Am I still paying the Section 301 forced-labor tariff while it’s being challenged in court?

Yes. The U.S. Court of International Trade heard oral arguments on September 30, 2026 on whether USTR’s forced-labor Section 301 tariffs — a two-tier regime imposing 10% or 12.5% duties on goods from 60 trading partners covering roughly 99.4% of U.S. imports — exceeded the agency’s statutory authority, but the panel has not ruled and granted no injunction. The duties, in effect since July 24, 2026, continue to apply. Challengers argue USTR skipped the country-specific findings Congress requires and used forced labor as a pretext to replace the broader IEEPA tariff authority the Supreme Court struck down in February 2026; the government says its investigations were genuine. Until a ruling issues, keep paying the applicable rate and budget for the possibility the duties stand.

My country is in the 10% forced-labor tariff tier, not the 12.5% tier — does that matter for my imports?

It can meaningfully lower your effective rate, but check the fine print. USTR’s July 2026 action split 60 trading partners into two tiers based on whether they have, or have committed to implement, forced-labor import prohibitions: 19 countries — including Mexico, Canada, India, Indonesia, and the United Kingdom — received the 10% rate, while 41 others, including China and Vietnam, face 12.5%. Several major partners (the European Union, Taiwan, Japan, South Korea, Switzerland) get a modified rate calculated net of each product’s existing most-favored-nation duty rather than a flat add-on. Raw materials essential to U.S. manufacturing, goods unavailable domestically in sufficient quantity, USMCA-qualifying imports, and certain agricultural goods and textile tariff-rate-quota items carry exemptions — confirm your specific HTS lines against the exemption list rather than assuming tier placement alone determines your cost.

CBP’s CAPE system opens Phase 3 on October 6 — how do I actually get my IEEPA refund?

Filing is required; nothing refunds automatically. CAPE (Consolidated Administration and Processing of Entries) Phase 3, launching October 6, 2026, addresses refunds on entries that have already completed final liquidation — a population CBP estimates at roughly 330,000 importers and 53 million entries representing about $166 billion in duties paid, following the Supreme Court’s February 2026 ruling against the administration’s IEEPA tariffs. To qualify, your entry must have completed final liquidation, you must be a plaintiff in a pending U.S. Court of International Trade case seeking IEEPA refunds, the entry must fall within the scope of a court reliquidation order, and your importer-of-record number must have been submitted to CBP before July 30, 2026. Importers who meet those conditions must actively file a CAPE Declaration and pass CBP’s file- and entry-level validation before any money moves to Treasury.

CBP just issued a new forced-labor import ban on palm oil — could this reach my supply chain even if I don’t buy directly from Indonesia?

Yes, if any supplier in your chain sources from the named producers. On September 29, 2026, CBP issued Withhold Release Orders under 19 U.S.C. § 1307 — the statute barring merchandise made with forced labor — against Mitra Aneka Rezeki and Hardaya Inti Plantation, two Indonesian palm oil plantations, based on evidence including payroll records, harvest-quota data, and NGO and academic reporting documenting debt bondage, wage withholding, and abusive conditions. CBP will detain covered shipments of palm oil and its derivative products — an ingredient category that reaches well beyond food into cosmetics, cleaning products, and industrial applications — at every U.S. port of entry, effective immediately. This is CBP’s 60th active forced-labor Withhold Release Order. Ask your suppliers and customs broker now whether any palm-oil-derived input in your products traces to either named plantation; detained shipments can only be released by export, destruction, or proof the goods weren’t produced with forced labor.

Mexico is in the 10% tier of the forced-labor Section 301 tariffs — do I pay that on top of my USMCA duty treatment?

For USMCA-qualifying goods, no — USMCA (United States-Mexico-Canada Agreement)-qualifying imports are specifically exempted from the Section 301 forced-labor tariff regime, so goods that meet USMCA rules-of-origin and are properly certified continue to enter duty-free under USMCA rather than paying Mexico’s 10% forced-labor rate. The exposure is for non-USMCA-qualifying Mexican-origin goods, which do fall into the 10% tier. This makes accurate, defensible rules-of-origin documentation more valuable than ever — a shipment that can’t substantiate USMCA qualification now faces the forced-labor tariff as a fallback, on top of whatever Section 232 steel, aluminum, or auto duties already apply.

What’s the status of the fourth round of USMCA review talks, and when should I expect clarity on Mexico’s steel, aluminum, and auto tariffs?

Still unscheduled. The fourth formal round, originally set for late September 2026, was postponed over scheduling conflicts tied to the Trump-Xi summit and the G20 trade ministerial, and as of this writing no new date has been announced. USTR Jamieson Greer and Mexican Economy Secretary Marcelo Ebrard did meet informally on the sidelines of the G20 trade ministerial in Milwaukee (September 29-October 1), with Ebrard describing the conversations as aimed at “bringing positions closer together,” but no agreement on the 50% Section 232 steel and aluminum tariff or the 25% auto tariff was announced. Treat the current rates as the operative baseline for planning until a formal round produces a signed outcome, and build flexibility into Q4 and 2027 sourcing and pricing models rather than assuming near-term relief.

The new Milwaukee Framework targets steel overcapacity — is Mexico part of it, and does that affect the existing Section 301 investigation into Mexico?

No — Mexico is not named among the Milwaukee Framework’s participants, and the framework is a separate, narrower initiative from the Section 301 investigation that directly names Mexico. The Milwaukee Framework, unveiled at the G20 trade ministerial, is built on the 28-member Global Forum on Steel Excess Capacity (including the EU, Australia, Japan, and South Korea) and focuses on data-sharing and coordinated trade measures against market-distorting subsidies — notably, China was excluded and did not participate. Separately, USTR’s Section 301 investigation into structural excess manufacturing capacity across 16 economies, which does include Mexico and has been pending since March 2026, remains open with no determination announced. The Milwaukee Framework gives a sense of the direction U.S. policy is heading on overcapacity generally, but it doesn’t resolve or substitute for the Mexico-specific Section 301 inquiry, which maquiladora-adjacent steel and aluminum producers should continue to monitor independently.

Does the U.S.-China truce extension to January 2027 change anything for goods my maquiladora sources from China for further processing?

Not materially, and the extension itself is a sign of how unresolved the underlying issues remain. The broader U.S.-China tariff and rare-earth truce — reached in October 2025 and due to expire November 10, 2026 — has been extended to January 10, 2027, preserving current tariff rates and keeping the tightest Chinese rare-earth export restrictions suspended through that date. But the extension explicitly punted deeper negotiation on tariffs, Chinese purchases of U.S. goods, rare-earth supplies, and technology restrictions to future talks, and some Chinese licensing requirements on medium and heavy rare-earth materials were never suspended in the first place. For maquiladora operations relying on Chinese-sourced components, this buys two more months of rate stability, not a resolution — keep documentation of substantial transformation and USMCA-qualifying origin current, since CBP’s transshipment-focused enforcement push has not slowed.