Trade & Regulatory Updates

Trade & Tariff Update #22 - Development of an IEEPA Refund Process Continues and More

Written by APPA Team | Mar 17, 2026 7:01:25 PM

Development of an IEEPA Refund Process Continues 

On March 11, the United States Trade Representative (USTR) announced new Section 301 investigations into the trade practices of China, the European Union, Singapore, Switzerland, Norway, Indonesia, Malaysia, Cambodia, Thailand, Korea, Vietnam, Taiwan, Bangladesh, Mexico, Japan, and India.  

On March 17, a docket for comments regarding the investigations will open.  Interested persons should submit written comments, requests to appear at the hearing, along with a summary of the testimony, by April 15, 2026 to be considered. USTR will hold a hearing in connection with these investigations starting on May 5.   

For more information, please see: USTR Initiates Section 301 Investigations Relating to Structural Excess Capacity and Production in Manufacturing Sectors | United States Trade Representative  

The EU reacted swiftly, indicating their expectation that any new tariffs must honor the substance  of the recently negotiated deal between it and the United States.   

One day after announcing the expansive 301 investigations listed above, the USTR reported a second set of 301 investigations into forced labor practices in China, Brazil, Vietnam and 57 other countries.  As required upon initiation of an investigation, the United States Trade Representative has requested consultations with the governments of the economies whose acts, policies, or practices are under investigation.  On April 28 the USTR will hold hearings in connection with these investigations. 

To be considered, interested persons should submit written comments, requests to appear at the hearing, along with a summary of the testimony, by April 15, 2026.  

 A pre-publication version of the Federal Register Notice is available here

A docket for comments regarding the investigation will be available here

A docket for requests to appear at the public hearing to be held in connection with this investigation will be available  here

More details can be found here: USTR Initiates 60 Section 301 Investigations Relating to Failures to Take Action on Forced Labor | United States Trade Representative 

These actions hopefully are intended to create leverage to hold countries – particularly China -- to the terms of the trade deals that were negotiated while IEEPA tariffs were in force.  Discussions began yesterday between Treasury Secretary Bessent and Chinese trade officials to pave the way for a summit between President Trump and Chinese President Xi, where it is hoped that further improvements to the United States/China trade deal can be negotiated.  While on Sunday President Trump suggested that the meeting between him and Chinese leader Xi Jinping could be delayed due to the Administration’s pressure on China to help reopen the Strait of Hormuz, on Monday Secretary Bessent said that summit instead could be delayed for “logistics” if the President decides to stay in Washington to coordinate the war actions in Iran.   

New Legislation Introduced to Refund Businesses for Section 122 Tariffs

Last week Senators Charles Schumer (D-NY), Kirsten Gillebrand (D-NY) and Ranking Member Edward J. Markey (D0 MA), with others, introduced The Small Business Liberation Act 2.0.  The bill would exempt small businesses from Section 122 duties and provide refunds for any duties already paid.  While this bill faces challenges given its narrow focus and partisan tensions, it reflects continued Congressional scrutiny of tariffs. 

 


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