📋 USITC Section 338(g) comment request — how the Commission should carry out its Section 338 duties US International Trade Commission (USITC) On September 4, 2026, the USITC asked for public comments on how it should carry out its duties under Section 338(g) of the Tariff Act of 1930, which cover identifying discrimination against US commerce by any country, collecting information and advising the President. The notice is general: it is not a case against Canada and does not set the product lists for the Section 338 tariffs and bans on Canadian goods. Before the Canada tariffs, Section 338 had never been used to impose tariffs (Holland & Knight). Next deadline November 8, 2026 · Comments due November 8, 2026 at 5:15 p.m. ET ▾
🚫 Section 338 import bans — Canadian alcohol, whey products and motorcycles, effective September 29, 2026 Executive / White House President Trump signed multiple Section 338 proclamations on September 8, 2026, banning imports of packaged Canadian beer, wine, spirits and cider; whey products, molasses and non-alcoholic beer; and motorcycles and mopeds over 800cc, effective September 29, 2026. Listed dairy such as milk and cream, and the cheeses listed Sept 15, stay at the 50% tariff, as does bulk alcohol. Transition rule confirmed by GHY International and Thompson Hine: goods imported but not entered for consumption before September 29 remain subject to 50% Section 338 duty rather than the ban. Next deadline Ongoing · Import bans now in effect from 12:01 a.m. ET on September 29, 2026; transition rule: goods imported but not entered for consumption before September 29 remain subject to 50% Section 338 duty rather than ban; no imports of covered goods permitted after entry deadline; product lists published in proclamations with detailed HTS annexes; American Action Forum calculates covered goods totalled $967 million in Canadian imports (2025 figures), with alcoholic beverages roughly 87% of that value (AP, September 29, 2026) ▾
📦 De minimis suspension made indefinite under the Tariff Act of 1930 — CBP interim final rules (June 24, 2026) US CBP / Federal Register On June 24, 2026, CBP published two interim final rules that make the suspension of the $800 de minimis exemption indefinite in its regulations: one for shipments arriving by any mode other than the international postal network (effective June 24, 2026) and one for mail, with a new postal informal entry process (effective July 24, 2026). CBP relies on 19 U.S.C. 1321(b) of the Tariff Act of 1930, which allows exceptions to the exemption when needed 'to protect the revenue or to prevent unlawful importations'. The exemptions for bona fide gifts and personal or household articles are not affected. Next deadline Ongoing · Both rules in effect; the CIT separately upheld the suspension on August 13, 2026 ▾
💰 CAPE Phase 2 — IEEPA refund claims extended to reconciliation entries US CBP CBP launched CAPE Phase 2 on June 29, 2026, extending IEEPA refund claims to reconciliation entries. As of September 11, 2026, CBP had accepted about $134.7B in claims and sent about $122B to Treasury for payment; about $1.3B is held up because importers haven't registered for ACH refunds. Next deadline Ongoing · CAPE Phase 3 opened October 6, 2026 for court plaintiffs only; DOJ's Federal Circuit appeal continues; Congress urged CBP on September 9 to address delays ▾
💰 DOJ Federal Circuit appeal — IEEPA refund universal injunctions US Court of Appeals for the Federal Circuit The DOJ filed its notice of appeal on June 2, 2026, challenging the scope of the Court of International Trade's universal injunctions governing IEEPA duty refunds. CBP had accepted about $134.7 billion in refund claims and sent about $122 billion to Treasury as of September 11, 2026. Next deadline Ongoing · Federal Circuit briefing and argument; dates not confirmed. About $134.7B in refund claims accepted as of September 11, 2026 ▾
⚖️ 25 states v. the Trump administration — Section 301 forced-labor tariffs US Court of International Trade (CIT) On August 3, 2026, the attorneys general of 25 states, co-led by Oregon, Arizona and California, sued in the Court of International Trade to overturn the Section 301 forced-labor tariffs (10–12.5% on 60 economies since July 24, 2026). They claim the tariffs violate the Administrative Procedure Act because USTR exceeded its statutory authority, acted contrary to law and acted arbitrarily and capriciously, including by imposing across-the-board tariffs not tied to ending the conduct it investigated. The suit joins earlier challenges by small businesses Burlap and Barrel, Inc. and Collective Horology LLC. Next deadline Ongoing · Pending at the CIT, alongside earlier suits by Burlap and Barrel, Inc. and Collective Horology LLC ▾
🚁 Section 232 unmanned aircraft systems — tariffs in effect September 3, 2026 Executive / Commerce Dept Proclamation 11055 (August 13, 2026), under Section 232 of the Trade Expansion Act: 100% on drones over 25 kg or with thermal imagers and 25% on smaller drones from September 3, 2026; 25% on listed components from February 9, 2027, 180 days after the proclamation. Next deadline February 9, 2027 · Component tariffs take effect February 9, 2027; UAS tariffs in effect as of September 3, 2026 ▾
⚖️ Section 301 forced-labor tariffs — 60 countries, 10–12.5%, effective July 24, 2026 USTR Section 301 forced-labor tariffs took effect at 12:01 AM EDT on July 24, 2026, replacing the expired Section 122. Rates: 10% for 19 economies (including Canada, Mexico, the UK and India; the EU and Taiwan pay 10% including their normal duty); 12.5% for the other 41 (including China; Japan, Korea and Switzerland pay 12.5% including their normal duty). A coalition of 25 states sued in the Court of International Trade on August 3, 2026, joining earlier suits by two small businesses. Next deadline Ongoing · Suits by 25 states (filed August 3, 2026) and by small businesses Burlap and Barrel, Inc. and Collective Horology LLC pending at the Court of International Trade ▾
🍁 Canada Section 338 tariffs — 50% on $27.6B CAD Canadian goods, effective August 22, 2026; Canada retaliates September 8; US import bans signed September 8, in effect September 29; tariff stacking reversal September 15; scope expansion September 15 Executive / White House Three proclamations (Proclamations 11046, 11047, 11048) signed July 20, 2026 imposed 50% tariffs under Section 338 on approximately $27.6 billion CAD of Canadian goods — the first time Section 338 has ever been used to impose tariffs. Tariffs took effect August 22; Canada retaliated September 8 with 15–50% duties on 629 tariff items (C$27.6B in affected imports). September 8 proclamations added 122 HTSUS items (specialty cheeses, ATVs, golf carts, motorboats, furniture, lamps, and steel and aluminum structures) and removed rock salt, Portland cement and a few other goods effective September 15, and reversed the non-stacking policy: goods on two of the three Section 338 lists now pay Section 338 duties on top of Section 232 duties. Bans on packaged Canadian alcohol, whey products and motorcycles over 800cc are in effect from September 29, 2026; listed dairy and cheeses stay at 50%. Next deadline Ongoing · US import bans on packaged Canadian alcohol, whey products and motorcycles over 800cc in effect from 12:01 a.m. ET on September 29, 2026 (transition rule: goods imported but not entered for consumption before September 29 subject to 50% duty rather than ban); Section 338 + Section 232 stacking for goods on two of the three Section 338 lists (effective September 15; up to 75% combined on some steel and aluminum structural products); no bilateral talks scheduled as of September 25; Trump's 50% auto tariff threat for January 1, 2027 ▾
🌎 Brazil Section 301 tariffs — 25% rate effective July 22, 2026 USTR USTR announced on July 15, 2026 a 25% Section 301 tariff on most goods of Brazil from 12:01 a.m. ET on July 22, 2026 (FR 2026-14542). The investigation covered digital trade and electronic payments, unfair preferential tariffs, intellectual property protection, ethanol market access and illegal deforestation. Exempt: goods already under Section 232, civil aircraft and parts, beef, orange juice, energy products, certain pharmaceuticals, and donations and informational materials. Next deadline Ongoing · Since July 24, 2026 Brazil's goods also pay the 12.5% Section 301 forced-labor tariff (with its own exemptions), so non-exempt goods can pay 37.5% combined ▾
🍄 Canadian fresh mushrooms — anti-dumping and countervailing duty investigations US Department of Commerce / USITC Commerce announced preliminary anti-dumping rates on Canadian fresh mushrooms on July 14, 2026 (published July 17): 2.00–11.80% by company and 8.26% for all others. The petitioners had alleged 26.29–38.31%. Preliminary countervailing duty rates of 1.62–4.97% (all others 2.84%) were published May 18, 2026, and the final countervailing duty determination is aligned with the final anti-dumping determination. Next deadline November 17, 2026 · USITC final-phase hearing November 17, 2026; Commerce's final anti-dumping determination is due within 135 days of July 17, 2026 (late November), with the countervailing duty final aligned to it ▾
🍷 CANADA Act — Section 301 investigation of provincial liquor bans US Congress / USTR Rep. Claudia Tenney (NY-24) introduced the Combating Attacks on our National Alcoholic Drinks by Allies (CANADA) Act on July 6, 2026. The bill would direct USTR to open a Section 301 investigation of the provincial restrictions on US alcohol, in place since March 2025, within 30 days of enactment. US wine exports to Canada fell 78%, from US$460M in 2024 to US$103M in 2025 (CBC). Separately, the US bans packaged Canadian beer, wine, spirits and cider under Section 338 from September 29, 2026. Next deadline Ongoing · US bans on packaged Canadian beer, wine, spirits and cider in effect from September 29, 2026; Canada suspended trade talks on August 21, and none were scheduled as of September 25 despite Trump's September 12 de-escalation signal ▾
💊 Germany pharmaceutical pricing — Section 301 investigation USTR USTR initiated a Section 301 investigation against Germany on June 18, 2026, alleging persistent underpayment for innovative pharmaceutical products and that Germany's pricing policies shift a disproportionate share of global R&D costs to the US. Written comment period closed August 10, 2026; public hearing on September 22, 2026. Next deadline Ongoing · Post-hearing rebuttal comments were due seven calendar days after the hearing ended (September 29 if it lasted one day); written comments closed August 10; USTR's determination is next ▾
🤝 CUSMA/USMCA joint review — negotiations suspended; retaliation cycle active; import bans in effect September 29; Trump de-escalation signal September 12; Canada explores EU alliance; stacking reversal September 15 US-Canada-Mexico Joint Commission USTR Greer confirmed July 1, 2026 that the Trump administration does not agree to renew CUSMA for a 16-year extension to 2042. Section 338 tariffs signed July 20 apply regardless of USMCA status. Canada suspended talks on the evening of August 21; Canada's retaliatory tariffs took effect September 8; US import bans signed September 8 now in effect September 29; Section 338 + Section 232 now stacking effective September 15; 122 HTSUS items added and rock salt/cement removed effective September 15. PM Carney addressed the European Parliament September 17 as Canada explores EU alignment; EU Commission President proposed Canada as EU's first 'associate member' September 16. Next deadline Ongoing · US import bans on packaged Canadian alcohol, whey products and motorcycles over 800cc in effect from September 29 (transition rule applies); tariff stacking now in effect (Section 338 + Section 232, cumulative); Trump said September 12 that a deal could come 'fairly soon', then said October 6 that he was in no rush to resume trade talks with Canada; Trump's 50% auto tariff threat for January 1, 2027 ▾
🇪🇺 EU-US reciprocal tariff deal — 15% all-inclusive ceiling Executive / Council of the EU The Council of the EU gave final approval on June 25, 2026 to two regulations: Regulation (EU) 2026/1455, which removes EU duties on most US industrial goods and opens quotas for some US farm and seafood products (applies to end-2029), and a regulation restoring duty-free entry for US lobster (retroactive to August 1, 2025). The EU's side took effect July 1, 2026. The 15% all-inclusive US ceiling dates from the August 2025 joint statement; since July 24, 2026 most EU goods pay 10% including the normal duty (Section 301). EU autos remain at 15% (Section 232 deal rate since August 2025); EU confirmed carved out of Section 301 stacking rules on July 24, paying 10% (not 12.5%) and protected by the 15% ceiling. EU steel and aluminum mill products pay 50%; EU goods on the 25% derivatives list pay 15% all-in since June 8, 2026. Next deadline December 31, 2026 · December 31, 2026: the EU can suspend its steel and aluminum concessions if the US still charges more than 15% on EU steel and aluminum derivative products (Regulation (EU) 2026/1455). MFN-only treatment for EU generics, their ingredients and chemical precursors has applied since September 1, 2025 ▾
⚖️ Section 122 tariffs — Federal Circuit appeal (tariff expired July 24, 2026) US Court of Appeals for the Federal Circuit Section 122 expired at 12:01 AM EDT on July 24, 2026 by operation of law (150-day statutory maximum). The CIT ruled 2-1 on May 7, 2026 that Section 122 was unlawful, but limited its permanent injunction to the named plaintiffs: Burlap & Barrel, Inc., Basic Fun, Inc. and the State of Washington. The government appealed on May 8; the Federal Circuit granted an administrative stay on May 12 and a stay pending appeal on June 11, which also put the plaintiffs' refunds on hold. Next deadline Ongoing · Federal Circuit appeal pending; the June 11, 2026 stay pending appeal also holds the named plaintiffs' refunds ▾
🔧 Section 232 steel/aluminum derivatives — tiered rate restructure Executive/Commerce Dept Proclamation 11021 (effective April 6, 2026, on full customs value): 50% on steel and aluminum mill articles, 25% on derivatives, 15% on industrial and grid equipment through December 31, 2027. Proclamation 11032 (June 1, 2026, effective June 8): the 15% tier widened to farm equipment and residential HVAC; CUSMA-qualifying Canadian and Mexican goods on the 25% list pay only on non-US content (at least 15%); EU, Japan, Korea, Switzerland, UK and Taiwan pay 15% all-in on that list; the threshold for counting as made entirely of US metal drops from 95% to 85%. Effective September 15, 2026, goods on two of the three Section 338 Canada lists pay Section 338 duties on top of Section 232 duties — ending the prior non-stacking policy. Next deadline December 31, 2027 · 15% rate on industrial, grid and farm equipment and residential HVAC runs through December 31, 2027; Section 338 now stacks on Section 232 for Canada effective September 15, 2026 — up to 75% combined on some steel and aluminum structural products ▾
📋 Section 301 China tariffs — second four-year review USTR USTR began the second statutory four-year review of the two 2018 China Section 301 actions on May 6, 2026: the July 6, 2018 action (List 1, 25% on about $34 billion of annual trade) and the August 23, 2018 action (List 2, 25% on about $16 billion). Industries that benefit could request continuation from May 7 to July 5, 2026 (List 1) and from June 24 to August 22, 2026 (List 2). By statute an action ends at its four-year anniversary only if no continuation request is received. Next deadline Ongoing · No Federal Register notice on the outcome as of September 25, 2026; if continuation requests were received, the actions continue and USTR conducts the review ▾
🔍 Section 301 investigations — 76 economies USTR USTR opened Section 301 investigations of 16 economies for excess capacity (March 11, 2026; Canada not included) and 60 for forced labor (March 12). Forced-labor determination (60 economies, 10–12.5%) took effect July 24, 2026, replacing Section 122. Excess capacity investigations ongoing separately; a 7.5% overcapacity tariff on Chinese goods was reported (Bloomberg, August 24) but had no USTR finding as of September 25. Next deadline Ongoing · Excess capacity investigations ongoing separately; USTR has published no finding yet. A 7.5% China overcapacity tariff was reported by Bloomberg on August 24; USTR had published no finding as of September 25, and Trump and Xi met on September 24 ▾
💊 Pharmaceutical tariff deadlines — 100% base rate Executive/Commerce Dept 100% tariff on patented pharmaceutical products and APIs applies from July 31, 2026 to large companies (Annex III) and from September 29, 2026 to all others. Federal Register document 2026-19498 (published September 23, 2026) confirms guidance and procedures for implementing Proclamation 11020, including modification of HTS codes from 9903.04.60-9903.04.69 to 9903.04.60-9903.04.70. The UK pays 10%; the EU, Japan, Korea and Switzerland 15%. Companies with Commerce-approved onshoring plans pay 20% until April 2, 2030, or 0% until January 20, 2029 if they also have an HHS MFN pricing agreement. Next deadline April 2, 2030 · 100% tariff now applies to all other (non-Annex III) companies from September 29, 2026; HTS scope modified from 9903.04.60-9903.04.69 to 9903.04.60-9903.04.70 per Federal Register 2026-19498 (published September 23, 2026); EU generics have paid only the MFN rate (typically 0%) since September 1, 2025; onshoring escalation cliff April 2, 2030 ▾
💰 IEEPA refund litigation US Court of International Trade (CIT) About 3,700 IEEPA refund suits are pending at the CIT, which has begun ordering CBP to refund IEEPA duties on plaintiffs' finally liquidated entries (Holland & Knight, July 2026). SCOTUS ruled IEEPA tariffs unlawful February 20, 2026 (6-3, Learning Resources, Inc. v. Trump). As of September 11, 2026: CBP accepted ~$134.7B in claims and sent ~$122B to Treasury; ~$1.3B held for missing ACH details. CAPE Phase 2 (launched June 29, 2026) expanded eligibility to reconciliation-flagged entries. DOJ appealed the scope of the CIT universal injunctions to the Federal Circuit on June 2, 2026. Next deadline Ongoing · DOJ's Federal Circuit appeal (filed June 2, 2026) pending; CAPE Phase 3 opened October 6, 2026 (court plaintiffs only; liquidated entries for which the CIT has ordered reliquidation); ~$134.7B in refunds accepted and ~$122B sent to Treasury as of September 11, 2026; Congress urged CBP September 9 to address administrative delays ▾