Expeditors (EXPD) Status update summary

Key updates on CAPE and IEEPA refunds

• CAPE Phase 1 launched on schedule, allowing importers and brokers to request IEEPA duty refunds for eligible entries via the ACE portal; refunds are not automatic and require submission.

• Only entries unliquidated or within 80 days post-liquidation are eligible in Phase 1; future phases will address other scenarios.

• Refunds are expected 60-90 days after CAPE acceptance, with June as a likely timeline for initial payments, pending potential government appeal.

• Data validation and entry sequencing are critical; issues like "unable to calculate duty" are rare but require troubleshooting.

• Filing strategy should prioritize entries near liquidation deadlines and ensure all post-summary corrections are completed before CAPE submission.

Section 232 and 301 tariff changes

• Section 232 tariffs on metals have been unified for steel, aluminum, and copper, now assessed on the full value of articles, with tiered rates (15%, 25%, 50%) effective April 6.

• Some HTS numbers were removed from Section 232 duties; de minimis content below 15% may be excluded.

• New pharmaceutical tariffs target patented drugs and ingredients, with incentives for companies agreeing to reshore or MFN pricing; generics are currently excluded.

• Section 301 investigations have expanded, targeting overcapacity and forced labor across a broad range of countries, covering 99% of U.S. trade.

• Remedies from these investigations are expected to be system-wide, making it harder to avoid duties by shifting sourcing.

Legal and legislative developments

• The government has until early June to appeal the IEEPA refund ruling, potentially pausing refunds.

• Section 122 authority for tariffs is set to expire July 24 unless extended; legal challenges and congressional proposals could impact valuation and importer privileges.

• Ongoing Section 301 and 232 investigations continue in sectors like autos, semiconductors, and digital services, with new announcements expected as deadlines approach.