Refunds are live. Brokers aren’t filing.

What changed this week

Apparel-specific Federal Register activity was light April 11–18. The material move is that every apparel importer who paid IEEPA country-specific duties on entries from China, Vietnam, Cambodia, or Bangladesh in the IEEPA window has a refund claim filing on Monday, April 20. The USTR structural-excess-capacity investigation that closed April 15 puts every major apparel sourcing country on notice — hearings begin May 5.

The current stack: MFN + Section 301 (China only) + 10% §122 baseline (150-day cap — sunsets ~July 24 absent Congressional extension). If §122 sunsets, Vietnam T-shirts revert to ~16.5% and Q4 sourcing math changes materially. Book summer orders with this cliff in mind.

What it means — current duty stack

MFN base rates vary by specific 10-digit HTS; ranges shown.²⁸²⁹³⁰

Section 232 does not apply to apparel directly. Apparel with metal trim or hardware may be caught by the April 6 derivative expansion if metal content is substantial — technical outerwear with aluminum/steel components should audit.

The play — fiber-content reclassification (6202)

The women’s outerwear heading 6202 is structured by shell fiber content and the duty rate moves materially across subheadings:²⁸³¹

The delta between 6202.13 (MMF) and 6202.12 (cotton) is ~18.8 percentage points of MFN alone. If an outerwear construction is currently classified under 6202.13 because the shell is >50% polyester/nylon, shifting to ≥50% cotton blend (or introducing a cotton outer layer) drops the classification to 6202.12 and strips 18.8 points off the MFN. On $100K imported under that HTS, savings are ~$18,800 per cycle.

This is a defensible classification move, not a reclassification gimmick. CBP Form 177 binding rulings on fiber-content shell classification are well-established — pull a few on CROSS to confirm scope before committing.³²

Caveat: we have not verified this play against a specific brand’s product spec. Framework is sound; the fabric-premium and break-even assumptions should be stress-tested against supplier quotes before acting.

What changed this week

No new Section 301 or HTS Chapter 84/85/95 Federal Register action April 11–18. The material move is CAPE going live on Monday, April 20. For FBA sellers with a China-forward 2025 book, this is the biggest one-time cash event of 2026 — and most customs brokers will not file for you unsolicited. Queue CAPE first, then walk the §232 derivative audit.

De minimis remains closed globally. EO 14324 (July 2025) ended the $800 duty-free exemption; the February 2026 EO preserved the suspension using independent (non-IEEPA) authority, and postal shipments default to the 10% §122 rate.¹³ Statutory repeal is on the books for 2027. Operational baseline: every import pays duty, full entry process, regardless of per-parcel value.

Current duty stack — China-origin

For Vietnam origin, subtract the §301 column (no direct §301, though CBP circumvention enforcement on China-to-Vietnam transshipment is active). Mexico: USMCA may zero the MFN but §122 still applies; §232 derivative exposure is origin-agnostic.

The §232 derivative trap — the most-missed change

Pre-April 6, a power strip containing $3 of aluminum heat-sink paid §232 only on the $3. Post-April 6, that same power strip — if classified as a covered derivative — pays 25% on the full customs value of the power strip, not the aluminum content. For a $40 landed power strip, that’s $10 of new duty, not $0.75. This hits harder on products where the metal is structural rather than trim: aluminum-housing LED fixtures, steel-body small appliances, wired goods with copper/aluminum conductor.

De minimis — dead for your business model

Section 321 is fully suspended globally. Every commercial small-parcel shipment requires formal entry, regardless of value or origin.⁸⁹ Any inventory model built on China-origin <$800 parcels flowing direct-to-consumer via §321 is no longer viable. Formal entry means: full MFN + §301 + §122 + §232 + any AD/CVD.

The play — First Sale for Export (FSFE)

FSFE is a customs valuation method that lets the importer declare duty on the price paid by the middleman to the factory, not the price paid by the US importer to the middleman. For FBA operators sourcing through Hong Kong trading companies, Alibaba reseller aggregators, or multi-tier agents, the gap between factory price and invoiced price is typically 15–35%. Applying FSFE on a high-MFN-rate SKU (e.g., HTS 6402 footwear at 20%, or §301-hit electronics) drops the duty base by that same 15–35%.

The bar is real: bona fide documentation of the earlier sale, clear title transfer, and arm's-length pricing. Most FBA operators sourcing direct-from-factory don't qualify. But operators using trading companies often do, and most don't realize it — brokers rarely volunteer FSFE because the documentation burden falls on them.

What changed this week

Quiet policy week — no new Federal Register proclamations, BIS inclusion determinations, CBP bulletins, or country quota deals in the April 11–18 window. Digestion of the April 6 restructuring (still operative, details below).

One meaningful court development. April 15: the CIT ordered depositions of CBP and BIS officials in G&H Diversified Manufacturing LP — the first-ever depositions in a Section 232 steel exclusion denial case (covering legacy 2020 denials). Discovery targets the inter-agency exclusion evaluation process.¹⁴ Relevant because SMBs sitting on denied legacy exclusions may have a live refund path if plaintiff prevails.

The exclusions portal is gone. The Commerce §232 Exclusions Portal is closed. No new product exclusion requests accepted since February 10, 2025. What replaced it: the “inclusions” process, which runs in the opposite direction — domestic US producers petition to add derivative HTS codes to §232 scope. Importers and foreign producers have no standing.¹⁵ Next window: July 1–14, 2026 (auto parts), Docket ITA-2025-0040.

Current duty stack — post-restructuring

Country treatment — collapsed to baseline

Prior country-specific TRQs (EU, UK, Japan, South Korea) are eliminated under the new regime. Country-rotation playbooks are dead plays.⁷¹⁷

The duty-base trap

Under the prior regime, a $100 steel derivative containing $20 of covered steel paid 50% × $20 = $10 of §232. Under the new regime, that same product pays 25% × $100 = $25 — a 2.5× increase on an identical article despite the nominal rate moving down from 50% to 25%.⁶⁷

The play — US-melted-and-poured sourcing

The ≥95% US melted-and-poured carve-out (10% rate, vs. 50%) is the largest structural arbitrage the new regime opens.⁷ For manufacturers with overseas machining or fabrication capacity, it is now economic to: source raw steel or aluminum from a US mill, ship to overseas fabrication, and re-import the finished component. Import pays 10% §232 — the US origin of the metal governs, not the country of fabrication. Documentation bar: mill test reports (MTRs) must establish US melt-and-pour with ≥95% metal content.