Customs and Border Protection (CBP) has announced that the first phase of the IEEPA tariff refund process will open on April 20, 2026, through its Consolidated Administration and Processing of Entries (CAPE) program in the Automated Commercial Environment Secure Data Portal (ACE Portal).  For this first phase of refunds, CBP is only accepting certain unliquidated entries and certain entries within 80 days of liquidation.  Using the ACE Portal, Importers of Record, and their authorized Customs Brokers, will be able to consolidate and submit their IEEPA refund requests, including interest, to cover multiple entries where IEEPA tariffs were imposed.  Once the submission is accepted, CBP will remove the IEEPA tariff number and recalculate the duties due without IEEPA tariffs, updating the entries to a new version.  CBP will review the updated version of the entries and liquidate or reliquidate.  Refunds will be consolidated by Importer of Record or designated party.  In order to request the IEEPA tariff refunds, importers/brokers will need to be registered in the ACE Portal and enrolled with CBP for ACH refunds.  Additional information on the CAPE refund program can be found at CBP’s website.  While this first phase of refunds is limited to unliquidated or recently liquidated entries, CBP has said that later phases of the CAPE rollout will include other types of entries, including entries for which liquidation is final, or more than 80 days have passed since liquidation.

Tariffs up to 100 percent on imports of certain pharmaceuticals and their ingredients have been imposed by the U.S.  On April 2, President Trump issued a proclamation pursuant to a Section 232 investigation that will impose a new 100 percent tariff on imports of patented pharmaceutical products and ingredients.  These new tariffs will come into effect in 120 days for certain large companies, and 180 days for other companies.  However, not all pharmaceutical imports will face the highest level of tariffs.  If a pharmaceutical product is from the EU, Korea, or Switzerland and Liechtenstein, a 15 percent tariff will apply.  If a pharmaceutical product is from the United Kingdom, a lower tariff will apply, subject to the recently concluded UK pharmaceutical agreement.  For companies that enter into Most Favored Nation (MFN) pricing agreements with the Department of Health and Human Services and onshoring agreements with the Department of Commerce, a 0% tariff will apply through January 20, 2029. For companies that only enter into onshoring agreements with the Department of Commerce, a 20 percent tariff will apply.  Generic pharmaceutical products, biosimilars, and associated ingredients are not subject to tariffs at this time, but will be reassessed in one year.  Orphan drugs, drugs for animal health, and certain other specialty pharmaceutical products will be exempt, if they are from trade deal countries or meet an urgent public health need.  The Proclamation establishes monitoring and enforcement mechanisms on subject imports.

On April 2, President Trump issued a proclamation that restructured the Section 232 tariffs on steel, aluminum and copper, and derivative products.  Under this new structure, the Section 232 tariffs will apply to the full customs value of the imported product, not just the subject metal content.  Updated tariff rates will be applied to the customs value of certain imports.  Products of steel, aluminum or copper will be subject to 50 percent ad valorem tariffs.  Subject derivative products made of steel, aluminum, or copper will be subject to 25 percent ad valorem tariffs.  Certain metal-intensive industrial equipment and electrical grid equipment will be subject to a total combine tariff of 15 percent, applicable through December 31, 2027.  Products manufactured overseas using at least 95 percent aluminum, steel, or copper that was melted/smelted and poured/cast in the U.S. will be subject to 10 percent ad valorem tariffs.  Products that contain less than 15 percent steel, aluminum, or copper will not be subject to any Section 232 tariffs.  Additionally, specific derivative products identified in Annex II of the Proclamation will no longer be subject to Section 232 tariffs.  The changes made in the Proclamation apply to imports entered for consumption on or after April 6, 2026.

Keeping track of all the tariffs that have been promulgated or proposed during the Trump Administration continues to be a head-spinning task.  To help follow the proliferation of tariffs in the Trump Administration, I have put together the following list of each of the tariff measures that have been implemented, pending, or proposed since January 20, 2025. 

Here is the developing landscape of U.S. tariffs as of April 13, 2026:

This list will be updated as new tariffs are implemented and new targets for tariffs are identified by President Trump and the administration.