28, 2026 📌 Freestyle World, Inc. v. United States (1:26-cv-01088) is the lead IEEPA refund case — oral argument was held Aug 19; a ruling is still pending ⚠️ JULY 24: Section 122 expired — replaced same-day by new Section 301 forced-labor tariffs (10–12.5%) on 60 countries, now themselves under legal challenge (see above) 📈 Don't assume the announced rate is what you paid — rates shifted repeatedly across the IEEPA period. Pull ACE report ES-003 for your actual duties assessed before estimating a refund ⚖️ Liberty Justice Center is fighting on two fronts: a CIT class certification motion for importers stuck outside CAPE, and a separate challenge to the Section 301 forced-labor tariffs 📅 Class certification motion (Rule 23(b)(2), V.O.S./Terry Precision) filed June 4, 2026 — class defined by CURRENT CAPE ineligibility, not final liquidation alone ⚔️ 90-day §1501 statutory liquidation-finality window vs. 80-day practical CAPE cutoff — these are not the same date, ask which one applies to you ⚖️ SCOTUS 6-3 Feb 20: Learning Resources v. Trump — IEEPA tariffs ruled unlawful • $166B+ refundable across ~53M entries and ~330,000 importers of record (CIT court filings)
🟢 Aug 25 CBP Filing
$132.5B Accepted, $106.6B Sent to Treasury — Phase 3 Still Delayed CBP's Aug 25 report to the CIT (data as of Aug 21) confirms Phase 3 remains undeployed while CBP builds additional system validations. No new date given.
🔴 Section 338 Canada — Now In Effect
50% Canada Duties Took Effect Aug 22 After a 3-Day Pause — Talks Collapsed First A last-minute proclamation delayed the original Aug 19 date three days; U.S.–Canada talks then broke down. No USMCA carve-out. Lawsuits are expected.
⚠️ Stuck Refunds Still Growing
22,170 Certified Refunds Worth ~$1.7B Are Sitting Unpaid They can't be transmitted to Treasury because no ACH information was provided — up from 19,726 two weeks earlier. Enroll ACH in the ACE Portal before your refund certifies, not after.
Section 338 In Effect • Class Cert Rulings Pending • CIT Filing Still Decides Phase 3 Coverage

Section 338 Landed on Canada.
Class Certification Rulings Aren't Out Yet.
Filing at the CIT Is Still What Covers You.

The Section 338 Canada tariffs didn't take effect on their original date — a last-minute pause and collapsed talks pushed them to August 22. Meanwhile, both class-certification arguments in the IEEPA refund litigation have now been heard, and neither ruling has issued. If you haven't filed at the CIT, nothing currently covers your finally liquidated entries. TariffIQ™ identifies exactly where your entries stand across Phases 1, 2, and 3 — and whether you need to file a CIT complaint to get covered.

⚡ The Tariff Bureau — Phase 3 Eligibility Strategy
01
Already filed at the CIT? Your finally liquidated entries fall under the July 17 order. We confirm your case is on Judge Eaton's docket, coordinate the importer IDs your counsel must supply, and track your refund.
02
Haven't filed yet? You are not covered under CBP's current position, and waiting on a class-certification ruling is not a plan. We assess whether an individual CIT complaint or a timely protest is your faster path.
03
Importing from Canada? We check your goods against all three Section 338 annexes, confirm the correct Chapter 99 heading, and flag any FTZ exposure now that the 50% duty is in effect.
📞 (404) 882-5839  •  Mon–Fri 9am–6pm ET  •  No obligation
$106.6B
Sent to Treasury
$132.5B
Accepted for Processing
~3,700
Filed CIT Cases Covered
26.4M
Entries Accepted
22,170
Certified, Stuck at Treasury
Alex Monroe - AI Trade Analyst, The Tariff Bureau
Alex Monroe
AI Trade Analyst • TariffIQ™
Online
Phase 3 has been ordered, but the portal function isn't live yet — and both class-certification rulings are still pending. Here's what that means for you:

Already filed a CIT case — your finally liquidated entries fall under the July 17 order. Let's confirm your docket status.
Haven't filed at the CIT — nothing currently covers you. We'll look at an individual complaint, a protest, or the pending class actions.
Importing from Canada — the Section 338 50% duty is now in effect. Let's check your goods against the annexes.

Tell me your CIT filing status and liquidation timing, and I’ll tell you exactly where you stand.

AI-powered analysis • Not legal or brokerage advice • Learn more

▶ Alex Monroe • TariffIQ™ Overview

Alex Monroe • AI Trade Analyst • TariffIQ™ • Not legal advice


Wire Intelligence • Updated August 28, 2026

Latest National & International Updates

Live intelligence from the wire services and the court docket — curated for U.S. importers navigating CAPE and the ongoing IEEPA refund landscape.

CBP • Aug 25 Declaration to the CIT
💰 $106.6B Sent to Treasury • August 25, 2026
CBP: $132.5B Accepted for Processing, Approximately $106.6B Certified and Sent to Treasury
In the August 25 declaration of Brandon Lord filed in Freestyle World (1:26-cv-01088), CBP reported that as of 3pm ET on August 21, $132.5 billion in potential and certified refunds had been accepted for processing in CAPE — covering approximately 26.4 million entries — of which approximately $106.6 billion in duties plus interest was certified and sent to Treasury for disbursement. CBP confirmed CAPE Phase 3 remains delayed while it builds additional system validations.
August 25, 2026 • Lord Declaration, CIT No. 1:26-cv-01088
Section 338 • Canada
🔴 Now In Effect — Aug 22, 2026
Section 338's 50% Canada Tariffs Take Effect After a 3-Day Pause — Talks Collapsed First
Hours before the original August 19 effective date, the administration delayed implementation three days, citing Canada's stated commitment to remove the discriminatory measures at issue. Talks then broke down on the evening of August 21 — Canadian PM Mark Carney announced Canada was suspending negotiations and would respond with matching retaliatory tariffs. With no agreement reached, the additional 50% ad valorem duty on certain Canadian-origin goods took effect at 12:01 AM ET on August 22, 2026. USMCA-qualifying goods get no relief, and Section 338 carries no fixed expiration. Excluded: energy, potash, fish, critical minerals, and goods already subject to Section 232. Trade lawyers now expect lawsuits challenging the action.
July 20, 2026 • Presidential Proclamations (3) • Delayed to and effective Aug 22, 2026
CBP • ACH Enrollment
⚠️ Stuck Refunds Still Climbing
22,170 Certified Refunds Worth ~$1.7B Cannot Be Paid — No ACH Information on File
As of August 21, CBP reported 22,170 refunds totaling approximately $1.7 billion that have not been transmitted to Treasury because the importer of record or its authorized CBP Form 4811 designee never provided Automated Clearing House account information — up from 19,726 two weeks earlier. This is entirely self-inflicted and entirely fixable: enrollment happens in the ACE Portal under the ACH Refund Authorization tab.
August 25, 2026 • Lord Declaration • Compare August 4 Decl.
CAPE • Phase 3 Status
🔴 Portal Function Still Not Live
Phase 3 Remains Delayed — CBP Cites Additional System Validations, No New Date
The July 17 order remains a case-linked reliquidation procedure covering only the ~3,700 filed CIT plaintiffs. A CAPE Phase 3 portal function that would let any importer file on finally liquidated entries still does not exist. CBP's August 25 progress report confirms Phase 3 is temporarily delayed while it develops additional system validations, with no deployment date announced. CBP's original late-July target passed with no deployment.
August 25, 2026 • Lord Declaration to the CIT
Attorney Reports
❗ Offsetting & Section 232 Reapplication
CBP Reportedly Offsetting IEEPA Refunds Against Disputed Debts — and Reapplying Full Section 232 Rates
Multiple attorneys report that CBP is netting IEEPA refunds against debts the importer disputes or that have not been finally fixed, rather than paying the certified refund amount outright. Separately, practitioners say CBP is using the IEEPA refund process as an occasion to retroactively apply full Section 232 duty rates to some entries that had been receiving reduced or exempted treatment. Neither practice has been the subject of a formal CBP announcement, and the scope of affected entries is not yet clear.
August 28, 2026 • Multiple practitioner interviews
CIT • Records Inquiry
🚨 Deleted Entry Information?
Judge Eaton Presses CBP Over Whether It Deleted Entry Information Tied to IEEPA Duties
On August 27, Judge Eaton asked the DOJ attorney handling the case whether the government intends to respond to his August 7 letter, which asked whether CBP has any protocol that could have resulted in the deletion of entry information belonging to importers who paid IEEPA duties. No substantive answer has been filed yet, and the scope of any deletion — if it occurred — is not known. Keep your own copies of entry summaries independent of ACE while this is pending.
August 27, 2026 • CIT Order, Freestyle World, CIT No. 26-01088
CAPE • Volume & Validation
📊 Historical • As of July 31
252,496 Declarations Filed — and 5.02 Million Entries Failed Entry-Level Validation
Of 252,496 CAPE declarations submitted as of July 31, 178,213 passed file validation, covering 25.1 million entries accepted for IEEPA duty removal. But 5.02 million entries failed entry-level validation — primarily because the entry date fell outside CBP's 90-day reliquidation authority, the entry carried no Chapter 99 HTS number used to assess IEEPA duties, or the entry was already on a prior declaration. A rejected entry is not a denied claim. See the Aug 25 filing above for the current 26.4M-entry total.
August 4, 2026 • Lord Declaration (superseded by Aug 25 totals above)
Fed. Cir. • Appeal Status
✅ 1898 Dismissed • AGS Withdraws From -1897
Federal Circuit Dismissed Appeal No. 2026-1898 — and AGS Automotive Solutions Has Since Withdrawn From -1897
The Federal Circuit granted the government's own unopposed FRAP 42(b)(2) motion to voluntarily dismiss Appeal No. 2026-1898 (Euro-Notions) on July 28, with mandate issued the same day. Nos. 2026-1895 (lead), -1897, and -1899 remain consolidated and active. On August 24, AGS Company Automotive Solutions notified the court it will not participate further in proceedings on No. 2026-1897 — the consolidated appeal itself continues unaffected. DOJ's opening brief was due August 3; as of August 28 it is still not confirmed filed on the docket.
July 28 & August 24, 2026 • Fed. Cir. Nos. 2026-1895/-1897/-1898/-1899
CIT • Class Certification
⚖️ Both Arguments Heard — Rulings Pending
V.O.S. Selections and Freestyle World Class Certification Arguments Both Heard — Neither Ruling Has Issued
Oral argument on Terry Precision Cycling's class certification motion was heard August 6 in V.O.S. Selections; counsel has said publicly it expects a ruling by month's end. A second argument, in Freestyle World, was held August 19. As of August 28, neither ruling has surfaced on the public docket. The government continues to oppose certification in both cases.
Argued Aug 6 & Aug 19, 2026 • CIT Nos. 25-00066 & 26-01088
CIT • New Litigation
⚖️ Section 301 Itself Challenged • Aug 24
Importers Challenge the Section 301 Forced-Labor Tariffs Themselves — A New Legal Front
Plaintiffs led by Learning Resources filed a motion for judgment on August 24 arguing that the Section 301 forced-labor tariffs — the duties on 60 countries that replaced Section 122 on July 24 — exceeded USTR's statutory authority because the agency did not make the required country-specific findings, and that the action violated the Administrative Procedure Act. This is separate from the IEEPA refund litigation and does not affect CAPE processing, but it opens a new track of exposure on duties importers are paying right now.
August 24, 2026 • In Re Section 301 Forced Labor Cases, CIT No. 26-03555
Rate Verification • ACE ES-003
⚠️ Don't Assume the Announced Rate
Announced Country Rates Are Not the Same As What You Actually Paid
IEEPA rates shifted repeatedly throughout the affected period — a single "announced rate" for a country is a snapshot, not a constant. Before estimating any refund, pull ACE report ES-003 to confirm the actual duties assessed on your specific entries. Any estimate built on headline rates, including ours, is a starting point and nothing more.
Ongoing guidance • CBP ACE Secure Data Portal
Liberty Justice Center
⚖️ Two Legal Fronts
Liberty Justice Center Still Litigating on Two Separate Fronts
Liberty Justice Center's CIT class certification motion seeking to unlock refunds for importers stuck outside CAPE has now been argued (see above), with a ruling still pending. Separately, the organization's distinct challenge to the Section 301 forced-labor tariffs continues — a different case from the new Learning Resources APA challenge to the same tariffs noted above.
2026 • CIT / Liberty Justice Center filings
USTR • Tariff Regime Change
⚠️ Section 122 Expired • July 24, 2026
Section 122 Expired — Replaced Same-Day by Section 301 Tariffs on 60 Countries, Now Under Legal Challenge
Section 122's 10% global tariff expired by statute at 12:01 AM EDT on July 24. USTR's new Section 301 tariffs of 10% or 12.5% on 60 countries — ~99.4% of U.S. imports — took effect the same instant. USMCA and CAFTA-DR textile/apparel goods are exempt, along with 471 additional HTS subheadings. Goods already subject to Section 232 are EXEMPT from the new 301. As reported above, these duties are now themselves being challenged as exceeding USTR's authority.
July 24, 2026 • USTR / Presidential Memorandum • CBP CSMS #69326983
CBP • CAPE Phase 2
🟢 2.2M Reconciliation Entries Filed
Reconciliation-Flagged Entries Are Moving — 2.2 Million Filed and Set for Processing
CBP deployed the reconciliation expansion at 5am ET June 29, per CSMS #69066837, covering flagged entries (types 01, 02, 06) where the Type 09 reconciliation entry has not been filed and the entry is unliquidated or liquidated within 80 days. As of the last confirmed count, 2.2 million reconciliation-flagged entries had been successfully filed in CAPE and set for processing. If your reconciliation deadline is inside 30 days, CBP's guidance is to prioritize the Type 09 filing.
June 29, 2026 • CSMS #69066837
U.S. Senate • S.3905
Legislative Backstop • Not Yet Enacted
Tariff Refund Act of 2026 (S.3905) — 180-Day Refund Mandate Independent of Appeal
S.3905 would require CBP to refund all IEEPA duties within 180 days with statutory interest, creating a priority queue for small businesses. The bill has not been enacted. If passed, it would function as a legislative backstop independent of the Federal Circuit appeal.
May 2026 • U.S. Senate / Sidley Austin LLP

Legal Tracker • Updated August 28, 2026

Key Court Cases & Regulatory Developments

The rulings, orders, and filings directly shaping your refund rights and CAPE filing eligibility.

Supreme Court • Landmark
Learning Resources, Inc. v. Trump
607 U.S. ___ • No. 24-1287 • Decided Feb. 20, 2026

In a 6-3 ruling, the Court held that IEEPA does not authorize the President to impose tariffs. All 2025 IEEPA emergency tariffs were ruled invalid, opening $166–170+ billion in potential refunds across roughly 330,000 importers of record and more than 53 million entries. This ruling is not under appeal — it stands.

✅ February 20, 2026 • Ruling final • Not under appeal
🟢 Reliquidation Ordered • July 17, 2026
Eaton Order — Case-Linked Reliquidation for ~3,700 Filed Plaintiffs
CIT Senior Judge Richard Eaton • Issued July 17, 2026

Judge Eaton ordered CBP to reliquidate, without regard to IEEPA duties, entries liquidated more than 80 days ago — strictly limited to the roughly 3,700 companies whose IEEPA cases are on his docket. This is a case-linked procedure: plaintiffs' counsel supply importer IDs and CBP accepts the resulting CAPE declarations. It is not a public Phase 3 opening. Importers who have not filed a CIT complaint are still not covered.

🟢 Filed CIT cases only • Counsel supplies importer IDs
🔴 CAPE Phase 3 • Not Yet Deployed
Phase 3 Portal Function — No Deployment, No New Date
Lord Declaration to the CIT, August 25, 2026

CBP told the CIT in June that Phase 3 would be ready by end of July. That target passed. The August 25 progress report confirms Phase 3 is temporarily delayed while CBP builds additional system validations, with no new deployment date given. Treat any claim that "Phase 3 is open" as inaccurate until CBP issues a deployment CSMS.

⚠️ Ordered by the court, not deployed by CBP
✅ Fed. Cir. • 1898 Dismissed, AGS Withdraws
Appeal No. 2026-1898 Dismissed — AGS Withdraws From No. 2026-1897
Fed. Cir. Order, No. 2026-1895, Doc. 17 • July 28 & Aug 24, 2026

The Federal Circuit granted the government's unopposed FRAP 42(b)(2) motion to voluntarily dismiss Appeal No. 2026-1898 on July 28, mandate issued the same day. On August 24, AGS Company Automotive Solutions notified the court it will not participate further in No. 2026-1897. Nos. 2026-1895 (lead), -1897, and -1899 remain consolidated and active regardless — the broader appeal continues.

🔴 Appeal narrowed, not resolved
CIT • Class Certification • Both Argued
V.O.S. Selections & Freestyle World, Inc. v. United States
CIT Dockets 25-00066 & 1:26-cv-01088

Oral argument on Terry Precision Cycling's class certification motion was heard August 6 in V.O.S. Selections; a parallel argument in Freestyle World — the lead case for the broader IEEPA refund docket — was held August 19. As of August 28, neither ruling has issued. The government opposes certification in both.

⚖️ Both argued • Rulings pending
CBP CAPE • Phases 1 & 2 Active
CAPE — Consolidated Administration & Processing of Entries
CBP ACE Secure Data Portal • Phase 1: April 20, 2026 • Phase 2: June 29, 2026

Phase 1 launched April 20 for unliquidated entries and entries within 80 days of liquidation; the reconciliation expansion launched June 29. Per CBP's August 25 CIT filing (data as of Aug 21): $132.5B accepted for processing and approximately $106.6B certified and sent to Treasury. 22,170 certified refunds worth ~$1.7B remain stuck solely because the importer or its Form 4811 designee never provided ACH banking information — up from 19,726 two weeks earlier.

✅ CAPE running • Check your ACH enrollment now
Section 338 • In Effect Since Aug 22, 2026
Section 338 Canada Tariffs — 50%, No USMCA Carve-Out
Three Presidential Proclamations, July 20 • Delayed to Aug 22 by an Aug 18 Proclamation

Three proclamations impose an additional 50% ad valorem duty on separate sets of Canadian-origin goods. Originally set for August 19, the effective date was pushed to August 22 by a three-day pause while negotiations continued; talks then collapsed on August 21, and the duty took effect as structured. USMCA preference provides no relief, and Section 338 carries no fixed expiration date. Excluded: energy, potash, fish, critical minerals, and articles already subject to Section 232. Trade lawyers now expect lawsuits challenging the action — this is the first modern use of Section 338.

⚠️ In effect since Aug 22 • Litigation expected
🔴 Federal Circuit • Consolidated Appeal Active
DOJ Appeal — Nos. 2026-1895 (Lead), -1897, -1899
V.O.S. Selections, Inc. v. United States, No. 26-1895 • Filed June 2–3, 2026

DOJ's Federal Circuit appeal, consolidated under No. 26-1895, targets the CIT’s universal injunction for finally liquidated entries. Appeal No. 2026-1898 was voluntarily dismissed July 28; AGS Company Automotive Solutions withdrew from No. 2026-1897 on August 24; the remaining appeals continue. The government's opening brief was due August 3, 2026not confirmed filed as of August 28. Both class-certification motions have now been argued (see above), with rulings still pending. Importers without filed CIT cases should consult trade counsel immediately.

🔴 Appeal active • Brief still unconfirmed as of Aug 28
Section 301 • Effective July 24, Now Challenged
Section 301 Forced-Labor Tariffs — 60 Countries
USTR / Presidential Memorandum • Effective July 24, 2026

On July 23, 2026, President Trump signed a memorandum directing USTR to impose new Section 301 tariffs of 10% or 12.5% on imports from 60 countries — roughly 99.4% of all U.S. imports. The duties took effect at 12:01 AM EDT on July 24, the same instant Section 122 lapsed. USMCA-qualifying and CAFTA-DR textile/apparel goods are exempt, along with 471 additional HTS subheadings. Goods already subject to Section 232 are EXEMPT from this new 301. On August 24, plaintiffs led by Learning Resources filed a motion for judgment arguing the action exceeded USTR's statutory authority and violated the APA — a new, separate legal front.

⚠️ Effective now • Itself under legal challenge as of Aug 24
Congress • S.3905
Tariff Refund Act of 2026 — Senate Bill S.3905
U.S. Senate • Introduced May 2026 • Not Yet Enacted

S.3905 would require CBP to refund all IEEPA duties within 180 days of enactment, with statutory interest, and create a priority queue for small businesses. The bill has not been enacted. If it were, it would function as a legislative backstop independent of the Federal Circuit appeal.

📅 Introduced May 2026 • Not yet enacted • Monitor Finance Committee
⚡ CAPE Live Statistics • Data as of 3pm ET Aug 21, 2026
$132.5 Billion Accepted for Processing — Approximately $106.6 Billion Sent to Treasury
Source: Declaration of Brandon Lord, Executive Director, Trade Programs, CBP — filed August 25, 2026 in Freestyle World, Inc. v. United States, CIT No. 1:26-cv-01088
$106.6BSent to
Treasury
$132.5BAccepted for
Processing
26.4MEntries
Accepted
22,170Stuck, No
ACH on File
Both HeardClass Cert
Arguments
Aug 22Sec. 338
In Effect
🚨
CBP Official Scam Warning: CBP has documented active IEEPA refund scams. File only through the official ACE Secure Data Portal at cbp.gov. Verify all communications originate from @cbp.gov addresses. The Tariff Bureau provides advisory and filing-preparation services only — we do not log into ACE on your behalf or request portal passwords.

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