On June 2, USTR released findings on its Section 301 forced-labor investigations, proposing duties of 10% to 12.5% across 60 economies, including China, India, Japan, South Korea, Thailand, and Vietnam. The proposal is reported to exclude pharmaceuticals and goods already subject to Section 232. The measure is proposed, not final: comments are due July 6, a hearing is set for July 7, and no implementation date has been set. Section 122 expires July 24, creating a key decision point for the post-expiry tariff posture, not an effective date for the proposed duties.
If finalized, the measure would move this exposure into Section 301's statutory and review framework. It is not final, does not automatically replace Section 122, and has no confirmed effective date. The proposal nevertheless brings many sourcing locations used for China diversification into the same investigative scope.
The hearing-and-comment window is the action item. Requests to appear at the July 7 hearing are due June 22; written comments are due July 6. The Section 122 product exclusion list is expected to carry over, so the comment record will shape any exclusion framework applied to these duties. Companies with concentrated exposure in a targeted economy have a narrow, real opening to argue for preferential treatment before rates are fixed.
Yale Budget Lab's effective tariff rate holds at 11.0%, the highest since 1943 excluding the prior year. CBP's CAPE refund process for IEEPA Phase 1 entries remains active. Liquidation timing, not the litigation calendar, governs eligibility.
The February 20, 2026 Supreme Court ruling striking IEEPA tariff authority opened the refund path, but the procedural windows close fast: CAPE Phase 1 reaches liquidated entries only within 80 days, and older entries need a protest within 180 days. Three pieces of the picture, plus a path to action.
In Learning Resources v. Trump, the Supreme Court held that IEEPA does not authorize tariffs, invalidating roughly $166 billion in collected duties. A DOJ appeal at the Federal Circuit challenges whether the universal refund order reaches importers who did not sue, which is the determinant variable for non-plaintiffs.
CBP's Consolidated Administration and Processing of Entries system handles IEEPA refunds. Phase 1 covers unliquidated entries and those within 80 days of liquidation, with refunds estimated at 60 to 90 days. Entries past that window require a protest under Section 1514 within 180 days of liquidation.
Eligibility requires (1) entries dated during the IEEPA tariff period through February 23, 2026, (2) duty paid under IEEPA authority specifically (not Section 232, 301, 122, or AD/CVD), and (3) liquidation status: unliquidated, within 80 days of liquidation for CAPE Phase 1, or within the 180-day protest window.
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