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: 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 …
CARMICHAEL COMPASS: ISSUE 25-044 – October 15, 2025
Reminder: Chinese Cargo Ship Fee Begins October 14 Fees on Chinese-built, -owned, or -operated vessels as well as foreign-built vehicle carriers entering U.S. ports began October 14. These fees, which will increase exponentially over the next three years, are the result of a determination by the USTR that the attempted dominance of China’s maritime, logistics, and shipbuilding sectors is actionable …
CARMICHAEL COMPASS: ISSUE 25-041 September 26, 2025
President Trump Plans New Tariffs on Imports of Furniture, Heavy Truck, and Pharmaceuticals President Trump posted an announcement on Truth Social that he would impose new tariffs on imports of furniture, heavy trucks, and pharmaceuticals on October 1. He will impose a 25% tariff on heavy trucks to protect the future of U.S. manufacturers. He will assess a 50% tariff …
CARMICHAEL COMPASS: ISSUE 25-040 September 17, 2025
Updated Implementation Guidance for U.S. Japan Agreement In a CSMS message released late on Monday, September 15, CBP has released updated guidance on the implementation of the U.S. Japan trade agreement. This update contains tariff numbers and effective dates for the various modifications of duties that accompany the agreement. Retroactive to 12:01 AM EDT on August 7, goods that are …
CARMICHAEL COMPASS: ISSUE 25-039 September 10, 2025
Supreme Court will Hear the Two Cases that the CAFC was Remanding Back to the CIT Last week the U.S. Court of Appeals for the Federal Circuit (CAFC) affirmed with CIT on the President’s unlimited authority under IEEPA to set reciprocal tariffs and the fentanyl tariffs on Canada, Mexico, and China. The CAFC set up to remand the cases back …
MEMO TO CLIENTS ISSUE 23-016 – AUGUST 28, 2023
Agricultural Marketing Services Announces Changes in Cotton Fees The Agricultural Marketing services (AMS) issued a Federal Register Noice (FRN) announcing the changes to cotton fees that will be collected for the Cotton Board through entries filed with Customs and Border Protection. The change is an increase in the value assigned to imported cotton. This is a proposed change that will …
