Expeditors (EXPD) Status update summary

Tariffs and trade measures

• Section 338 Canada measures include 50% tariffs and an import ban effective Sept. 29; the HTS scope means impacts can extend beyond dairy, autos and alcohol.

• Entry data showed agriculture and prepared products surged before the ban, with shipments nearly doubling, then declined; other tracked sectors saw limited movement.

• Section 232 polysilicon duties remain scheduled for Dec. 4; Commerce’s anti-stockpiling rule requires approval for imports above normal levels or storage in a bonded warehouse until implementation.

• A Russia-sanctions law could impose stacking secondary tariffs, but an Oct. 16 executive order set rates and waived the new duties and most provisions for now; no new Russia-related tariffs are in effect.

IEEPA refunds and litigation

• CBP had processed $136.6bn of the $166bn in IEEPA duties cited at CAPE launch; $126bn had been refunded or sent to Treasury for refund, with ~ $30bn still outstanding.

• CAPE Phase 3 launched Oct. 6; by Oct. 7, more than 1m entries covering $500m in refund claims had been accepted. Eligibility requires a CIT lawsuit, timely IOR submission and entries beyond the 80-day post-liquidation threshold.

• CBP is issuing Phase 3 filing instructions in waves; importers with lawsuits and IOR details submitted July 31–Aug. 13 became eligible, with later filers to receive instructions on a rolling basis.

• Judge Eaton certified a class covering importers that paid IEEPA duties from Feb. 1, 2025, to Feb. 19, 2026, except those that filed CIT lawsuits; refunds still require further court action and may take years.

• Importers were advised to weigh refund amounts, entry status, litigation costs and the two-year filing deadline with counsel; separate Section 301 forced-labor and Section 122 cases remain under court review and could create refund opportunities.

Policy outlook

• U.S.-China Section 301 tariffs remain in place; a Board of Trade initiative identifies 77 product categories for possible MFN treatment, with details and a comment period still developing.

• A proposed rule on informal entries has comments due Dec. 7; it would restrict use after U.S. arrival, add data requirements and allow Section 232/301 goods valued $250–$2,500 to use informal entries again.

• A Section 301 overcapacity case remains pending; 75% of G20 members endorsed cooperation on cars, EVs, batteries, chemicals, semiconductors and solar panels.