Tariff Watch: Stronger Customs Enforcement EO, Section 232 Expansion, Court Intervenes in IEEPA Case

In this week’s edition of Tariff Watch from J.M. Rodgers, we’re tracking several interesting developments, including the President ordering more aggressive customs enforcement and a federal court stepping into the IEEPA case to halt testimony from the CBP Commissioner about delays in issuing refunds.

Meanwhile, Section 232 has been expanded to cover a new class of products. Here’s what you need to know from the week of June 8, 2026.

What’s New

• CBP ordered to strengthen customs enforcement: Following a new executive order from the White House, Customs and Border Protection (CBP) is planning sweeping changes to its enforcement activities. The “Strengthening Customs Enforcement” EO, signed by President Donald Trump last week, orders CBP to take stronger measures to prevent unlawful imports, tighten eligibility requirements for Importers of Record (IORs), and intensify the agency’s duty collection efforts.
• Section 232 tariffs expand to include new derivative products: While last week’s news highlighted tariff reductions for agricultural equipment, the recent Section 232 proclamation, which officially took effect on Monday of this week, also imposed some new duties on specific industries. The list of derivative products subject to Section 232 tariffs now includes aluminum lithographic plates and steel racks.
• The Federal Circuit intervenes in the CIT’s IEEPA hearing: Following the Department of Justice’s expedited motion, the US Court of Appeals for the Federal Circuit intervened ahead of a hearing scheduled for this past Tuesday at the Court of International Trade (CIT). The stay temporarily relieved CBP Commissioner Rodney S. Scott of the obligation to testify before the CIT about delays in issuing IEEPA tariff refunds for older liquidated entries.

Who’s Impacted

This week’s developments have a wide reach across the entire supply chain, affecting a number of stakeholders:

• All Importers of Record: The “Strengthening Customs Enforcement” EO mandates that CBP take a closer look at who is importing goods into the United States. All IORs, particularly those relying on foreign entities or complex corporate structures, will likely face heightened scrutiny regarding their identity and bond sufficiency.
• Printing, warehousing, and logistics industries: Businesses that rely on imported aluminum lithographic plates (crucial for commercial printing) and steel racks (the backbone of modern warehousing and fulfillment centers) are the immediate targets of the Section 232 expansion that went into effect this week. The industries are facing sudden cost increases for essential operational equipment.
• Businesses awaiting older IEEPA refunds: Importers holding entries that were liquidated more than 90 days ago continue to be caught in the legal crossfire. The Federal Circuit’s intervention on Tuesday further delays the CIT’s push to force CBP to issue these universal refunds immediately.

What We’re Seeing

Rather than waiting for the dust to settle, proactive supply chain leaders are already adjusting their strategies in response to this week’s news:

• Businesses are preemptively auditing their IOR compliance: In the aftermath of the new customs enforcement EO, JMR is seeing companies work closely with their brokers and surety providers to verify their IOR setups. Many are proactively reviewing their continuous customs bonds to ensure they are adequately sized to prevent CBP from flagging their entries under the new enforcement mandate.
• Importers rushing to file Section 232 exclusion requests: With aluminum lithographic plates and steel racks now subject to hefty tariffs, impacted businesses are assessing the domestic availability of these goods. Where American supply falls short, companies are initiating the formal exclusion request process through the Department of Commerce to seek relief from the new tariffs.
• Importers are shifting their IEEPA legal strategies: Amid delayed CIT hearings and the DOJ’s aggressive appeals, some businesses are trying new approaches to secure their universal IEEPA refunds. Realizing that the contested CIT universal injunction may take significant time to wind its way through the courts, some importers owed substantial sums are even filing lawsuits to get their refunds faster.

What We’re Monitoring

JMR continues to keep a close watch on these ongoing issues:

• CBP’s Implementation of the Enforcement EO: We’re watching CBP’s official messaging channels to determine exactly how and when the agency will roll out the tightened IOR identification rules mandated by the administration’s recent executive order.
• The 60-country Section 301 proposal: Following last week’s announcement of proposed forced-labor tariffs on 60 countries, trade groups and global manufacturers are making heavy use of the public comment period. We’re tracking these submissions ahead of the July 6 deadline to gauge which industries are pushing back the hardest and where the USTR might grant exemptions.
• Activity on the CAPE refund portal: While litigation around older entries continues, CBP’s Consolidated Administration and Processing of Entries (CAPE) portal is still processing unliquidated and recently liquidated IEEPA entries. We continue to evaluate the portal’s processing speeds, as CBP previously committed to issuing refunds within 60 to 90 days of a declaration’s acceptance.

Sources

• New Executive Order on “Strengthening Customs Enforcement,” WilmerHale
• President Trump Further Adjusts Section 232 Tariffs, JD Supra
• Appeals Court Halts Customs Chief’s Testimony, The Hill
• Importers Move To Certify Class Action in IEEPA Tariff Refund Litigation, BakerHostetler