Let’s Talk Tariffs with Jamie Rodgers: CAPE Phase 3 Arrives, FY27 Quotas Open & Canadian Import Bans Take Hold

Your weekly coffee chat on tariffs & trade.

October is off to a busy start.

After months of court filings, revised timelines and plenty of questions from importers, we’ve finally reached the scheduled launch of CAPE Phase 3.

We’ve been following this process closely at J.M. Rodgers, so it’s encouraging to see things moving forward. I’m particularly interested in how the rollout progresses and what it means for importers who have been waiting to recover their IEEPA duties.

Meanwhile, the new fiscal year’s tariff-rate quotas have opened, Canadian import bans are now in effect, and we’ve got more regulatory changes coming later this month.

What Caught My Eye

Naturally, CAPE Phase 3 is getting a lot of attention.

The October 6 deployment was scheduled to expand the refund process to certain finally liquidated entries covered by court-ordered reliquidation. Participation remains limited to qualifying importers involved in litigation before the Court of International Trade.

That’s an important distinction, and one I hope becomes clearer for the broader importing community as the litigation progresses.

There are businesses with significant amounts of money tied up in these duties. For them, the difference between being eligible for a refund today and potentially becoming eligible sometime down the road is substantial.

We’ve spent decades helping companies recover duties at J.M. Rodgers, and I can tell you that preparation makes an enormous difference.

Importers should understand which entries may qualify, what duties were paid, whether those entries have liquidated and what documentation is available to support a potential refund.

I wouldn’t wait until every legal question is resolved to start understanding those numbers.

The more organized you are today, the better positioned you’ll be when an opportunity becomes available.

Here’s My Take

While CAPE is understandably dominating the conversation, the opening of fiscal year 2027 tariff-rate quotas deserves some attention of its own.

October 1 marked the beginning of new quota periods for several commodities, including sugar, certain food products and apparel.

This is familiar territory for anyone who regularly imports quota-controlled merchandise, but I think it’s worth emphasizing how much the details matter.

Some programs have country-specific allocations. Others operate on a first-come, first-served basis, and certain openings can result in proration when submissions exceed the available quantity.

The financial difference between getting merchandise entered within a quota and missing that opportunity can be significant.

I’ve always found quota administration to be a good example of why customs expertise matters well before a shipment reaches the border.

You need to understand the program, know the opening procedures and coordinate the timing of your entries.

And even with everything properly prepared, an oversubscribed quota can still produce an outcome you weren’t expecting.

After more than 75 years in this business, J.M. Rodgers has seen just about every variation of customs complexity you can imagine. Quotas certainly aren’t new, but they remain an area where good planning can make a meaningful difference.

If It Were My Business…

I’d also be taking a fresh look at our Canadian supply chain.

The September 29 import bans are now in effect for certain Canadian-origin alcohol, dairy and motor vehicle products.

Think about how much has changed in just a few months.

Earlier this summer, many businesses were focused on calculating additional duties and determining whether their existing sourcing arrangements still made financial sense.

Now, for certain products, importing them into the United States is no longer an option.

That’s a significant adjustment for companies that have spent years building relationships with Canadian suppliers.

And I don’t think those relationships are necessarily easy to replace.

If I were importing affected products, I’d want to know exactly what inventory we have, where it’s located and whether any merchandise imported before September 29 may still qualify for entry under the previous 50% duty treatment.

I’d also want purchasing, logistics and customs working closely together on any alternative sourcing plans.

One thing I’ve seen throughout my career is that companies can get into trouble when a sourcing decision is made without fully understanding the customs implications.

A new supplier may look attractive on paper. Then you start factoring in origin, classification, duties, transportation costs and lead times, and the numbers can look quite different.

I’d rather have those conversations before committing to a change.

One for the Road

We’ve still got plenty to watch as October continues.

CBP has additional international mail requirements approaching on October 22, including electronic certification requirements for certain products regulated by the Consumer Product Safety Commission.

We’re also watching whether the administration takes action under the recently enacted secondary tariff authority related to Russian energy purchases.

And, of course, I’ll be following CAPE Phase 3 closely as we learn more about the rollout and what happens next for importers who remain outside the current process.

Looking at everything happening right now, I think it’s important for businesses to spend as much time understanding their own operations as they do following the latest trade announcements.

You can read every tariff update that comes out of Washington, but ultimately, you need to know how those changes affect your products, your entries and your bottom line.

That’s where the real work happens.

We’ve been helping businesses navigate these issues for more than 75 years, and while the rules have certainly become more complicated, the value of knowing your business and staying prepared hasn’t changed.

See you next week.

Jamie Rodgers
CEO, J.M. Rodgers Co.