Reviewed by Sasha Božič, Licensed Customs Broker
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The Bottom Line
We covered the delay in CBP's IEEPA refund program earlier this month. On September 15, CBP confirmed that CAPE Phase 3 refunds will open on October 6. This is the phase for finally liquidated entries, and for now, it applies to importers that filed their own lawsuit and have a court order allowing those entries to be reliquidated.
A couple other dates to note: 1) Canada's Section 338 import bans on certain packaged alcohol, dairy, and motorcycles are set to start September 29. 2) Commerce's final antidumping and countervailing duties on solar cells from India, Indonesia, and Laos took effect September 16.
IEEPA Refunds
CBP confirmed in a September 15 court filing that importers who sued over the IEEPA tariffs and received an order to reliquidate their entries can start filing for refunds on October 6 as part of Phase 3.
Phase 3 covers finally liquidated entries, including entries that closed more than 80 days ago and that CBP says it can't reopen without a court order. It's a narrow group: plaintiffs with a pending Court of International Trade case where the court ordered reliquidation. Importers that gave CBP a valid importer-of-record number by July 30 get to file first.
CBP has already sent more than $100 billion in IEEPA refunds to Treasury for disbursement across the first two phases. For companies with a case, make sure the entries are covered by the reliquidation order and that CBP has current ACH information for the importer of record (missing banking information can hold up the refund).
Importers that never filed suit aren't included in this phase. For now, the window is limited to plaintiffs. Whether refunds will eventually extend to companies that didn't sue is still being litigated at the Federal Circuit.
Sources: CBP declaration to the CIT, our September 2 issue
Trade Remedies
Commerce issued final antidumping and countervailing duty determinations on solar cells from India, Indonesia, and Laos on September 16.
For India, Commerce set a 123.04% dumping margin and a 126.09% subsidy rate after the Indian producers dropped out of the case. After the subsidy offset, the cash deposit rate on the dumping side is 107.17%.
Commerce also found "critical circumstances," so suspension of liquidation goes back to January 28. The orders will follow after the International Trade Commission completes its injury vote.
Sources: Federal Register: dumping, subsidies
Steel Rebar Duties. Commerce issued antidumping and countervailing duty orders on concrete reinforcing bar from Bulgaria, Egypt, and Vietnam on September 18. Cash deposits and suspension of liquidation continue, with the antidumping duties reaching back to March 13. (Federal Register: AD orders, CVD orders)
Tin Mill Products From China. Commerce issued a preliminary antidumping determination on tin mill products from China, adding a dumping case to the countervailing duty case already underway. A critical-circumstances finding could pull earlier entries into the case, and Commerce extended the provisional measures period. (Federal Register)
Evasion Findings. Commerce preliminarily found that steel wire garment hangers finished in Cambodia using Chinese or Vietnamese wire circumvent the existing orders, and that Chinese compacted graphite iron brake drums are later-developed merchandise already covered by the brake-drum orders. (Federal Register: hangers, brake drums)
What We're Watching
Canada's September 29 Import Ban. The Section 338 bans on certain packaged Canadian alcohol, dairy, and motorcycles are set to take effect September 29, and CBP hasn't published filing guidance for the ban itself. We're watching for the ACE mechanics and the transitional treatment of goods already imported, and we'll cover them when they land.
Check Your CAPE Phase 3 Eligibility
Confirm you have a case pending at the Court of International Trade with a reliquidation order, and that CBP has your importer-of-record number and current ACH details. Refunds can't move forward without them.
Screen Canadian-Origin Entries Before September 29
Pull every Canadian-origin line and check the full 10-digit HTS against the banned-product lists. Goods imported before September 29 stay at the 50% duty and goods that arrive after will be refused entry.
Reprice Solar Cells From India, Indonesia, and Laos
If you import cells or modules from these countries, update landed costs for the final antidumping and countervailing cash deposit rates.
Reach Out to Caspian to Understand Your Impact
Multi-Origin Products
Model duty on a product you buy from more than one country. A product can hold more than one country of origin, and a simulation prices whichever origin you pick. Record aluminum and steel content and the estimate reflects Section 232 on the metal.
Related-Party Details From 7501s
See related-party information pulled straight from your 7501 entry summaries. Caspian pulls it from the form, so valuation questions show up with the entry instead of in a separate review.
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