November ’26 at-a-glance … taxes, tariffs & trade

Trump eases tariffs on Canadian refrigeration equipment

President Trump modified tariffs on certain Canadian imports under Section 338 of the Tariff Act of 1930, removing some machinery and refrigeration equipment from the list of products subject to additional duties. The changes, effective Oct. 30, also add certain valves and other products to the tariff list. The tariffs apply regardless of whether products qualify under the United States-Mexico-Canada Agreement (USMCA) and are separate from existing Section 232 tariffs. NAFEM members importing equipment or components from Canada should review the revised product classifications to determine how the changes affect their operations.

Section 301 exclusions on China imports extended

USTR extended the remaining exclusions for the China Section 301 tariffs through Jan. 9, 2027. The exclusions were scheduled to expire Nov. 9. Every product subject to the Section 301 actions is identified by an 8-digit or 10-digit HTS Subheading. The USTR website provides a search engine for more information.

Seeking member perspectives on USMCA review

The U.S. Trade Representative (USTR) is seeking public input ahead of the 2027 joint review of the USMCA. USTR is accepting public comments and requests to testify through Jan. 12, 2027. A majority of NAFEM members responding to the 2026 business challenges survey identified trade with Canada and Mexico under the agreement as important to their businesses. Members interested in helping shape potential comments should email advocacy@nafem.org by Nov. 30.

Court ruling could expand IEEPA refund eligibility; refund status update

The U.S. Court of International Trade certified a class of importers seeking IEEPA tariff refunds Oct. 8, potentially expanding eligibility to businesses that have not filed individual lawsuits. The ruling does not immediately authorize additional refunds but U.S. Customs and Border Protection (CBP) continues to notify additional qualifying importers of their eligibility to file Phase 3 claims.

As of Oct. 2, CBP reported sending approximately $126 billion in refunds and interest to the Department of the Treasury for disbursement, although not all funds have reached importers. Missing banking information continues to delay some payments.

NAFEM members should preserve import records, verify electronic payment information, and consult trade counsel about potential refund claims as litigation continues. Filing guidance is available on the CBP IEEPA Duty Refunds page.

Russia tariffs delayed under new sanctions law

President Trump issued an executive order Oct. 16 implementing the Lindsey O. Graham Sanctioning Russia and Iran Act but waived its new tariffs and several sanctions provisions, citing U.S. national interests. The order establishes tariffs of 500% on Russian imports and 100% on imports from certain countries that purchase Russian energy or facilitate sanctions evasion, but the waivers prevent these duties from taking effect. The administration will monitor Russian energy purchases and sanctions evasion to determine whether further action is warranted.

CBP considers tougher import documentation requirements

CBP is seeking public input on potential new import documentation and reporting requirements aimed at improving supply chain transparency and strengthening customs enforcement. An advance notice of proposed rulemaking explores expanded foreign export documentation, enhanced identification of manufacturers and shippers, and new supply chain tracing technologies. Although CBP has not yet proposed specific regulations, the changes could increase compliance obligations and costs for NAFEM members importing equipment or components into the U.S. Comments are due Dec. 1.

Investigation into Vietnam IP protection lengthened

USTR extended by three months its Section 301 investigation into Vietnam’s inadequate intellectual property protection and enforcement. The investigation was scheduled for a determination by Nov. 29. The investigation will now conclude by Feb. 28, 2027.

Fees on China-built vessels delayed

USTR further delayed the implementation of Section 301 fees on China-built vessels through Jan. 9, 2027. On Oct. 30, NAFEM and more than 200 trade and business organizations sent the USTR a letter welcoming the previous two-month extension and encouraged the USTR to extend or permanently suspend the fees, which would increase shipping costs, disrupt supply chains and undermine U.S. manufacturers’ competitiveness.