§72 / US · CN · MX · CA

국경 간 무역의 오늘 짚어야 할 10가지 — 2026년 6월 14일

6월 14일 10가지 — 미·멕 2라운드 개시까지 48시간(에브라르드 6/15-18 워싱턴 4일 일정), 강제노동 §301 실제 2단계 세율(6국 「부분 금령」 10%, 54국 「미시행」 12.5%) — 6/3 「최대 12.5%」 표현 수정, USTR 6/9 미·중 Board of Trade 공개의견 7/10 마감, 중국 반응 계층화 — 제도 수용·세율 거부, CAPE 검증 입항 약 1,600만 건 확대, §122 사법 상태 불변, §232 금속 70일 차 안정, §232 의약품까지 47일, 7월 집중 시행 — 3주 6개 이벤트 연쇄, 부산 만료까지 149일·Board of Trade가 11/10 갱신 최대 신규 변수.

2026-06-14 · Marcus · 7분 분량

1. US-Mexico round 2 opens in 48 hours — Ebrard already booked June 15-18 in Washington. Mexico's Economy Minister Ebrard's itinerary is locked: arrival in Washington June 15, departure June 18, covering the full June 16-17 round 2 plus accompanying bilateral side-meetings. Three agenda blocks this round: agriculture + "level playing field" conditions + continued rules-of-origin work left open from round 1. Ebrard's previously-prepped 5-20% retaliatory list (pork, cheese, produce) reaches its actual sequencing point.

2. Forced-labor §301 is actually a "two-tier rate" structure — 10% and 12.5%. The detail in USTR's June 1-2 notice we didn't get exactly right on June 3: it's not "up to 12.5%" — it's a two-tier structure: 10% for economies "with full or partial prohibition on forced-labor trade" (the 6: Canada, Ecuador, EU, Indonesia, Mexico, Pakistan); 12.5% for "all other" economies (the 54: China, India, Japan, Korea, Vietnam, Brazil, etc.). Mexico therefore sits at the 10% tier under forced-labor §301 — meaningfully safer than its position under §232 / §301 16-economy.

3. USTR opens public comment on the US-China Board of Trade — deadline July 10. On June 9, USTR published a Federal Register notice seeking public comment on the scope and operation of the Board of Trade — the new bilateral institution announced at the May 14-15 Beijing summit. Stated goal: institutionalize ongoing dialogue, identify "non-sensitive goods" trade (agriculture, energy, specific inputs) that delivers concrete benefits for US farmers, ranchers, small manufacturers. MOFCOM's He Yongqian publicly endorsed the Board of Trade as the preferred negotiation channel — while opposing the forced-labor §301 tariff action. Both signals coexist: that's China placing bets on both tracks.

4. China's response stratifies — embrace the institution, reject the tariff. MOFCOM's early-June messaging is internally consistent: "will engage US on the forced-labor §301 proposal" + "will advance Board of Trade and Board of Investment operations." That separates US-side tools — the institution receives engagement, the tariff receives objection. CFO models need separate scenarios for both lines; treating "US-China relations" as one variable misses the bifurcation.

5. CAPE — May 26 court update expands validated entries to roughly 16M. CBP's May 26 progress filing to the CIT: CAPE Declarations passing validation now cover approximately 16 million entries (up from 15.12M on May 11). About 900K incremental over 45 days — sustained intake but no fundamental easing of the ACH disbursement bottleneck. Action remains unchanged: IOR ACE Portal ACH registration this week. /updates syncs each CBP progress report in real time.

6. §122 judicial status unchanged — CAFC administrative stay holds collection in place. May 7 CIT ruling + May 12 CAFC stay + May 20 CIT denial of government motion — the three-event sequence locks in. Next phase: long waiting window for CAFC merits ruling. Standard appellate cadence puts the substantive opinion most likely late 2026 through early 2027. Until then, §122 continues to be collected from every importer except Burlap & Barrel, Basic Fun, and Washington State. Real risk window: if CAFC delivers an early opinion before §301 July 24, every §122-paid importer has a protest opportunity — data archival now is the action.

7. §232 metals tiered system day 70 of operation, stable. April 6 framework — 50% on commodity / 25% on derivatives with ≥15% metal content / full exemption below 15% — has now run 70 days without major controversy. CBP scope-ruling queue building; those rulings will determine which HS codes land in which tier across the next 18 months. Load "CN → US steel derivative" preset in the Tariff Stack Calculator for layered structure.

8. §232 pharma 47 days from kickoff. 17 Annex III companies at 100% full value July 31. Other pharma companies September 29. Switzerland holds the 15% preferential tier; the only country discount. Ireland, India, China, Singapore, Belgium, Denmark, Germany, France, Italy stay default 100%. Switzerland has settled a "pharmaceutical reciprocal framework" with USTR — other major supplier states still chasing that door.

9. §301 16-economy + forced-labor + Brazil-specific — July landing density. USTR's July action calendar: July 6 forced-labor §301 comment deadline + July 7 forced-labor hearings start + July 10 Board of Trade comment deadline + week of July 20 US-Mexico round 3 in Mexico City + July 24 §301 16-economy action target + July 31 §232 pharma Annex III 17 companies kickoff. Six events trigger across three weeks — CFO models should build scenarios on a weekly cadence, not monthly.

10. Busan-truce countdown 149 days — Board of Trade is the largest new variable for November 10 renewal. Yesterday's data-layer calibration added six events from the past six weeks of digests that hadn't yet hit the structured layer. Live view now shows 18 entries; the 2026-05 snapshot still shows 11. Compare policy archives by month — /updates toggles "live" / "May 2026" buttons. The H2 2026 sourcing-decision environment is now fully drawable: tariffs won't return to zero (Greer May 21) + controls won't be lifted (MOFCOM May 20) + Board of Trade absorbs the dialogue (USTR June 9 + MOFCOM early June). Three things that used to look contradictory are the actual H2 shape.

Figures

Mar 2018
Original §232: 25% steel / 10% Al, metal-content basis
2019-2024
TRQ deals: JP 1.25 Mt · KR 2.63 Mt · EU quota
Feb 2025
Aluminum raised 10% → 25%
Apr 6 2026
Restructure: 50% A-I / 25% I-B / 15% transitional · full customs value
Dec 2027
Annex II 15% transitional carve-out expires
§232 STRUCTURE OVER TIME (CBP guidance · White House proclamations)
Figure 1 — §232 timeline. April 2026 marks the largest single restructure since the original 2018 proclamation.
0%25%50%75%100%🇨🇳 China§122§301§232 (50%)94%Effective ~94%🇯🇵 Japan§122§232 above-quota67%Above 1.25 Mt TRQ — in-quota = 17%🇰🇷 Korea§122§232 above-quota67%Above 2.63 Mt TRQ — in-quota = 17%🇬🇧 UK (95% melt-in-UK)§122§232 UK rate42%Special carve-out (50% ⇒ 25%)🇲🇽 Mexico§232 (full)50%USMCA exempts §122; melt-and-pour in MX/USA required
Figure 2 — Effective duty stack on HS 7208 (hot-rolled flat steel) into the US, by country of origin, post April 6 2026.
AnnexCoverageExamplesRateBasis
I-AArticles made entirely or almost entirely of steel/Al/CuBars, rods, plates, sheets, tubes, pipes, unwrought metal50%Full customs value
I-BDerivative articles with substantial metal contentBicycles, washing machines, prefab structures, wire products25%Full customs value (was: metal content)
IIMetal-intensive industrial / electrical grid equipment (transitional)Transmission towers, transformers, certain wind components15%Full customs value · expires Dec 31, 2027
IIITrade Agreement Partner-origin metal, drawback-eligibleAnnex I-B articles where metal smelted in UK/EU/JP/KR/MX/CAVariesDrawback restored
Figure 3 — §232 classification regime. Sources: April 2 2026 White House proclamation, Annexes I-A / I-B / II / III; CBP CSMS #68253075.