CARMICHAEL COMPASS: ISSUE 26-020 – May 27, 2026

Section 232 Tariff Reduction for Select Taiwanese Goods In a Federal Register notice set to be published on May 28, the Office of the United States Trade Representative has announced that it will be lowering the Section 232 tariffs on Taiwanese auto parts and some wood products, as well as eliminating tariffs on aerospace goods that were subject to Section …

CARMICHAEL COMPASS: ISSUE 26-019 – May 13, 2026

Update on the CIT Section 122 Tariff Case As expected, the US government filed an appeal of the Court of International Trade’s decision striking down the Section 122 tariffs imposed by President Trump in February. The US also sought a stay of the injunction against the collection of the tariffs which was applicable only to the importers that filed suit …

CARMICHAEL COMPASS: ISSUE 26-018 – May 8, 2026

Court of International Trade Strikes Down Section 122 Tariffs On May 7, the U.S. Court of International Trade ruled that the Section 122 tariffs as imposed by President Trump in February 2026 are unlawful. The 2-1 split decision ruled that the President failed to identify a balance-of-payment deficit within the scope of the meaning of Section 122. However, it should …

CARMICHAEL COMPASS: SPECIAL ISSUE 26-017 April 20, 2026

Identifying Potential CAPE-Eligible Entries: Current Options for Clients As we move towards the Phase 1 implementation for CAPE, clients have several options already at their disposal to help identify entries that may qualify for CAPE processing. While each method provides useful data, it is important to understand their limitations and the level of manual review required. To start, clients can …

CARMICHAEL COMPASS: ISSUE 26-015 – April 8, 2026

Section 232 Updates to Steel, Aluminum, and Copper Effective April 6, 2026 On April 2, President Trump signed a proclamation making sweeping changes to the Section 232 tariffs on Steel, Aluminum, Copper, and their derivatives. These changes aim to boost domestic manufacturing and are effective as of 12:01 AM EDT on April 6. The key changes made by this proclamation …

CARMICHAEL COMPASS: ISSUE 26-014 – April 2, 2026

CBP Files CAPE Update with Court of International Trade CBP has filed an updated status report with the Cour of International Trade (CIT) regarding progress on the Consolidated Administration and Process of Entries program or CAPE. According to the update, phase 1 will be limited to entries that are unliquidated or for which the 90-day voluntary reliquidation period has not …

CARMICHAEL COMPASS: ISSUE 26-013 – March 26, 2026

CBP Creates ACH Rejected Refunds Report A new ACE report, REV-613 ACH Rejected Refunds, has been created by Customs and Border Protection (CBP) to help importers track refunds that are rejected “solely due to failure to provide CBP with the necessary banking information to effectuate the electronic refund.” Importers can use this program to confirm if they have their ACE …

CARMICHAEL COMPASS: ISSUE 26-011 – March 16, 2026

IEEPA Refund Process CBP has reported to the Court of International Trade (CIT) its progress on its development of ACE functionality for the processing of IEEPA refunds ordered by the courts. This new program will be called the Consolidated Administration and Processing of Entries (CAPE). CAPE will have a portal that will be the single-entry point for importers and brokers …

CARMICHAEL COMPASS: SPECIAL MEMO TO CLIENTS ISSUE 26-010 – March 9, 2026

Follow Up on IEEPA Case from CIT’s Closed Meetings In a closed meeting Friday morning, Brandon Lord, the Executive Director of CBP’s Trade Programs Directorate, explained the difficulties of immediately processing the liquidation and reliquidation in ACE of all entries filed with CBP containing IEEPA tariffs with the intent to refund the IEEPA duties.  He presented a brief explaining how …

CARMICHAEL COMPASS: SPECIAL ISSUE 26-008 – February 20, 2026

Supreme Court Rules 6-3 Against IEEPA Tariffs, Case to Return to CIT for Refund Judgement In a 6-3 vote, the U.S. Supreme Court has issued a historic decision this morning against the IEEPA tariffs imposed by President Trump. Chief Justice Roberts wrote the majority opinion and has stated “The Government reads IEEPA to give the President power to unilaterally impose …

CARMICHAEL COMPASS: ISSUE 26-007 – February 13, 2026

New Bipartisan Bill Jeopardizes First Sale A new bipartisan bill was introduced in the House on Wednesday February 11 by Senators Cassidy (R-LA) and Whitehouse (D-RI). This bill, known as The Last Sale Valuation Act would: At this time, language for this bill has not been posted on Congress.gov. However, it can be found on Senator Whitehouse’s website. Argentinian Trade …

CARMICHAEL COMPASS: ISSUE 26-006 – February 4, 2026

Short-lived Partial Government Shutdown Ended, AGOA and Haiti HELP Restored The partial government shutdown that took effect over the weekend has ended. On February 3 the House voted to pass the consolidated spending bills and extended funding for DHS through February 13. This gives Congress approximately ten days to find a solution to the calls for reform to Immigration and …

CARMICHAEL COMPASS: SPECIAL ISSUE 26-005 – February 1, 2026

Lapse in Appropriations Leads to Hopefully Short-lived Partial Government Shutdown On Friday, the Senate voted to separate a DHS funding bill from the remaining five bills funding other agencies for the rest of the fiscal year. The splitting of the DHS bill stems from increased pressure to place restrictions on Immigration and Customs Enforcement (ICE) operations. It’s important to note …

CARMICHAEL COMPASS: ISSUE 26-004 – January 29, 2026

REMINDER: CBP Electronic Refunds Will be Effective on February 6 Customs and Border Protection’s (CBP) program eliminating refund checks and implementing electronic refunds through the ACE portal will start next Friday, February 6.  All duties and fees refunds will only be issued through an ACE Portal account. CBP encourages all importers to have their own ACE Portal account. Importers with …

CARMICHAEL COMPASS: ISSUE 26-003 – January 22, 2026

Section 232 Duties Imposed on Imports of Certain Semiconductors A presidential proclamation issued January 14, has imposed 25% tariffs upon imports of certain semiconductors and their derivative products beginning January 15. A fact sheet was also released. In the proclamation, a 25% duty is implemented on imports of semiconductors classifiable under HTS headings 8471.50, 8471.80, 8473.30 that meet the following technical parameters: A total …

CARMICHAEL COMPASS: ISSUE 26-002 – January 9, 2026

Electronic Only Refunds Start February 6 An interim final rule published in the Federal Register on January 2 has provided guidance on CBP’s transition from offering refunds by check to electronic refunds. The interim final rule will take effect on February 6, 2026 and any comments regarding this interim final ruling are due by March 3, 2026. This rule applies …

CARMICHAEL COMPASS: ISSUE 25-054 – December 19, 2025

Tariff Cuts for Switzerland and Liechtenstein Retroactive to November 14 In a Federal Register notice set to take effect tomorrow, December 18, the U.S. Trade Representative and the Department of Commerce have announced that the reciprocal tariff cuts promised in the recent trade deal with Switzerland and Liechtenstein will be effective retroactively beginning November 14. Annex I to this notice …

CARMICHAEL COMPASS: SPECIAL ISSUE 25-053 – December 11, 2025

Major ACE Portal Changes for Importers The President of the Unites States has set the goal of eliminating the use of checks in its transactions. Customs and Border (CBP) has developed programming towards this goal. The first part is that every importer should get its own ACE (Automated Commercial Environment) Portal account. CBP will be using the ACE Portal accounts …

CARMICHAEL COMPASS: ISSUE 25-052 – December 9, 2025

Trade Agreement Between United States and South Korea Begins Implementation On November 13 the U.S. and South Korea released a joint fact sheet regarding the details of the trade agreement between the two countries. This fact sheet details the steps both countries agreed to undertake. On December 3, the United States Trade Representative followed through on the promises made in the fact sheet, releasing …

CARMICHAEL COMPASS: ISSUE 25-050 – November 25, 2025

Busy Weekend Sees Multiple Trade Agreement Announcements Last weekend was a busy weekend for Trade. The White House, in conjunction with various trading partners, made multiple announcements regarding trade agreements that have been reached. The countries with which trade agreements were reached include Argentina, Ecuador, El Salvador, Guatemala, Switzerland and Liechtenstein, and South Korea. All these agreements are in the …