TradeLane

On July 23, 2026, the White House issued a Presidential Memorandum directing the United States Trade Representative (USTR) to impose new Section 301 tariffs on imports from 60 economies that were investigated for failing to impose or effectively enforce prohibitions on the importation of goods produced with forced labor. The new tariffs follow the expiration of the prior 10% Section 122 tariffs on July 23^rd, adding a new Section 301-based duty framework for covered imports from the investigated economies.

Background

The United States-Mexico-Canada Agreement (USMCA), which replaced NAFTA in July 2020, is a trilateral free trade agreement between the United States, Mexico, and Canada. The Agreement includes a six-year review mechanism to determine whether it should be extended for another 16-year term. On July 1, 2026, the three governments met to conduct the review.

This week, we’ve received the same question from many clients: “I heard CUSMA wasn’t renewed. What does this mean for my business?”

The good news is that CUSMA has not expired, nor has it been terminated.

Re-Introduction to ‘CAPE’—What is it and what does it mean?

The Consolidated Administration and Processing of Entries system (CAPE) was established within the Automated Commercial Environment (ACE) by U.S. Customs and Border Protection (CBP) to process refund requests for duties imposed under the International Emergency Economic Powers Act (IEEPA). These tariffs were deemed unlawful by the U.S. Supreme Court in February of 2026, meaning that eligible parties are able to apply for reimbursement.

In international trade, outcomes are shaped not only by the movement of goods, but also by the data behind them. This dynamic is evident in President Trump’s recent Executive Order (E.O.) on Strengthening Customs Enforcement which points to a systemic shift in the U.S. import compliance environment. While much of the initial commentary has centered on the stricter treatment of foreign importers of record (IORs), including restrictions on informal entries, tighter conditions for formal entries, and limits on the use of continuous bonds, that is only part of this broader structural reset.