TRADE POLICY ANALYSIS
Long-form policy memos for importers, customs brokers and supply-chain teams who need to act this week — not next quarter.
2026-06-03 · By Marcus · 6 min read
Ten items as of June 3: USTR forced-labor §301 publishes concrete proposal — 60 economies, up to 12.5% (comments July 6, hearings July 7); 54 'failed to enforce' vs 6 'have but failed to enforce' tier split; Brazil §301 separately initiated June 1; §122 CAFC merits opinion most likely late 2026 (correcting May 29 deep-dive); CAPE — no paper checks since Feb 6, IOR without registered ACH = no refund; China State Council Order No. 834 (March 31) confirmed as the supply-chain security regulation; rare earths samarium/gadolinium/lutetium added Jan 1; §232 pharma 58 days; full July sequence locks in; Busan 160 days.
Read analysis →2026-05-31 · By Marcus · 6 min read
Ten items as of May 31: US-Mexico round 1 closed May 29 with USTR joint readout — auto ROO, §232 steel/aluminum, economic security, and a new scope add (medical devices/pharma/cosmetics regulatory compatibility); Deputy USTR Jeffrey Gerrish led (not Greer); round 2 June 16-17 adds agriculture; round 3 week of July 20 slotted 4 days before §301 July 24 action; Canada track lagging — trilateral becomes de facto bilateral; §122 — CIT May 20 denied government stay but CAFC administrative stay holds; CAPE — ~1,880 refunds stuck on missing ACE ACH registration; §232 pharma 61 days; §301 54 days; CBAM Q2 36 days; Busan 163 days.
Read analysis →2026-05-29 · By Marcus · 7 min read
CBAM's Q2 2026 certificate price publishes July 6 — 38 days out. Q1 set €75.36/tCO₂; the 2026 adjustment factor is 2.5%, so headline cash is small. But three numbers will matter on July 6: the new price (EU ETS futures currently €82-88), whether JRC default emission factors get refreshed, and whether EU buyers begin embedding 'verified emissions data' in RFQs. Walks through a worked example (Chinese BOF mill, 50K tonnes/year HRC) — €25M cumulative 2026-2034 CBAM cash impact — and lays out a week-by-week six-week prep checklist driven from the DutyTrade CBAM Cost Estimator.
Read analysis →2026-05-29 · By Marcus · 9 min read
After yesterday's confirmation of the §122 CIT strikedown, the next gate is the CAFC ruling — likely landing inside the window before §301's July 24 action target. CFO H2 2026 cash-flow models must split into Path A (CAFC reverses, §122 holds to natural retirement) and Path B (CAFC affirms, §122 invalidated early). Aggregate Chinese flat-rolled steel rate sits at 115% today; the two paths diverge by 15 pp for a six-week window June through mid-July. The piece walks through the modeling — and wires DutyTrade's tariff-stack calculator and route lookup into the decision flow.
Read analysis →2026-05-28 · By Marcus · 6 min read
Ten items as of May 28: §122 strikedown by CIT on May 7 is now confirmed by 10+ top firms (Proclamation 11012 invalidated, 2-1 split); CAFC May 12 administrative stay keeps §122 collected from everyone except 3 plaintiffs pending appeal; §122's two possible endings (CAFC reverses vs affirms) both resolve before §301 July 24; US-Mexico actual first round runs May 28-29 today/tomorrow with Deputy USTR Goettman leading; three-round schedule locked (5/28-29, 6/16-17, week of 7/20); CAPE first refunds expected to land week of June 2; §232 metals stable; 64 days to §232 pharma; 166 days to Busan expiry with the §122 judicial risk tightening pressure.
Read analysis →2026-05-26 · By Marcus · 6 min read
Ten items as of May 26: Sheinbaum gave first US-Mexico round read ("advancing positively"); §122 is by design a bridge expiring July 24 when §301 takes over; single-source signal §122 may already be struck by CIT May 7 (flagged for verification); §301 178-product exclusions extended to November 10 (date-aligned with Busan); Beijing summit commercial deliverables (soybeans, Boeing) in execution; CAPE first refund landings still publicly unconfirmed but on-window; §232 metals tiered system stable in month two; 66 days to §232 pharma; 168 days to Busan expiry — the architectural timeline is now fully visible.
Read analysis →2026-05-22 · By Marcus · 6 min read
Ten dated items as of May 22: Bessent May 19 Reuters names a ceiling (§301 restores but won't go higher); MOFCOM May 20 also names ceiling (Busan level is the redline); first concrete number — $30B per side reciprocal framework from May 12-13 Seoul talks; §301 16-economy investigation effectively becomes a China-only ceiling lock; Ebrard May 20 calls USMCA review a decade-plus annual cycle; US-Mexico May 25 agenda locked at 3 days out; CAPE first refunds not yet publicly confirmed; §232 pharma 70 days; Busan-truce 172 days with the framework numbers now visible.
Read analysis →2026-05-21 · By Marcus · 6 min read
Ten dated items as of May 21: the Busan rare-earth promise is leaking — April yttrium oxide US exports at 10 tonnes vs 60 in March; MOFCOM May 20 reframes controls as 'lawful'; White House tacitly accepts; Greer pre-positions Mexico (tariffs never returning to zero) four days before May 25 round; CAPE refunds 3-5 weeks ACH from liquidation; no §232 Mexico carve-out; 71 days to §232 pharma; §301 forced-labor in determination; §301 excess-capacity narrowing toward China-only on hearing record; 173 days to Busan expiry with the first crack already visible.
Read analysis →2026-05-19 · By Marcus · 6 min read
Ten dated items as of May 19: Trump-Xi Beijing summit landed May 14-15 heavy on symbolism ($17B/yr soybeans, 200 Boeing, two new bilateral committees), rare-earths named only in US communiqué not China's, CAPE Phase 1 at 15.1M validated and $35.46B refund pool with Treasury disbursing May 12, US-Mexico bilateral opens May 25 with 52 US demands on the table, July 1 trilateral review unlikely to conclude on time, US average effective rate on China at ~31.6% base, §232 pharma 73 days from kickoff, CAPE Phase 2 timing undisclosed, forced-labor §301 entering determination, 175 days to Busan expiry.
Read analysis →2026-05-12 · By Marcus · 7 min read
On May 12 Trump arrived in Beijing for the Xi summit. From the May 12 desk state — 182 days to Busan-truce expiry, the §301 16-economy hearing closed May 8, He Lifeng holding parallel Seoul talks — five distinct paths run forward: full Busan renewal plus critical-minerals add-on, a larger G2 framework, partial renewal sector-by-sector, talks collapse and full stack returns November 10, or trade decouples from a non-trade agenda collapse. Each scenario carries a concrete observable signal.
Read analysis →2026-05-06 · By Marcus · 5 min read
Ten dated items as of May 6: §301 excess-capacity day-one testimony aimed at China while pushing to drop the other 15, CAPE's first IEEPA refund Monday, forced-labor §301 rebuttals due Friday, Eaton's next CBP progress report May 12, US-Mexico bilateral May 25, leaked Mexican retaliation list 5–20%, Canadian Liberal minority govt April 28, US average effective tariff at 11.8% (highest since early 1940s), §301 maritime vessel fees in force since April 17, and 188 days to Busan-truce expiry.
Read analysis →2026-05-03 · By Marcus · 5 min read
Ten dated, sourced items shaping cross-border trade as of May 3: §301 excess-capacity hearings open Monday, CAPE Phase 1 throughput at 3% in stage, May 25 US-Mexico bilateral, §232 full-value methodology one month in, pharma 100% on calendar, Mexico textile decree sunset, CBAM Q2 due July 6, single-source PRC retaliation cluster, and 191 days to the Busan-truce expiry.
Read analysis →2026-04-26 · By Marcus · 7 min read
March 11 — USTR Greer named 16 economies and 21 sectors. Statutory window: 12 months. Greer's public target: July 24, 135 days. Compared with the 2017 China §301 investigation that ran 322 days from launch to first tariff, this calendar is 58% shorter. The investigation is still running; the destination has been marked.
Read analysis →2026-04-22 · By Marcus · 6 min read
Every trade publication led with the steel numbers on April 2. The second §232 signed the same afternoon puts 100% ad valorem on patented pharmaceuticals — with Switzerland at 15%, Ireland and India at the default rate, generics exempt, and a July 31 deadline for 17 named companies.
Read analysis →2026-04-20 · By Marcus · 5 min read
December 30 2024: 1,463 Chinese product categories hit with 5-50% duties. The narrative was industrial protection; the mechanics were pre-emptive USTR compliance with IMMEX carve-outs intact.
Read analysis →2026-04-20 · By Marcus · 5 min read
Q1 2026 CBAM landed at €75.36/tonne CO₂ — but the 2.5% adjustment factor means the bill is tiny. The actual policy is a verified-emissions registry that producers pay to build.
Read analysis →2026-04-20 · By Marcus · 5 min read
April 6 raised §232 from 25% to 50% — but the policy story is buried in Annex I-B's switch from metal-content to full-customs valuation.
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