Simply Trade

[Cindy's Version] Begin Again: Refunds are coming, but so are 100% Tariffs


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Host: Cindy Allen

Published: April 3, 2026
Length: ~15 minutes
Presented by: Global Training Center

Summary

In this week’s episode of Simply Trade: Cindy’s Version, Cindy Allen breaks down a major shift in trade operations as CBP moves closer to launching the CAPE system for IEEPA duty refunds—while at the same time, new Section 232 actions signal that trade enforcement is far from slowing down.

CBP has indicated it is on track for an April 20 rollout of CAPE, with key components nearing completion. However, Phase 1 will only cover certain entries, leaving many importers navigating critical decisions around protests and timing.

At the same time, new developments in pharmaceutical tariffs and steel and aluminum revisions suggest that, despite recent legal challenges, trade enforcement is evolving—not retreating.

Inspired by Taylor Swift’s Begin Again, Cindy walks through why this moment feels less like closure—and more like the start of a new phase in global trade compliance.

This Week in Trade

• CBP signals April 20 target for CAPE rollout tied to IEEPA refunds

• Phase 1 expected to cover ~63% of entries, excluding many already liquidated cases
• Judge highlights importers’ right to file protests, raising strategic considerations
• Strait of Hormuz disruptions continue to create supply chain uncertainty
• No movement on key legislation including First Sale and Foreign Importer of Record rules

IEEPA Refunds & CAPE: Where Things Stand

CBP continues to make progress toward launching CAPE (Consolidated Administration and Processing of Entries):

• Claim portal (~85% complete)

• Mass processing of entries (~60% complete)
• Review and liquidation (~80% complete)
• Refund processing (~75% complete)

Phase 1 will:

• Focus on unliquidated entries and those within voluntary reliquidation windows
• Exclude fully liquidated entries, protests, drawback, and certain AD/CVD cases

⏱️ Timeline:

• Target launch: ~April 20
• Estimated processing: up to 45 days post-launch

Section 232: We’re “Beginning Again”

This week brought significant new developments under Section 232:

Pharmaceutical Tariffs

• 100% duty on name-brand pharmaceuticals

• Generics excluded
• Implementation expected within 180 days

Key complexity:

• Importers must now identify brand vs. generic at entry
• Multiple exemptions and reduced rates tied to reshoring and trade agreements

Steel & Aluminum Updates

• 50% duty remains for core steel/aluminum products

• 25% duty on derivative products (full value)
• New de minimis exemption for products with <15% steel/aluminum by weight

These updates simplify some calculations—but may increase duty exposure for many importers.

Key Takeaways

• CAPE is progressing—but refunds will be phased and complex

• Importers should evaluate protest strategies carefully
• Trade enforcement is not slowing—it’s resetting and expanding
• Section 232 is entering a new operational phase
• Compliance will require more detailed product-level data than ever before

Resources & Mentions

Global Training Center

Cindy Allen – LinkedIn
Global Training Center

Global Training Center on LinkedIn

YouTube
Spotify
Apple Podcasts
Trade Geeks Community

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