Brazil 301 Tariffs Hit July 22; IEEPA Refund Path Opens; Enforcement Ramps Up
NEWSLETTER | Trade Insight AI
USTR Imposes 25% Section 301 Tariff on Most Brazilian Goods July 22
STR Trade Report • July 17, 2026
Effective 12:01 a.m. ET July 22, USTR will assess a new 25% Section 301 duty on nearly all goods of Brazil, with in-transit relief for cargo loaded before that time and entered by July 29. Hundreds of products are excluded to prevent supply disruptions and cover items not made domestically, including aluminum hydroxide, pig iron, certain pharmaceuticals, wood and seafood products, antiques, unflavored instant coffee, used clothing, and items already subject to Section 232 tariffs, while high-purity dissolving pulp and non-pharmaceutical chemical uses remain covered. The 25% duty applies in addition to any AD/CVD and may stack with a separate forced-labor Section 301 tariff proposed at 12.5 percent, so importers should review classifications and the annexes immediately.
Tariff Actions, Refunds & Strategy
U.S. Imposes 25% Section 301 Tariffs on Select Brazilian Imports
USTR Press Releases •July 15, 2026
The United States finalized a Section 301 action imposing a 25% tariff on certain Brazilian imports after a yearlong investigation into measures spanning digital trade and electronic payment services, preferential tariffs, anti-corruption enforcement, IP protection, ethanol market access, and illegal deforestation. The decision follows consultations with Brazil, two public hearings, and review of 360+ comments, with USTR concluding these policies are unreasonable and burden U.S. commerce. Importers with Brazil exposure should review the Federal Register notice to identify covered products and assess tariff, supply chain, and compliance impacts while monitoring potential further negotiations.
File CIT Suit Now to Access CAPE Phase 3 IEEPA Refunds
STR Trade Report •July 17, 2026
CBP plans to issue IEEPA tariff refunds for entries liquidated more than 80 days ago through CAPE Phase 3 by the end of July; to qualify, importers must file suit at the Court of International Trade, obtain an importer‑specific reliquidation order, and then submit a CAPE refund request. Since July 15 the CIT has begun issuing such orders in roughly 3,700 cases, and with CBP set to start Phase 3 with court plaintiffs, importers who file now— including those with protested entries—are best positioned to accelerate refunds despite a two‑year filing window and pending class actions that could later change the pathway.
U.S. Court of International Trade Sets Procedures for New IEEPA Tariff Cases
CIT News •July 13, 2026
The court, led by Chief Judge Mark A. Barnett, issued an administrative order standardizing how new cases involving tariffs under the International Emergency Economic Powers Act will be handled. The framework clarifies filing and case-management expectations, offering greater predictability for companies, counsel, and the government navigating IEEPA-related tariff disputes.
MFN Keeps Tariff Talks Simple and Trade Concessions Secure
WTO Latest News •July 15, 2026
The piece argues MFN is more than a fairness rule: it is the institutional linchpin that simplifies tariff bargaining—via uniform rates and principal-supplier talks—and safeguards the value of concessions by multilateralizing them. Citing early GATT evidence, including the 1950–51 Torquay Round where experienced members’ initial offers (80.8% of existing tariffs) closely matched final outcomes (80.6%), it warns that weakening MFN would revive complex, unstable discrimination—timely context for post-MC14 reform debates.
Tariffs Stall Auto Relocation; India Presses U.S.; Vietnam-EFTA Concluded
STR Trade Report •July 16, 2026
Governments are largely avoiding tit-for-tat responses to U.S. tariffs to preserve the WTO rules-based system, even as India hardens its demands in talks with Washington for a tariff edge over China and guarantees against new levies. Automakers are opting to absorb tariffs rather than invest billions to reshore production, signaling continued import flows and sustained tariff exposure. Separately, Vietnam and EFTA have concluded an FTA covering goods, services, IP, procurement, SPS/TBT, and sustainability, setting up new market access and rules-of-origin options once implemented.
Enforcement & Border Risk
DOJ launches trade enforcement unit; recoveries top $1B, penalties surge
STR Trade Report •July 17, 2026
The DOJ intensified trade enforcement by creating a Global Trade and Commerce Enforcement Section and, with DHS, releasing a Resource Guide to Trade Fraud Enforcement, as its revitalized Trade Fraud Task Force reported over $1 billion in recoveries in under a year. CBP has separately assessed $2.1 billion in penalties and debarred 35 parties this fiscal year, signaling a shift toward aggressive criminal prosecutions and False Claims Act actions. With liability extending across the supply chain and priorities on duty evasion, forced labor, and product safety, companies should tighten compliance and prepare for nationwide investigations.
CBP Reports $22.9B in Duties and Significant Forced-Labor, IP Seizures
CBP Media Releases •July 16, 2026
CBP’s June update underscores an aggressive trade enforcement posture: $330 billion in imports were processed and $22.9 billion in duties identified, while 372 shipments tied to potential forced labor ($38+ million) were stopped and nearly 2 million counterfeit goods valued over $1.4 billion were seized. The figures signal sustained scrutiny on forced-labor compliance and intellectual property protection, elevating risk for importers across high‑exposure sectors. Trade teams should expect continued rigorous reviews at the border and ensure supplier due diligence and tariff/valuation controls are audit‑ready.
Louisville CBP Seizes Counterfeit Audemars Piguet Watches Worth $28M MSRP
CBP Media Releases •July 17, 2026
On July 9, Louisville CBP intercepted a Hong Kong shipment bound for Illinois containing 200 counterfeit Audemars Piguet watches that would retail for over $28 million MSRP if genuine; CBP’s Centers of Excellence and Expertise confirmed the goods were inauthentic and seized them for bearing counterfeit, recorded trademarks. Coming two weeks after a separate Louisville seizure of 375 AP watches (MSRP >$54 million), the case signals intensified IPR enforcement in mail/express e-commerce channels and heightened compliance risk for small-parcel imports.
Trade Remedies & Investigations
AD/CVD Roundup: High China Foil Subsidies; Tire Orders Continued
STR Trade Report •July 17, 2026
Commerce and the ITC issued several AD/CVD updates: preliminary CVD review results for Chinese aluminum foil set net subsidy rates at 21.62% and 149.69% (2024 period), while preliminary AD reviews yielded a 35.79% margin for Chinese mobile access equipment (Apr 2024–Mar 2025) and a zero margin for Thai citric acid (Jul 2024–Jun 2025). The ITC also made preliminary affirmative injury findings in the AD probes on PTMEG from China, South Korea, Taiwan, and Vietnam, and AD/CVD orders on Chinese passenger and light truck tires were continued effective July 7. Importers should reassess potential cash deposit and assessment exposures and plan around sustained tire duties and possible PTMEG tariffs.
AD/CVD Roundup: New Monomers AD Order, Crepe Paper Continued, Rate Updates
STR Trade Report •July 16, 2026
Commerce and the ITC issued multiple AD/CVD actions, including a final affirmative injury finding that will trigger an antidumping order on multifunctional acrylate and methacrylate monomers and oligomers from South Korea, and a sunset decision keeping the China crepe paper AD order in place for another five years. Preliminary reviews set a 7.62% CVD rate on Indian common alloy aluminum sheet for calendar year 2024 and a 1.96% AD margin on Taiwanese stilbenic optical brightening agents for May 1, 2024 to April 30, 2025, while final results in the Oman steel nails case set a zero dumping margin for July 1, 2023 to June 30, 2024. Importers should verify current cash deposit rates and assess potential duty exposure or refunds as these determinations take effect.
ITC Launches Section 201 Probe of Increased Lamb Meat Imports
STR Trade Report •July 17, 2026
The U.S. International Trade Commission has opened a Section 201 safeguard investigation into whether rising imports of fresh, chilled, or frozen lamb meat are a substantial cause or threat of serious injury to domestic producers. The case covers specified HTSUS 0204 lamb meat subheadings and excludes live lambs/sheep and mutton. If the determination is affirmative, potential remedies include tariff hikes, quotas, tariff‑rate quotas, and trade adjustment assistance—changes that could reshape pricing, sourcing, and inventory planning for lamb importers and buyers.
South Africa Launches SACU Safeguard Probe on Cold-Rolled Steel Imports
WTO Latest News •July 13, 2026
South Africa notified the WTO on 14 July 2026 that it initiated, on 10 July, a safeguard investigation into certain cold-rolled iron and steel imports into the Southern African Customs Union. Interested parties must identify themselves and submit comments or hearing requests within 20 days of initiation, with confidentiality claims requiring detailed public summaries. If serious injury from increased imports is found, SACU could impose temporary import restrictions, impacting pricing and market access for regional steel buyers and exporters.
Programs, Agreements & Regulatory Updates
WTO DG Urges Dual-Track Progress; GC Extends AGOA/CBERA Waivers
WTO Latest News •July 13, 2026
At the 14–15 July General Council, DG Ngozi Okonjo‑Iweala pressed members to advance WTO reform and negotiations in tandem, noting momentum in post‑MC14 fisheries work (122 acceptances of the AFS and 34 new subsidy notifications) amid persistent divides on agriculture and the e‑commerce moratorium. Members approved LDC-focused steps—routing TRIPS implementation discussions to the TRIPS Council and launching EIF Phase III without budget impact—and granted U.S. waivers to maintain AGOA/CBERA duty‑free preferences through 31 December 2026. Reform efforts will proceed under newly appointed facilitators with a dispute‑settlement update due 24 July, while India and Pakistan questioned interim arrangements for the 67‑member E‑Commerce Agreement; the next General Council is slated for 5–6 October.
FDA Proposes Single Registration for Distributed Manufacturing; Foreign APIs Must Register
STR Trade Report •July 16, 2026
FDA proposed amending drug establishment registration and listing rules to accommodate distributed manufacturing and expand oversight of foreign producers; comments are due Sept. 11. Distributed manufacturing networks could register as a single establishment with streamlined updates, while advance notice would be required for unit relocations. The rule also clarifies that foreign facilities, including API makers whose products indirectly enter the U.S. supply, must register and list drugs—aligning with the PREVENT Pandemics Act—heightening upstream supply-chain visibility and compliance duties for importers and overseas suppliers.
CITA OKs CAFTA-DR Short Supply for Double Weave Polyester/Spandex Fabric
STR Trade Report •July 17, 2026
CITA approved a CAFTA-DR short supply request, adding certain double weave polyester/spandex fabrics (HTSUS 5407.52.2040 and 5407.72.0015) to Annex 3.25 effective July 14. Apparel made in CAFTA-DR countries using this fabric now qualifies for duty-free treatment in unrestricted quantities regardless of fabric origin, easing sourcing constraints and enabling immediate cost savings for regional producers and U.S. importers.
FTZ Board Approves Tesla Tracy Expansion, Webco Subzone; Puerto Rico, Texas Filings
STR Trade Report •July 16, 2026
The FTZ Board approved expanding Subzone 18G to include Tesla’s Tracy, California facility and established Subzone 164B for Webco Industries in Kellyville, Oklahoma. It also accepted applications for new subzones at Sonnell Realty IV LLC within FTZ 61 in Bayamón, Puerto Rico, and at the Kerrville Public Utility Board Public Facility Corporation within FTZ 155 in Garwood, Texas. These actions extend duty‑deferral and inverted‑tariff benefits to approved sites, with additional capacity pending review for firms seeking customs and cost efficiencies.
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