New Section 301 hearings target forced labor

U.S. tariff refunds

On April 20, the federal government opened the process for importers to begin filing for refunds of tariffs that were overturned by the U.S. Supreme Court. Importers or their customs brokers must have or set up access to the Automated Commercial Environment (ACE), ensure their bank information is on file, and submit refund requests through the new Consolidated Administration and Processing of Entries (CAPE) tool. Refund requests may not be initiated via post summary corrections.

As of an April 28 update, U.S. Customs expects to begin issuing the first refunds on or about May 11. Approximately 21% of eligible entries have been accepted into the system, while about 3% have reached the refund stage. The U.S. Court of International Trade has directed U.S. Customs to provide a progress report by May 12. For more detail, read our client advisory.

Alternative tariffs

Meanwhile, the reciprocal tariffs and other tariffs that were struck down have been replaced by a temporary, universal 10% Section 122 tariff that remains in effect through July 24, 2026, and can only be extended by an affirmative vote of Congress.

Concurrently, the U.S. administration has made clear its intent to reconstruct previous country-specific tariff levels through new Section 301 actions. The first Section 301 hearing, in April, addressed concerns related to screening for forced labor and supply-chain due diligence in 60 countries. A second set of hearings the first week of May focused on alleged excessive industrial capacity in 16 countries plus the European Union and its impact on U.S. producers.

Following these hearings and the public comment period, the U.S. administration could finalize new Section 301 tariffs at levels similar to the former rates as early as the first week of June 2026, setting the stage for implementing country-specific trade deals.

Increased steel, aluminum, and copper tariffs

On April 2, 2026, the White House issued a new proclamation adjusting the tariffs on imports of steel, aluminum, and copper into the United States. The action raises tariff rates, expands the base on which the tariffs are applied, and tightens enforcement.

These commodity-specific Section 232 tariffs now apply to the entire customs value of the covered steel, aluminum, and copper articles and their derivative products, regardless of actual metal content, eliminating the previous approach that applied the tariff only to the metal portion of the item.

For the new tariff rates, see our client advisory.

New tariff-free provision for non-metal content

The Bureau of Industry and Security introduced a tariff-free provision under subheading 9903.82.01 for goods classified as steel, aluminum, or copper articles that do not actually contain those metals. This exemption applies to eligible imports entered on or after April 6, 2026.

Reduced tariffs tied to U.S. manufacturing commitments

The Department of Commerce issued guidance outlining how Canadian and Mexican steel and aluminum producers may qualify for reduced Section 232 tariffs—up to 50%—if they supply U.S. auto or heavy-duty vehicle manufacturers and commit to expanding production in the United States. This follows the October 2025 proclamation authorizing such reductions.

Visit our Trade & Tariff Insights page for the latest news, insights, perspectives, and resources from our customs and trade policy experts.

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