Tariff Watch: Section 301 Expands to 60 Nations, IEEPA Appeals, and Section 232 Adjustments

Welcome to Tariff Watch, the weekly series from J.M. Rodgers all about the latest tariff news and announcements impacting US businesses. 

The first week of June 2026 saw the Trump administration make some aggressive moves, both in court and in targeting forced labor around the globe. Here’s the latest this week.

What’s New

• The Trump administration appealed the CIT’s IEEPA tariff refund order: On June 2, the Department of Justice (DOJ) formally appealed the US Court of International Trade’s (CIT) mandate that compelled Customs and Border Protection (CBP) to issue universal IEEPA tariff refunds, including to importers whose entries were liquidated past 90 days. The DOJ argues that the CIT lacks constitutional authority to issue a nationwide injunction affecting non-litigants.
• The USTR proposed Section 301 tariffs on 60 countries for forced labor violations. The United States Trade Representative (USTR) proposed on June 2 additional duties ranging from 10% to 12.5% on imports from 60 nations for failing to enforce prohibitions on forced labor. The proposed framework includes carve-outs for goods that qualify for duty-free imports under the USMCA and CAFTA-DR.
• The President adjusted Section 232 tariffs on steel, aluminum, and copper imports: In a June 1 proclamation, effective June 8, the Trump administration expanded the subset of derivative products eligible for a reduced 15% duty rate. to include agricultural equipment, such as combines and certain HVAC systems. The proclamation lowered the required US-origin metal threshold to qualify for preferential duty rates from 95% to 85%.
• The USTR proposed 25% Section 301 tariffs on Brazil: Following a separate Section 301 investigation, the USTR issued a determination on June 1 proposing a sweeping 25% tariff on specific imports from Brazil in response to the country’s contested acts, policies, and trade practices.

Who’s Impacted

This week’s developments affect a broad array of industries, including:

• Global sourcing operators: The USTR’s proposed 60-country Section 301 forced labor tariffs cast a massive net. Importers sourcing from major trading partners — including the EU, Canada, Mexico, the UK, and China — face potential 10% or 12.5% rate hikes unless specific product or program exclusions apply.
• Importers owed Category 3 IEEPA refunds: Importers who paid now-invalidated IEEPA tariffs but did not file a specific suit for entries liquidated more than 90 days ago are directly impacted by the DOJ’s appeal. This legal maneuver threatens to delay, or entirely block, billions of dollars in expected refunds.
• Agricultural and heavy machinery importers: Companies importing agricultural equipment, mobile industrial equipment, and qualifying HVAC systems stand to benefit from the expansion of the reduced 15% Section 232 tariff tier.

What We’re Seeing

The tradewinds are always shifting, as are the strategies importers take in response. Here’s how US businesses are reacting to this week’s news:

• Submitting Section 301 comments: The USTR is proposing tariffs on 60 countries, and businesses are using the public comment period (which runs through July 5) to make their voices heard. This includes everything from written comments to requests for product exclusions.
• Reviewing Section 232 bills of materials: Companies are checking their BOMs to see whether some imported equipment qualifies for the reduced 15% tariff rate. Some are also looking into whether the new rule, which lowers the domestic metal content threshold to 85%, changes their eligibility for preferential rates.
• Auditing USMCA/CAFTA-DR compliance: The USTR’s forced labor proposal includes exemptions for qualifying imports under the USMCA and CAFTA-DR. Since CBP will likely apply extra scrutiny to exemption claims, businesses are auditing their certificates of origin and other documentation to ensure compliance.

What We’re Monitoring

Here are the new events and continuing stories we’re paying close attention to this week:

• The June 9 CIT hearing: We’re closely monitoring whether the Federal Circuit will grant the DOJ’s motion to expedite a ruling, which seeks to prevent the CBP Commissioner from having to testify in person before the CIT on June 9 regarding the implementation of the tariff refund process.
• The Brazil Section 301 comment period: We await publication of the specific product lists that will be subject to the proposed 25% tariffs on Brazilian imports, which will heavily impact the agricultural and raw materials sectors.
• CAPE portal processing: We’ll be keeping an eye on CBP’s CAPE portal to ensure it continues processing IEEPA refunds in Category 1 (unliquidated) and Category 2 (litigated). Even with the DOJ’s latest filings, the Trump admin acknowledges it remains obligated to process these refunds, even as litigation over older entries continues.
• The fate of IEEPA refunds: What looked like a win for all US importers late last month has hit a massive roadblock. Last week, the CIT ordered CBP to show cause for delaying refunds on older entries; this week, the DOJ effectively threw down the gauntlet at the appellate level to block those universal payouts. The fight over IEEPA duties is far from over, and importers are readjusting their forecasts as appropriate.

Sources

• Trump Administration Appeals CIT’s IEEPA Tariff Refund Order, SmarTrade
• USTR Makes Findings and Proposes Action in 60 Section 301 Investigations, USTR.gov
• Us Issues Proclamation Further Adjusting Section 232 Tariff Regimes, EY Tax News
• USTR in Brazil Section 301 Investigation Determination Proposes 25% Tariffs, SmarTrade