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Section 301 Forced-Labor Duties and Canadian exports to the USA

Timothy Byrnes — Sat, 25 Jul 2026 03:34:51 GMT

Trade Compliance Alert

By Timothy Byrnes, Jet Worldwide Published July 24, 2026 min read

Effective 12:01 a.m. ET on July 24, 2026, Section 301 forced-labor duties apply to imports from 60 economies. Seventeen face a flat 10 percent, 38 face a flat 12.5 percent including China, and five reach a 10 or 12.5 percent all-in rate. USMCA and Section 232 goods are exempt.

On this page

What changed on July 24
The rate tiers and all 60 economies
Canada and Mexico: the USMCA carve-out
Exemptions, general and country-specific
Filing mechanics: sequence, Chapter 98, and FTZ
Frequently asked questions

What changed on July 24

At 12:01 a.m. Eastern time on July 24, 2026, the Office of the United States Trade Representative brought new additional duties into force under Section 301 of the Trade Act of 1974. The action is the final determination in a forced-labor investigation covering 60 trading partners, and CBP issued filing instructions the same day in CSMS number 69326983.

The duties replace the expiring 10 percent global tariff that had been running under Section 122 of the Trade Act, which expired at midnight the same night.

The mechanics are entirely different from the flat measure they replaced. Rather than one rate for everyone, CBP created 65 country-level Chapter 99 headings running from 9903.05.20 through 9903.05.84, plus 8 general exemption headings and a further set of country-specific exemption headings reaching 9903.06.21. Every affected entry now needs the correct heading, in the correct reporting position.

Summary for Canadian Shipments to the USA:

10% minimum duty (10% plus regular duty)
Duty Free if Canadian origin under USMCA
Section 232 steel and aluminum tariffs still apply

The rate tiers and all 60 economies

There are four structural groups. Two apply a flat additional duty. Two apply an all-in rate, where the Section 301 duty tops the column one rate up to a ceiling rather than stacking on top of it.

Section 301 forced-labor rate tiers, per CBP CSMS number 69326983
Tier	Count	Economies	Mechanism	Rate
Flat 10 percent	17	Argentina, Bangladesh, Cambodia, Canada, Ecuador, El Salvador, Guatemala, Honduras, India, Indonesia, Jordan, Malaysia, Mexico, Pakistan, Sri Lanka, Trinidad and Tobago, United Kingdom	Additional ad valorem duty added to the column one rate	10%
All-in to 10 percent	2	European Union member states, Taiwan	If the column one rate is below 10 percent, a combined column one plus Section 301 rate of 10 percent applies. If it already equals or exceeds 10 percent, no additional duty is assessed.	10% all-in
All-in to 12.5 percent	3	Japan, South Korea, Switzerland	If the column one rate is below 12.5 percent, a combined column one plus Section 301 rate of 12.5 percent applies. If it already equals or exceeds 12.5 percent, no additional duty is assessed.	12.5% all-in
Flat 12.5 percent	38	Algeria, Angola, Australia, Bahamas, Bahrain, Brazil, Chile, China, Colombia, Costa Rica, Dominican Republic, Egypt, Guyana, Hong Kong China, Iraq, Israel, Kazakhstan, Kuwait, Libya, Morocco, New Zealand, Nicaragua, Nigeria, Norway, Oman, Peru, Philippines, Qatar, Russia, Saudi Arabia, Singapore, South Africa, Thailand, Türkiye, United Arab Emirates, Uruguay, Venezuela, Vietnam	Additional ad valorem duty added to the column one rate	12.5%

Canada and Mexico: The USMCA exemption

For Canadian exporters the headline "10 percent on Canada" is misleading read alone. Canada sits at 10 percent under heading 9903.05.29, but that heading is excepted by headings 9903.05.85 through 9903.05.93 rather than the usual 9903.05.85 through 9903.05.92. The extra heading is the point.

Heading 9903.05.93 provides that the Canada duty does not apply to products entered free of duty under the United States-Mexico-Canada Agreement, including treatment under subchapter XXIII of chapter 98 and subchapter XXII of chapter 99. Critically, it applies regardless of whether the good is entered under a provision showing "S or S plus" in the Special sub-column. Heading 9903.05.94 does the same for Mexico under note 52(h).

Other Exemptions, general and country-specific

General exemptions available to all 60 economies

Eight headings apply across every affected economy. Each is claimed on the entry, so none of them operate automatically.

General exemption headings, 9903.05.85 through 9903.05.92
Heading	Covers
`9903.05.85`	In-transit goods meeting both the July 24 loading test and the July 28 entry test
`9903.05.86`	Articles under subdivision (b) of U.S. note 52, the general product exemption list
`9903.05.87`	Articles under subdivision (c) of U.S. note 52, specifically named items such as seeds and tropical fruits
`9903.05.88`	Civil aircraft, engines, parts, components, subassemblies, and ground flight simulators
`9903.05.89`	Articles for use in pharmaceutical applications
`9903.05.90`	Section 232 articles: aluminum, steel, copper and derivatives; passenger vehicles and light trucks and parts; medium and heavy duty vehicles and parts; wood products; semiconductor articles
`9903.05.91`	Donations intended to relieve human suffering, such as food, clothing, and medicine
`9903.05.92`	Informational materials, including publications, films, recordings, artworks, and news wire feeds

Filing mechanics: sequence, Chapter 98, and FTZ

HTSUS reporting order on the entry summary line

This is the detail most likely to generate rejected entries in the first weeks, because Section 301 is reported ahead of Section 232 rather than after it. The required order is:

Chapter 98, if applicable.
Chapter 99 heading or headings for additional duties, if applicable.
Trade remedies in this sequence: Section 301 first, then Section 122, then Section 232, then Section 201 duties, then Section 201 quota.
Chapter 99 heading or headings for replacement duty or other use, such as Miscellaneous Tariff Bill provisions.
Chapter 99 heading for other quota not covered above.
Chapter 1 to 97 commodity classification.

The entered value is reported on the Chapter 1 to 97 line unless a Chapter 98 provision requires otherwise.

Chapter 98 treatment

The additional duties do not apply to goods properly entered under Chapter 98 where CBP agrees the provision is appropriate, with four carve-outs from that relief:

Subheadings 9802.00.40, 9802.00.50, and 9802.00.60. The additional duty applies to the value of the repairs, alterations, or processing performed abroad.
Heading 9802.00.80. The additional duty applies to the value of the article assembled abroad, less the cost or value of the United States products incorporated.

Frequently asked questions

How many economies face the 12.5 percent rate?

Thirty-eight economies face a flat 12.5 percent additional duty, including China, Brazil, Vietnam, Thailand, Australia, Singapore, and Israel. Japan, South Korea, and Switzerland separately reach 12.5 percent on an all-in basis, where the Section 301 duty tops up the column one rate rather than adding to it.

Does the 10 percent duty apply to all goods from Canada?

No. Heading 9903.05.93 exempts products of Canada entered free of duty under USMCA. The exemption applies regardless of whether the good is entered under a provision showing S or S plus in the Special sub-column. The 10 percent duty under heading 9903.05.29 therefore falls on Canada-origin goods that are not entered duty free under USMCA.

In what order do I report Section 301 and Section 232 on the entry summary?

Section 301 is reported first among the trade remedies

What is the in-transit exception and how do I claim it?

The in-transit exception is claimed under Chapter 99 heading 9903.05.85. Goods must have been loaded at the port of loading and in transit on the final mode of transit before 12:01 a.m. eastern time on July 24, 2026, and must be entered for consumption or withdrawn from warehouse for consumption before 12:01 a.m. eastern time on July 28, 2026. Both conditions are required.

Can I admit affected goods into a foreign trade zone to defer the duty?

Only as privileged foreign status under 19 CFR 146.41, unless the goods qualify for domestic status under 19 CFR 146.43. Privileged foreign status fixes the tariff treatment at admission, so admitting goods to a foreign trade zone does not avoid the Section 301 forced-labor duty.

Are Section 232 goods also charged the forced-labor duty?

No. Heading 9903.05.90 exempts aluminum, steel, and copper articles and their derivatives, passenger vehicles and light trucks and their parts, medium and heavy duty vehicles and their parts, wood products, and semiconductor articles. Pharmaceutical goods are exempt separately under heading 9903.05.89. Antidumping and countervailing duties continue to apply regardless.

Sources

U.S. Customs and Border Protection, CSMS number 69326983, Guidance: Section 301 Forced Labor Import Duties, including the Chapter 99 heading schedule, general and country-specific exemptions, Chapter 98 treatment, foreign trade zone requirements, and the HTSUS reporting sequence.
Office of the United States Trade Representative, Section 301 Forced Labor Notice of Action, announced July 23, 2026.
Harmonized Tariff Schedule of the United States, U.S. note 52 to subchapter III of chapter 99, and general note 29(d)(v).
19 CFR 146.41 and 19 CFR 146.43 on privileged foreign and domestic status in foreign trade zones.

This article is general information for Canadian and United States importers and exporters. It is not legal advice and it is not a substitute for a binding ruling. Confirm the treatment of your specific goods with your customs broker before entry.

EU Product Identifiers (PID): The 1 November 2026 Rule Canadian Exporters Need to Know.

Timothy Byrnes — Wed, 15 Jul 2026 13:12:58 GMT

By Timothy Byrnes Updated 15 July 2026

The short answer

From 1 November 2026, businesses selling goods into the European Union must transmit product identifiers at the point of import. The obligation comes from Regulation (EU) 2026/382, the same instrument that abolished the 150 euro customs exemption and replaced it with a flat 3 euro per item tariff. Voluntary filing opened on 1 July 2026.

The codes themselves those already in use them for internal systems. But they will service as a shared reference point between a business and customs.

Mandatory from: 1 November 2026
Voluntary from: 1 July 2026
Legal basis: Regulation (EU) 2026/382
Guidance: EU Guidance of 2 June 2026
Who is in scope: Businesses engaged in distance selling of goods imported into the EU
TARIC codes: C127, C128, C129, and Y081 for exceptions
Identifier types: M-PID (platform), NS-PID and S-PID (manufacturer)
Next horizon: July 2028: new Union Customs Code and EU Customs Data Hub

The change is not the code. It is the transmission.

Product identifiers are simply alphanumeric codes used internally by businesses. Effective November 2026 those codes are a necessary part of the data set transmitted systematically to customs.

That distinction matters more than it first appears, and it is worth being precise about why.

More Granular Oversight

The June 2026 EU Guidance explicit goal is to improve the traceability of individual products. Once customs identifies a non-compliant product, it can extend the outcome of that single inspection cross referenced with the importer's internal records.

Inspectors are finite and the traditional answer for parcels was sampling. Product identifiers break that constraint by decoupling the finding from the inspection. One examination can yield a result that propagates across an entire product inventory.

What this means for your risk profile

Under sampling, a defect had a low probability of being caught and a contained consequence when it was. Under identifier-linked enforcement, the probability of exposure rises.

The direction is not uniquely European

Since 8 July, roughly 600 products have had to be declared in advance to United States Customs and Border Protection, covering the content of the certificates of conformity required by the Consumer Product Safety Commission, with the product identifier among the required elements.

Two major customs authorities converging on item level identification within four months of each other is not coincidence. It is the same recognition arriving in two places: that parcel volumes have outrun physical inspection capacity, and that the only scalable answer is to make the data do the work.

The sequence

Already in force Customs exemption for consignments up to 150 euros abolished, replaced by a flat 3 euro per item tariff under Regulation (EU) 2026/382.
2 June 2026 EU Guidance published, clarifying that the objective is granular traceability across the supply chain.
1 July 2026 : voluntary compliance opens Operators may transmit product identifiers ahead of the mandate. This is the testing window, and it is open now.
8 July 2026 United States: advance declaration begins for roughly 600 products requiring CPSC certificate of conformity content, including the PID.
1 November 2026 : mandatory Product identifiers must be provided to EU customs on distance sales of imported goods.
July 2028 Full implementation of the new Union Customs Code and the EU Customs Data Hub. Product identifiers feed the Digital Product Passport under Regulation (EU) 2024/1781 on ecodesign.

M-PID, NS-PID, S-PID: who owns what

The source material and much of the early commentary uses these three abbreviations without expanding them, which is where most readers stall. The distinction is about who owns the code and what it points to.

Identifier types, owners and what each one actually anchors
Identifier	Owned by	What it anchors	Where it breaks
M-PID	Marketplace or platform	The listing as the platform knows it, linking the offer to the seller and the consignment	Platform feed does not reach the declarant, or reaches it after the declaration is filed
NS-PID	Manufacturer	The product at model or series level, guaranteed by the party that made it	Supplier will not or cannot supply it, common with private label and multi-tier sourcing
S-PID	Manufacturer	A more specific production level reference tying goods to a defined run	Exists in the factory system but never crosses into the seller's master data

The obligation is relevance, not presence

Supplying a code is not compliance. Where more than one identifier exists, the rule is to prioritize the identifier that maximizes control. That is a judgement standard, not a data entry standard. Document your selection logic down so that it is consistent, defensible and repeatable.

Distributed responsibility, concentrated exposure

Compliance splits across three parties who do not report to each other:

Who does what under the product identifier regime
Party	Obligation	Practical exposure
Platforms	Manage the M-PID	Feed integrity, and delivering the code to the declarant in time to be filed
Manufacturers	Guarantee the NS-PID and S-PID	Accuracy at source, and willingness to release production level references downstream
Customs declarants IOSS holders or indirect representatives	Formal declaration using TARIC document codes	Carries the filing liability while originating almost none of the data

That last row deserves emphasis, because it is the structural tension in the whole design. The declarant is accountable for the accuracy of a field that the platform or the manufacturer controls. If you are an indirect representative, you are jointly liable on a declaration built from data you did not create and frequently cannot verify.

The mitigation is contractual rather than technical. Before 1 November, the data supply obligation should be written into your terms with platforms and suppliers: which identifier, in what format, on what refresh cycle, with what warranty of accuracy, and who bears the cost when it is wrong. Distributed responsibility has a well known failure mode, which is that every party assumes another party owns the field.

TARIC document codes

Document codes used to transmit product identifiers on the customs declaration
Code	Use
`C127`	Product identifier document code
`C128`	Product identifier document code
`C129`	Product identifier document code
`Y081`	Declared where an exception applies and no product identifier is provided

Verify before you build

Confirm the exact mapping of C127, C128 and C129 to identifier type against the current TARIC publication and the 2 June 2026 guidance before configuring your declaration system. Document codes are the kind of detail that moves between draft and implementation, and a mapping error is silent until it is a rejection. Your broker or indirect representative should confirm the field mapping in writing.

Note also what Y081 represents an exception code. Every Y081 declaration is a documented assertion that no identifier was required, which means it is a queryable population. Patterns of use run the risk analytics of greater oversight by customs.

What this means for Canadian exporters

A Canadian merchant shipping direct to consumer parcels into the EU is in scope, whether selling through its own storefront or through a marketplace.

Three points that matter specifically on this side of the Atlantic:

Marketplace reliance is not delegation. If your EU volume moves through a platform, the platform manages the M-PID.
Private label and re-sale sourcing is the hard case. If you do not manufacture, the NS-PID and S-PID sit with a supplier who may be several tiers away with no direct EU obligation. Start those conversations now.

A six step readiness sequence

Map which identifier exists for every EU bound SKU. Line by line, record what is actually available: M-PID from the platform, NS-PID or S-PID from the manufacturer, or nothing. The nothing rows are your project plan.
Fix ownership in writing. Which party supplies which identifier, in what format, on what refresh cycle, with what accuracy warranty.
Decide the identifier priority rule. Where several exist, you must declare the one that maximizes control effectiveness. Document the selection logic.
Include TARIC codes into the declaration data set Configure C127, C128 and C129 as applicable and Y081 for exceptions. Confirm field mapping with your broker before volume arrives.
File voluntarily and read the errors. The window has been open since 1 July. Rejection messages on real consignments are free diagnostics on your master data.

The case for using the voluntary window

Use the test period before November to review potential identifier error messages. It is the the most useful testing environment available.

Where this is heading

November 2026 is a waypoint to the the new Union Customs Code in July 2028.

The pattern is clear: De minimis removal, product identifiers, greater oversight. Information transparency becomes structural to how goods move in the single market.

Frequently asked questions

What is a product identifier (PID) in EU customs?

An alphanumeric code that uniquely identifies a specific product or model within a business What is new under Regulation (EU) 2026/382 is that the code must be transmitted to EU customs at the point of import on distance sales, converting a private inventory reference into a regulatory data element.

When does the requirement start?

Mandatory from 1 November 2026. Voluntary compliance opened on 1 July 2026, allowing operators to test data flows.

What is the difference between M-PID, NS-PID and S-PID?

They differ by who owns the code and what it points to. The M-PID is the marketplace or platform level identifier, managed by the platform. The NS-PID and S-PID are manufacturer side identifiers.

Which TARIC document codes apply?

Declarants use C127, C128 and C129 to transmit product identifiers on the declaration. Y081 is used where an exception applies and no identifier is provided. Confirm the exact mapping against the current TARIC publication before configuring your system.

Who is legally responsible for declaring the identifier?

Responsibility is distributed. Platforms manage the M-PID. Manufacturers guarantee the NS-PID and S-PID. The customs declarant, in practice the IOSS holder or indirect representative, makes the formal declaration using the TARIC document codes. The declarant carries the filing exposure despite rarely originating the data, which is why the data supply obligation belongs in your contracts.

Does this apply to Canadian businesses shipping to the EU?

Yes.

How does this relate to the abolition of the 150 euro de minimis?

Both come from Regulation (EU) 2026/382, which removed the exemption for consignments up to 150 euros and replaced it with a flat 3 euro per item tariff. The identifier obligation is a separate requirement but part of the overall effort of greater oversight.

What happens if the identifier is missing or wrong?

A missing identifier where no exception applies is a declaration error, exposing the consignment to a hold, request for information and possible rejection.

How do product identifiers connect to the Digital Product Passport?

The PID is the on ramp. The reform runs to July 2028 with the new Union Customs Code and the EU Customs Data Hub.

Should we start filing voluntarily now?

For most operators with meaningful EU parcel volume, yes. Voluntary filing is a low risk way to surface master data and revealing coding errors without a rejected declaration (until November).

Shipping parcels from Canada into the EU

Jet Worldwide has supported Canadian exporters through EU customs reform. Contact our team for support with building compliant programs.

A note on sources

This article summarizes Regulation (EU) 2026/382, the EU Guidance of 2 June 2026 and related reporting. Document codes, dates and scope should be confirmed against the current official publications before you configure systems or file. Nothing here is legal advice.

About the author

Timothy Byrnes writes on customs classification, origin documentation and cross border compliance for Jet Worldwide, a licensed US customs brokerage and cross border specialists since 1988.

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Published 15 July 2026. Jet Worldwide provides this content for general information on Canadian and international trade compliance. It does not constitute legal, customs or tax advice, and regulatory requirements change. Confirm current obligations with a licensed professional or the relevant authority before acting.

The EU's New €3 Parcel Duty: What Canadian Sellers Need to Know Before July 1st

Timothy Byrnes — Fri, 05 Jun 2026 16:30:13 GMT

Home › Blog › EU B2C Customs Changes 2026

International Shipping Intelligence

June 5, 2026 by Jet Worldwide EU Customs Canada Post Alternative Cross-Border Ecommerce

€3 New per item/per line item duty on every non-EU e-commerce parcel
20 Postal operators warning they are not ready
Jul 1 EU implementation deadline — no delay confirmed
€150 Previous duty-free threshold — now eliminated

If your business ships to European customers through Canada Post or any postal network, the EU's new customs rules create a challenge.

Twenty postal operators — including some of Europe's largest — have publicly stated they are not ready. The businesses that will be fine are the ones that stopped relying on postal channels before July 1st.

Note that the 3 EUR fee applies to each unique HS code, per declaration line:

"the 3EUR customs duty will automatically apply per declaration line irrespective of the quantity (number of the articles) in that declaration line, provided that the intrinsic value of all goods included in the declaration does not exceed EUR 150."
Group multiple items of the same tariff classification per line on the invoice to avoid the 3 Euro duty being applied unnecessarily.

Service Alert:Canada Post has suspended parcel service to most of Europe

Effective June 30th, Canada Post has suspended service to major European Countries.

The trigger is the EU's new customs regime, effective July 1: a EUR 3 per-item duty on top of import VAT, plus item-level data and compliance requirements that postal DDU service simply cannot meet at scale.For small, occasional sellers, this is a hard stop.

For serious Canadian merchants, it is an opening. The exporters who win Europe from here will be the ones who stop relying on "easier postal clearance " and build a dedicated B2C lane: consolidation out of Canada, air freight into Europe, IOSS registration for compliant VAT collection, and reliable final-mile delivery across the EU.

Yes, there is an upfront cost to standing that up. But it turns a per-parcel gamble into a scalable system, and your unit costs fall as volume rebounds and grows.The border did not close but requires dedicated advanced logistics options. Contact our team.

How long will the Postal Suspension of Service to Europe Last?

To support the July 1st transition, postal operators continue to build new operational processes. We expect the suspension may not last longer than a week or so. However, the actual timeline remains unclear.

The several challenges that remain include:

Incomplete or incorrect customs data may lead to customs rejection, double handling or incorrect taxation
Finding ways to reduce recipients refuse to pay import fees by building delivery duty paid options and ways to alert consignees of pending charges prior to clearance.
Differences in national implementation, regarding DAP acceptance, transition periods, POA requirements, or customs processes

Canadian Registered Customs Representatives (RDE)

Unlike IOSS-collected VAT, the €3 duty is charged on businesses — the seller or representative at import. That has direct operational consequences for customs brokers. In practice, this means Registered Customs Representatives (RDE) now need to cover a materially larger guarantee amount to clear parcels.

For high-volume operators, that guarantee ceiling becomes a hard operational constraint: it directly limits how many parcels a broker can clear at any given time, unless the comprehensive guarantee is renegotiated and increased upstream with customs authorities.

Locally pre-cleared, EU-held inventory avoids the pinch entirely — stock already released for free circulation and stored in the EU sidesteps this per-parcel duty and guarantee pressure on every last-mile delivery

Where this Jet Worldwide creates opportunity.

FedEx, UPS and DHL Shipments to Europe and 3 euro minimum charge

The concern is not limited to postal operators. In a separate letter to EU finance ministers, the presidents of DHL Express Europe, FedEx Europe, and UPS EMEA — writing on behalf of the European Express Association — warned that without "a stable and workable legal framework," there is a "real risk" of shipments being held at EU borders, with disruption potentially affecting medical supply availability, industrial production, and broader European supply chains.

The real-world evidence is when France brought in its own €2 parcel tax before anyone else in Europe, the volume via the Paris CDG gateway fell over 920% within a week. But, in this case, the volumes simply transferred to other European gateways. The July 1st EU-wide rollout carries similar risks that are a magnitude larger. But, perhaps, this is the policy goal all along?

What the EU Is Changing — and Why It Matters Now

For years, packages valued at €150 or less entered the EU duty-free. That exemption disappears on July 1, 2026. Under the new rules, every item in a parcel shipped from outside the EU — including from Canada — is subject to a flat €3 customs duty per item, regardless of value. VAT obligations remain in addition to this charge.

The math shifts fast. A parcel with five different items now carries €15 in duty at the EU border before a single VAT calculation. For Canadian sellers shipping apparel, supplements, accessories, home goods, or any category with modest per-unit margins, this is not an abstraction. It is a direct hit to landed cost — and if your shipping program is not set up to handle it cleanly, your customer feels it at the door.

The critical issue: Duty must be declared, collected, and remitted correctly before or at customs clearance. Parcels that arrive without proper documentation will face holds, additional fees, or return to sender. Postal networks — Canada Post included — are not structured to manage this at scale for individual e-commerce shipments.

Direct-to-consumer flows into the EU and Tariff Classification:

The EUR 3 fee - administratively - is the easy part. The real work is tariff classifications at the SKU level that will be necessary effective July 2028. At this point, actual duty rates will apply. Still time to prepare but something to keep in mind when building and updating your inventory listing.

Why Postal Operators Themselves Are Raising the Alarm

This is not speculation from logistics consultants. On May 29, 2026, the chief executives of 20 postal operators — including An Post, DHL Group, and the national postal services of France, Germany, Italy, Spain, the Netherlands, and 14 other EU member states — sent an urgent letter to European Commissioner Maros Sefcovic requesting a minimum six-month delay.

"The final legal text will be available only four weeks before the due date of July 1st, making it impossible for businesses, merchants and operators to be fully compliant." — Open letter to Commissioner Maros Sefcovic, May 29, 2026

Their stated concerns reveal exactly why postal channels are the wrong infrastructure for this moment:

1. Compliance is structurally impossible on this timeline. The final legal text arrives just four weeks before the deadline. Postal operators cannot retool systems, train staff, or update processes in that window, Non-EU operators like Canada Post face the same constraint from the other side of the Atlantic.
2. Postal networks serve fragmented, low-value traffic with no alternative infrastructure. The letter specifically notes that postal operators "predominantly serve fragmented, low-value and socially inclusive traffic — SME exports and consumer-to-consumer exchanges."
3. Millions of parcels face return to sender. Without proper duty documentation, the postal operators warned that "millions of parcels would have to be returned." (If your shipments move through Canada Post or a European postal network, your parcels are in that pool.)
4. Inconsistent enforcement across EU member states. The short implementation timeline risks "divergent interpretations" across different EU customs authorities — meaning the same shipment could be handled differently in Germany versus Spain versus Ireland. Jetship imports via France.
5. The European Commission is not backing down. Despite the letter, the Commission confirmed its timeline remains unchanged. A guidance document was published, but the deadline stands.

The Honest Problem With Canada Post and Postal Solutions for EU Shipping

Canada Post has served Canadian e-commerce sellers well for domestic and some international volume. But the new EU customs environment exposes the fundamental limitations of postal infrastructure for cross-border B2C shipping into a regulated single market.

Capability Required	Canada Post / Postal Networks	Jetship Dedicated Program
Prepaid duty collection at checkout (DDP)	Not supported	Supported
Per-item €3 duty declaration and remittance	Not ready — operators' own admission	Built into program design
Consolidated customs documentation	Individual parcel level only	Consolidated manifest with full compliance data
VAT Payment	Being established	Can be arranged
Consistent customs treatment across EU member states	Varies — divergent enforcement risk flagged	Routed through one consistent clearance point.
End-to-end tracking visibility for EU delivery	Limited after handoff to EU	Full visibility through final delivery
Scalable for B2C e-commerce volume	of course.. but eventually	Designed to help you scale

This is not a criticism of Canada Post as a carrier as we still recommend Canada Post for personal shipments to Europe. And we support their universal coverage mandate and support of small businesses. But the "easier postal clearance advantage" is no longer a thing.

The EU's new customs framework demands conformity regardless of carrier, postal or commerical clearance. A purpose-built program has its own limitations but - at the same time - give a real opportunity to scale your sales to Europe. Including taking advantage of duty free import via CETA.

How Jet Worldwide Builds a Better European Shipping Program

Jet Worldwide helps Canadian ecommerce sellers replace postal-channel EU shipping with structured, scalable programs built specifically for the post-exemption customs environment. Here is what that looks like in practice:

Cost Efficiency

Parcel Consolidation into Europe

Jet aggregates yourCanadian B2C shipments and moves airfreight into European markets.

Compliance

Prepaid Duty and VAT — Delivered Duty Paid

Under a DDP program, duty and VAT are collected before the parcel reaches EU customs — meaning your customer pays a known all-in price at checkout with no surprise charges on delivery. Under the new €3-per-item regime, this is actually easier to calculate and administer.

Dedicated Infrastructure

Proprietary Import Process — Your Program, Not a Shared Network

The biggest risk of relying on postal channels is delays in an overwhelmed system. Jet builds you a proprietary import lane: a dedicated customs broker, consistent clearance routing, and a documented processes.

Direct Routing

Direct Shipping to Europe — No Postal Handoff

Jet routes shipments directly into European distribution without handing off to the postal networks that are publicly warning they cannot handle the new duty requirements. Direct routing provides full tracking visibility, eliminates the postal last-mile uncertainty that accounts for most EU delivery failures, and keeps your shipments out of the fragmented postal backlog the new customs rules are about to create.

If You Are Still Shipping to Europe Through Canada Post, It Is Time to Change That

The postal operators signing letters to the European Commission are not warning about a minor administrative adjustment. They are describing a system that is not ready for the new rules — and asking for more time because the consequences of proceeding unprepared are serious: returned parcels, customer complaints, compliance exposure, and lost sales.

Canadian sellers do not need to accept that risk. Jet Worldwide exists precisely to build the kind of structured, documented, duty-paid European shipping program that postal channels cannot provide. Whether you are shipping 50 parcels a week to the UK and Germany, or building out a serious European market strategy across multiple countries, we can build you a program that works under the new rules — and keeps working as those rules evolve.

Get a European Shipping Assessment See Our EU Solutions

Source: An Post CEO David McRedmond and 19 European postal operators, open letter to Commissioner Maros Sefcovic, May 29, 2026. Reported by The Irish Times. European Commission response, June 2026.

Frequently Asked Questions

Common questions from Canadian ecommerce sellers about the EU's new customs rules and alternatives to postal shipping.

What exactly is the EU's new €3 parcel duty and when does it start?

Starting July 1, 2026, the European Union will apply a flat customs duty of €3 per item on all goods purchased online from non-EU countries. This applies to every item inside a parcel — not per parcel, per item. A parcel containing three products carries €9 in duty. A parcel containing six products carries €18 in duty. This replaces the previous rule that allowed packages valued at €150 or less to enter the EU duty-free. That exemption no longer exists.

Does this new EU duty apply to Canadian sellers?

Yes. The new €3-per-item duty applies to all online purchases shipped from any non-EU country to an EU consumer. Canada is included, along with the United Kingdom, the United States, Switzerland, Norway, and all other non-EU origin countries. There is no exemption for small sellers or low-volume shippers.

If you are selling to customers in Germany, France, the Netherlands, Ireland, or any other EU member state, this duty applies to your shipments.

Why are so many postal operators saying they are not ready for the July 1st deadline?

On May 29, 2026, twenty postal operators — including An Post (Ireland), DHL Group (Germany), and the national postal services of France, Italy, Spain, Belgium, the Netherlands, and 13 other EU member states — signed an open letter to the European Commission requesting a six-month delay.

Their core reasons were as follows. The final legal text of the new rules will not be available until just four weeks before the July 1st deadline, making technical compliance impossible. The duty collection system depends on non-EU operators like Canada Post being ready to capture and transmit the correct data — and those systems are not built for per-item duty declaration at scale.

Without proper documentation, millions of parcels will be returned to senders rather than delivered. Despite this letter, the European Commission has confirmed its deadline remains unchanged.

Why is Canada Post not a good solution for shipping to the EU under the new rules?

Canada Post and other postal networks were designed to move individual parcels between senders and recipients with simpler "postal clearance" processes. Most often, these did not include having to manage duty charges.

The new €3-per-item duty requires that duty be declared, collected, and remitted correctly before or at EU customs clearance.

Canada Post - and postal resellers in Canada -do not offer a Delivered Duty Paid (DDP). Furthermore, they do not provide a dedicated importer of record in EU markets. The hand off from Canada post to EU postal networks that have publicly stated they are not ready for the new regime.

What is Delivered Duty Paid (DDP) shipping and does my business need it for the EU?

Delivered Duty Paid (DDP) means that the seller — not the buyer — is responsible for paying all customs duties and taxes before the parcel reaches the customer. Under a DDP program, the duty and VAT are calculated at checkout and remitted to the relevant customs authority before or at the point of clearance.

Using a dedicated clearance process, this can be achieved.

What does Jet Worldwide offer as an alternative to Canada Post for shipping to Europe?

Jet Worldwide builds purpose-built European shipping programs for Canadian companies. This includes parcel consolidation from Canada into Europe to reduce per-unit costs, Delivered Duty Paid programs that collect and remit €3-per-item duty and VAT before customs clearance. A Jet program is built specifically for your business — with consistent documentation, predictable transit, and compliance.

Talk to a Jet specialist about your EU shipping program →

How do I know if my current EU shipping setup is ready for the July 1st changes?

Ask your current carrier or shipping provider three questions. First: do you offer Delivered Duty Paid (DDP) service into the EU. member states?

Second: do you have an established importer of record in the EU markets I ship to manage IOSS/ VAT?

Third: can you guarantee my parcels will clear EU customs without being held or returned due to incomplete duty documentation after July 1st?

Request a free EU shipping assessment from Jet →

CUSMA USMCA Review 2026: What Happens on July 1st and What to Expect

Timothy Byrnes — Mon, 01 Jun 2026 16:12:27 GMT

Home › Blog › CUSMA USMCA Review 2026

June 2026 · Updated June 1, 2026 · By Jet Worldwide

The much-anticipated CUSMA/USMCA joint review is now weeks away, and the central question across the trade community is straightforward: will it be resolved — and if so, how soon? The short answer is that very little will be settled on July 1. Here is what the agreement requires, where things stand, and what Canadian exporters and importers should plan for.

Key Takeaways

July 1, 2026 triggers the mandatory review under Article 34.7 — it is a trigger date, not a deadline.
Three possible outcomes: 16-year extension, full withdrawal, or annual review cycles for up to 10 years.
A straightforward renewal is highly unlikely given current trade tensions.
Early engagement has been largely between the US and Mexico — Canada's role has been limited.
Expect a prolonged negotiation extending well into 2026 and beyond.

In This Article

What does Article 34.7 require?
What are the three possible outcomes?
Where do things stand right now?
How have tariff measures changed the landscape?
What does the shift in US trade strategy mean?
What should Canadian shippers expect?
Frequently asked questions

What Does Article 34.7 of CUSMA Actually Require?

Under Article 34.7, CUSMA is subject to a formal joint review six years after implementation — July 1, 2026. But this date is a trigger, not a deadline. It initiates a mandatory conversation among Canada, the United States, and Mexico to assess whether to extend, adjust, or wind down the agreement.

This is the first time the review mechanism has ever been used, so there is no established blueprint for how the process will be conducted.

What Are the Three Possible Outcomes of the CUSMA Review?

The review process can lead to one of three outcomes:

1. Extension

A 16-year extension of the agreement, providing long-term stability for North American trade.

2. Annual Reviews

A transition into annual review cycles for up to 10 years, followed by expiration if no resolution is reached.

3. Withdrawal

A full withdrawal by any party, effectively ending the trilateral agreement.

Where Do Things Stand Right Now?

A straightforward renewal of CUSMA looks highly unlikely. Early rounds of engagement have taken place largely between the United States and Mexico, while Canada's role has been limited.

The review process opens the door to re-litigating longstanding trade irritants among all three parties.

How Have Tariff Measures Changed the Landscape?

Ongoing tariff measures have reshaped the broader trade environment. This executive authority -rather than requiring congressional legislation - is used more freely. With IEEPA being abolished, key tools that remain include:

Authority	Legislation	Basis for Restrictions
Section 122	Trade Act of 1974	Balance of payments and large trade deficits (currently challenged in court)
Section 301	Trade Act of 1974	Unfair foreign trade practices and IP violations
Section 232	Trade Expansion Act of 1962	National security threats from specific imports

These tools allow trade restrictions to be imposed under specific economic or national security conditions — and their expanded use has added significant pressure to the broader trade environment heading into the CUSMA review.

What Does the Shift in US Trade Strategy Mean for CUSMA?

These developments reflect a fundamental shift in U.S. trade strategy: trade is increasingly treated not as an economic matter but as a tool of foreign policy leverage. This more transactional approach carries directly into the CUSMA review process.

The review opens the door to re-litigating longstanding irritants rather than locking in the stability that businesses on both sides of the border depend on.

What Should Canadian Exporters and Importers Expect?

We expect the review process to extend beyond 2026. For Canadian exporters and importers, the practical takeaways are clear:

Plan for continued uncertainty.
Monitor developments closely and make necessary changes
Review supply chain contingency planning.
Understand your tariff exposure to Section 122, 232, and 301 tariffs

What is shaping up is a prolonged negotiation rather than a routine renewal. The three parties — Canada, the United States, and Mexico — will need to work through significant differences before any lasting resolution is reached.

Need help navigating CUSMA uncertainty?

Jet Worldwide has been helping Canadian businesses ship internationally since 1983.

Get a Shipping Consultation

Frequently Asked Questions: CUSMA USMCA Review 2026

What happens to CUSMA on July 1, 2026?

July 1, 2026 triggers the mandatory joint review under Article 34.7 of CUSMA. It is a trigger date, not a deadline. Canada, the United States, and Mexico must begin formal consultations on whether to extend, adjust, or wind down the agreement.

What are the three possible outcomes of the CUSMA review?

A 16-year extension, a full withdrawal by any party, or a transition into annual review cycles for up to 10 years — followed by expiration if no resolution is reached.

Will CUSMA be renewed on July 1?

A straightforward renewal is highly unlikely. Current trade tensions and limited Canadian involvement in early discussions suggest the review process will extend well into 2026 and possibly beyond.

How do US tariff actions affect the CUSMA review?

Ongoing tariff measures under Section 122, Section 301, and Section 232 have reshaped the trade environment. The increased reliance on executive authority rather than congressional legislation reflects a shift toward using trade as a foreign policy tool, adding complexity to the CUSMA review.

What should Canadian exporters do during the CUSMA review?

Plan for continued uncertainty, monitor developments closely, review supply chain strategies, and understand your tariff exposure under current Section 122, 232, and 301 actions.

Related Jet Worldwide Resources

EU E-Commerce Customs Rules 2026: What Canadian Sellers Need to Know

Timothy Byrnes — Fri, 29 May 2026 13:33:43 GMT

Quick answer: From July 1, 2026, a new customs duty of 3 euros per distinct item applies to all e-commerce parcels entering the European Union where the goods are valued at 150 euros or less. This replaces the previous duty exemption. Canadian online sellers shipping to EU consumers must understand two customs entry pathways: H7 (simplified e-commerce declaration for low-value B2C shipments) and H1 (traditional full customs entry for higher-value or commercial shipments). Registering for IOSS (Import One-Stop Shop) lets Canadian sellers collect VAT at checkout and use the streamlined H7 process.

New Rule Effective July 1, 2026

The EU has eliminated the customs duty exemption for e-commerce parcels valued at 150 euros or less. A flat 3 euro duty per distinct item category in each parcel now applies across all 27 EU member states. An additional 2 euro handling fee per consignment applies from November 2026. VAT (ranging from 17% to 27% depending on the member state) continues to apply on top of the duty.

In this guide

The New 3 Euro Per Item Duty
H7 vs H1 Customs Entry Explained
IOSS for Canadian Sellers
How the Duty Is Paid
Impact on Returns and Refunds
CETA and Preferential Origin
Identifying EU vs Non-EU Sellers
Action Steps for Canadian Sellers

The New 3 Euro Per Item Customs Duty (Effective July 1, 2026)

From July 1, 2026, a new customs duty of 3 euros for each distinct item category in a parcel applies to goods purchased online from non-EU countries, including Canada. This change applies uniformly across all 27 EU member states.

How the 3 euro duty is calculated

The duty is assessed per distinct item category (including tariff sub-category) in the shipment, not per parcel. For example:

Example 1: A package from Canada contains a pen, a notebook, and a key ring. Each distinct item has a 3 euro duty charge: 3 items x 3 euros = 9 euros customs duty, plus VAT.

Example 2: A package contains two identical pens. These are considered one item category: 1 category x 3 euros = 3 euros customs duty, plus VAT.

Example 3: A Canadian Shopify seller ships one silk scarf and four wool scarves. Silk and wool fall under different tariff sub-headings, creating two distinct categories: 2 categories x 3 euros = 6 euros customs duty, plus VAT.

Important not: The 3 EUR duty applies to each unique HS code, per declaration line. Multiple items with the same tariff classification should be on a single line on the invoice to avoid the 3 Euro duty being applied unnecessarily.

From November 2026, an additional 2 euro handling fee per consignment is expected.

Options now that Canada Post has suspended service to Europe?

Canada Post announced a suspension of service to France, Germany, Spain, Portugal, Ireland nd other major European countries on June 30, 2026.

For small shippers, the best option of using commercial carriers (or their partners) but the costs are much more than the small packet service offered via the post

Large shippers should look to build direct shipping processes to Europe: Consolidate, ship via air freight, dedicated clearance process, distribute across Europe. Contact our team for details.

H7 vs H1: Two Customs Entry Pathways into the EU

When goods arrive at an EU border, they must be declared to customs through a formal entry. The EU customs system offers two distinct declaration types for imports, and understanding the difference is essential for Canadian e-commerce sellers:

H7 — Simplified Low-Value E-Commerce Declaration

The H7 dataset is a streamlined customs declaration designed specifically for B2C (business-to-consumer) e-commerce shipments valued at 150 euros or less. It was introduced as part of the EU's July 2021 e-commerce VAT reform alongside the IOSS system.

Key characteristics of H7:

Fewer data elements: H7 requires approximately 15 data fields, compared to 50 or more for a standard H1 declaration. This makes filing faster and less expensive.
No full tariff classification required: Goods do not need a full 8 or 10 digit HS/CN code. A simplified commodity description is sufficient in most cases.
IOSS integration: When the seller is registered for IOSS, the IOSS VAT identification number is included in the H7 declaration. This tells EU customs that VAT has already been collected at checkout, allowing the parcel to clear without the recipient paying VAT on delivery.
Used by postal operators and express carriers: Postal services and courier companies (FedEx, UPS, DHL, national postal operators) file H7 declarations in bulk for the low-value parcels they carry.
Value ceiling: Strictly for qualifying goods with a value less than 150 euros. Above this threshold, a H1 declaration is necessary.
Goods excluded: Goods requiring specialized treatment, including alcohol, tobacco, some cosmetics and supplements do not qualify for H7 import processes.

July 2026 change: Before July 1, 2026, H7 shipments cleared with zero customs duty (only VAT applied). From July 1, 2026, H7 shipments are subject to the new 3 euro per item/per line duty in addition to VAT. The H7 simplified declaration process itself remains available — only the duty treatment changes.

H1 — Traditional Full Customs Declaration

The H1 dataset is the standard, full-format customs declaration used for all imports that do not qualify for H7 simplified treatment. This includes:

All shipments valued above 150 euros
All B2B (business-to-business) commercial shipments regardless of value
Shipments containing excise goods (alcohol, tobacco, perfume, supplements)
Pallet and freight shipments, FCL and LCL ocean consignments

Key characteristics of H1:

Full data requirement: 50 or more data fields including complete 8 or 10 digit commodity code (Combined Nomenclature), country of origin, customs valuation, EORI number of the importer, transport document references, and detailed goods description.
Traditional duty calculation: Duty is calculated based on the applicable tariff rate for the specific HS code. In many cases, this may actually be an advantage and involve lower duty. For Canadian-origin goods, CETA preferential duty rates (often 0%) can be claimed if a valid origin declaration is provided.
EORI required: The EU importing business must have a valid EORI number (Economic Operators Registration and Identification).
Higher compliance cost: A customs broker typically prepares the H1 entry, adding brokerage fees of 15 to 50 euros per declaration depending on the complexity. Couriers usually charge less than independent brokers. Regular importers most often find the benefit from having their own dedicated broker worth the additional cost.

H7 vs H1 comparison at a glance

Feature	H7 (Simplified)	H1 (Traditional)
Value limit	150 euros or less	No limit
Typical use	B2C e-commerce parcels	B2B, high-value, commercial
Data fields	~15 (simplified)	50+ (full dataset)
HS code required	Simplified description	Full 8-10 digit CN code
Customs duty (from July 2026)	Flat 3 euros per item category	Full tariff rate by HS code (CETA 0% if qualified)
VAT collection	Via IOSS at checkout or on delivery	Collected at import by customs broker
EORI required	Not for the buyer	Yes (importer of record)
CETA preference available	No (flat rate applies)	Yes (0% duty with origin declaration)
Brokerage cost	Minimal (bulk filed by carrier)	15 to 50 euros per entry

Send direct to Europe from Canada and get H1 clearance

Jet Worldwide offers Canadian e-commerce sellers access to H1 clearance for their European orders. This program offers a significant discount versus couriers and a for superior service to postal options. Contact our team for details.

See our PDF presentation

IOSS (Import One-Stop Shop) for Canadian Sellers

The Import One-Stop Shop (IOSS) is an EU VAT registration mechanism that allows non-EU sellers (including Canadian e-commerce businesses) to collect VAT at checkout and remit it to a single EU member state, which then distributes it to the destination country.

Why IOSS matters for Canadian Shopify and e-commerce sellers

Better customer experience: When you collect VAT at checkout via IOSS, your EU customer pays the final all-in price and receives the parcel without any surprise charges on delivery.
Faster customs clearance: Parcels with a valid IOSS number clear customs more quickly.
H7 simplified declaration: IOSS shipments are declared through the H7 simplified process, reducing data requirements and compliance costs per parcel.
Applies only to B2C under 150 euros: IOSS covers distance sales of goods with an intrinsic value of 150 euros or less shipped from outside the EU to consumers. B2B sales and higher-value shipments require the H1 process.

Will IOSS be available for shipments over €150?

They are discussions to expand IOSS to include higher value values beyond €150. While, the outcome remains uncertain, we predict there will be a higher threshold for IOSS VAT payment in 2027.

How a Canadian seller registers for IOSS

Non-EU sellers must appoint an IOSS intermediary established in the EU. The intermediary registers on behalf of the Canadian seller in one EU member state, and that single registration covers sales to consumers in all 27 member states. The Canadian seller receives an IOSS VAT identification number (format: IMxxxxxxx) which is provided to the carrier on each shipment.

Jet Worldwide can assist Canadian e-commerce businesses in connecting with IOSS intermediaries and integrating the IOSS number into shipping workflows. Contact our team for IOSS guidance.

How the New Customs Duty Will Be Paid

EU consumers will pay the 3 euro customs duty per item in one of two ways, depending on the terms and conditions of the selling business:

Option 1 — Charged at checkout (DDP / Delivered Duty Paid)

Some websites will be set up to collect the duty at the point of sale.

Option 2 — Charged on delivery (DAP / Delivered at Place)

Other websites may not collect the duty at checkout. In this case, the delivery company (for example, the national postal service or a courier such as FedEx, UPS, or DHL) will require the consumer to pay the 3 euro duty per item before the goods can be delivered. Most carriers also add a disbursement or handling fee (typically 5 to 15 euros) for collecting duty and VAT on behalf of the consumer.

Recommendation for Canadian sellers: Contact our team to explore direct shipping options and dedicated clearance processes.

Impact on Returns and Refunds

The new rules significantly affect the returns process for goods purchased from outside the EU:

Customs duty is non-refundable: If a consumer returns an item, the 3 euro customs duty will not be refunded, unless the goods are faulty or defective.
VAT refunds vary by seller: Some online suppliers will refund the VAT paid if an item is returned, but many will not. This depends on how individual businesses account for their VAT liabilities through IOSS or the carrier's import process. This is often not obvious to consumers at the time of purchase.

Implication for Canadian sellers: Your returns policy and terms of service should clearly state whether customs duty and VAT are refundable on returned goods.

CETA and Preferential Origin: When the 3 Euro Duty Does Not Apply

Under the Canada-European Union Comprehensive Economic and Trade Agreement (CETA), most Canadian-origin goods can enter the EU duty-free (0% tariff) when accompanied by a valid origin declaration on the commercial invoice.

However, CETA preferential treatment applies only to H1 (full customs) declarations, not to H7 simplified e-commerce entries.

This creates an important strategic decision for Canadian sellers:

H7 route (under 150 euros, B2C): The flat 3 euro per item duty applies regardless of Canadian origin. CETA preferences cannot be claimed on an H7 declaration. But the process is simpler, faster, and cheaper per parcel.
H1 route (any value, B2B or B2C): If the goods are of Canadian origin and you provide a valid CETA origin declaration, the duty rate can be 0%. But the H1 process is more complex, requires a full HS code, and typically involves a customs broker fee.

For most low-value e-commerce shipments, the H7 route with the 3 euro flat duty is more practical and cost-effective than filing an H1 entry with CETA origin documentation. But for higher-value Canadian-made goods (handcrafted products, premium food, specialized equipment), the H1 with CETA 0% duty may save money, especially on multi-item orders where the flat 3 euros per item would otherwise add up.

Shopping Within the EU: Identifying Where Goods Actually Ship From

There is no customs duty if goods are located in an EU country at the time the order is placed. The 3 euro duty applies only to goods shipped from outside the EU.

Some websites may appear as if the business is EU-based — by using a local domain (for example, a ".ie" or ".de" domain), showing prices in euros, or displaying a European return address — but the goods may actually be shipped from a non-EU country such as China, the United Kingdom, or Canada.

For EU consumers: Check the website's "Terms and Conditions" or "About Us" page to confirm the physical business address and the location from which goods will be shipped.

For Canadian sellers: Be transparent about your shipping origin. If you ship from Canada, clearly disclose this and explain any applicable duty and VAT in your checkout flow. Sellers who pre-stock inventory in EU fulfillment warehouses avoid the 3 euro duty entirely because the goods are already inside the EU when the consumer orders.

Action Steps for Canadian E-Commerce Sellers

If you sell online to EU consumers, take these steps before July 1, 2026:

Register for IOSS (through an EU-based intermediary) to collect VAT at checkout and enable H7 simplified customs filing.
Update your checkout flow to show the 3 euro per item customs duty to EU buyers. If you use Shopify, WooCommerce, or a similar platform, work with your developer or shipping app to integrate duty calculation.
Update your terms and conditions and returns policy to state clearly whether customs duty and VAT are refundable on returned goods.
Decide between DDP and DAP for your EU shipments. DDP (collecting duty and VAT at checkout) is strongly recommended for customer satisfaction.
Evaluate CETA origin for higher-value shipments. If your products are Canadian-made, the H1 route with a CETA origin declaration may eliminate duty entirely on orders over 150 euros.
Consider EU fulfillment for high-volume sellers. Pre-stocking inventory in an EU warehouse eliminates the 3 euro duty, speeds delivery, and removes cross-border friction for consumers.

Jet Worldwide supports Canadian e-commerce businesses with IOSS integration, H7 customs filing, and direct delivery solutions across all 27 EU member states. Contact our team to prepare for July 1, 2026.

EU VAT Rates by Member State (2026 Reference)

VAT is charged on top of the 3 euro customs duty. Rates vary by member state. The standard rates for the most common Canadian export destinations are:

Member State	Standard VAT Rate
Germany	19%
France	20%
Netherlands	21%
Spain	21%
Italy	22%
Belgium	21%
Ireland	23%
Poland	23%
Sweden	25%
Hungary	27%

Note: Reduced VAT rates apply to certain product categories (books, food, children's clothing) in many member states. Confirm the applicable rate with your IOSS intermediary or customs broker.

Related Resources

Jet Worldwide

Canadian logistics provider for EU e-commerce, B2B shipping, IOSS integration, and CETA-qualified exports across all 27 member states.

EU destinations served: Germany, France, Netherlands, Spain, Italy, Belgium, Ireland, Poland, Sweden, Denmark, Austria, Portugal, Czech Republic, Finland, Romania, Hungary, Greece, and all remaining member states.

Last updated: May 28, 2026 | Reviewed by: Jet Worldwide Customs and Compliance Team | Content type: Regulatory update and editorial guide

Source: This article incorporates guidance from the Irish Revenue announcement of May 28, 2026 regarding new EU customs rules for e-commerce imports, as well as EU Regulation on customs reform for low-value consignments applicable across all 27 member states from July 1, 2026.

Get an EU Shipping Quote Contact Our Team Shipping Blog

Disclaimer: Information in this article is provided for general guidance only and does not constitute legal, customs, or tax advice. Always confirm current regulations with your customs broker, IOSS intermediary, or the relevant EU member state customs authority before shipping.

The 10% Section 122 Tariffs Just Got Struck Down. Here Is What Comes Next

Timothy Byrnes — Fri, 08 May 2026 18:33:07 GMT

Breaking — Trade Compliance-july 2026: Section 301 tariffs

Section 122 Tariffs Ruled Invalid

By Timothy Byrnes, Jet Worldwide | Published May 8, 2026 | 8 minute read

The short version

The Court of International Trade has struck down the 10 percent Section 122 tariffs that took effect February 24, 2026.
The court ruled that the President exceeded his authority by claiming a balance-of-payments emergency.
Importers have paid over20 billion dollars in these tariffs so far
An appeal to the Supreme Court is almost certain.
The CIT did not issue an injunction. The tariffs remain in place pending appeal.

This morning the Court of International Trade handed down a ruling that, if it survives appeal, will terminate the 10 percent Section 122 tariffs, which took effect February 24, 2026.

Did the President exceeded his authority when he claimed that a balance-of-payments emergency warranted invoking Section 122. On that question, the judges were direct.

"Nowhere does Proclamation No. 11012 identify balance-of-payments deficits within the meaning of Section 122 as it was enacted in 1974." — Court of International Trade ruling, May 2026

Section 122 of the Trade Act is a narrow, time-limited tool. It gives the President the ability to impose a temporary surcharge of up to 15 percent for a maximum of 150 days in response to a fundamental international payments problem. The court is saying that the proclamation did not meet the balance-of-payments deficit as defined in the statutory language. Just declaring one is not enough.

July 24, 2026 update

The 10% Section 122 tariffs fall on Friday, July 24. Still uncertain whether many of these get replaced with new Section 301 tariffs (of 10 or 12.5%) or if only Section 232 tariffs apply? But the US just announced a new round of potential tariffs (50% on some goods).

IEEPA to Section 122 to Section 301?

The executive branch of the US government remains committed to the application of tariffs. They are turning now to Section 301 tariffs which are more burdensome to apply but likely more durable to judicial review.

The likely (some say dubious)rational for implementing Section 301 tariffs are “unreasonable or discriminatory" practices of a country. The application can include a country having excess capacity beyond their domestic market.

How we got here — the timeline

February 24, 2026 The 10 percent baseline tariffs take effect under Proclamation No. 11012, with the administration citing Section 122 authority. This was done following the Supreme Court determining IEEPA tariffs to be invalid.
February to May 2026 Importers across thousands of HTS codes have paid billion dollars in Section 122 duties.
Spring 2026 Multiple lawsuits work through the Court of International Trade challenging the legal basis of the tariffs.
May 2026 The Court of International Trade strikes down the tariffs, ruling that Proclamation 11012 failed to identify a balance-of-payments deficit as Section 122 actually defines one.
Next 1 to 3 days An appeal to the Supreme Court is almost certain. The administration will likely seek a stay of the ruling pending that appeal, which would keep collections in place in the meantime.

Why this ruling matters

Two reasons, and they are unrelated to each other but equally important.

1. The precedent

This adds to a growing body of case law that the President's tariff-imposing power is narrow. The decision pushes future tariff action back toward the more traditional and durable mechanisms — Section 301 investigations, anti-dumping and countervailing duty proceedings, or actual congressional tax legislation. Each of those carries procedural rigour that broad presidential proclamations do not.

2. The refunds question

If the ruling holds on appeal, we are likely heading into another major refunds process for the +20 billion dollars already collected. Importers and their brokers have been able to secure refunds via CAPE for the IEEPA duties.

What importers should do now

Keep accurate records and await for a decision from the final appeal.

Start preparing regardless

Pull a clean report of every entry that paid Section 122 duty between February 24, 2026 and the date of the ruling. By tracking number, by HTS, by liquidation status.
Verify EIN and importer-of-record alignment in ACE for each. A mismatch will kill a refund claim faster than anything else.
Confirm none of the entries are tied to drawback claims, reconciliation flags, or active protest or litigation. Those are the categories CAPE rejects outright, and the Section 122 process will likely follow the same pattern.

The bigger picture

The IEEPA tariff cycle taught us how the refund process can work. CAPE works great but is unforgiving. Compliant entries have never mattered more than ever as the refund process is essentially another audit.

Frequently asked questions

What did the Court of International Trade actually rule?

The court ruled that the President exceeded his statutory authority when he invoked Section 122 of the Trade Act of 1974 to impose a 10 percent baseline tariff under Proclamation 11012. The judges held that the proclamation did not identify a balance-of-payments deficit as Section 122 actually defines one, so the legal basis for the tariffs failed.

What is Section 122 of the Trade Act?

Section 122 of the Trade Act of 1974 gives the President authority to impose temporary import surcharges of up to 15 percent for a maximum of 150 days to address a fundamental international payments problem. The authority is narrow, time-limited, and tied specifically to balance-of-payments emergencies as defined in the 1974 statute.

How much have importers paid in Section 122 tariffs?

Estimates suggest importers have paid over 20 billion dollars in Section 122 tariffs since the tariffs took effect on February 24, 2026. The tariffs were in place for 72 days before the Court of International Trade struck them down.

Will the tariffs continue during the appeal?

Likely yes, at least in the short term. The administration is expected to seek a stay of the ruling pending appeal, which would keep collection in place. Importers should not assume duty stops accruing on goods entering the United States until clearer guidance from CBP is issued.

Why might the administration pivot to Section 301 next?

Section 301 is a more administrative-law-driven tariff framework. It requires formal investigations, findings, and procedural steps that emergency-authority claims under Section 122 or IEEPA do not. But it still gives the Executive Branch substantial flexibility to adjust tariff rates up or down as a negotiating tool — without requiring the emergency-authority arguments that just failed at the Court of International Trade. Expect more reliance on Section 301 investigations to support tariff actions going forward.

How do importers claim refunds if the ruling stands?

Refunds would most likely flow through the CAPE submission process, which is the same system used for IEEPA tariff refunds. Protests are filed under 19 CFR 174 within the protest window. Accurate entry data, attestation by the importer of record, and clean documentation is necessary to secure a refund.

Should I file protests now or wait for the appeal?

Protest windows run on calendar deadlines from the date of liquidation, not from the date of any court ruling. Entries that liquidated early in the Section 122 period will hit their 180-day protest deadlines regardless of whether the appeal is decided. Coordinate with your customs broker and file protests as necessary.

What is CAPE?

CAPE is the refund process for processing IEEPA tariff refunds. It is the most likely vehicle if Section 122 refunds become a reality.

Get in touch

Timothy Byrnes
Jet Worldwide
Cross-border customs and international logistics specialist

Jet Worldwide | International Logistics, Customs Brokerage, and Trade Compliance |

This article is provided for general information and does not constitute legal or customs advice. Tariff regulations and court rulings change frequently. Consult a licensed customs broker or trade attorney before applying these analyses to specific shipments.

Shipping Aquaculture Samples to Canada: Cold-Chain Solutions

Timothy Byrnes — Sat, 25 Apr 2026 01:31:30 GMT

Aquaculture Logistics Cold Chain Sample Transport

Aquaculture operations across Mexico, South America, and the Caribbean routinely need to send tissue samples, water samples, and fish specimens to laboratories in Canada for disease testing, environmental analysis, and product quality verification. The transit time and cold-chain integrity requirements make this one of the more difficult sample-shipping challenges in the biological sciences. Here is how our transit routing with ice-pack refresh makes it work on common-carrier economics.

By Timothy Byrnes, Jet Worldwide | 7 min read | Published April 2026

Key Takeaways

Aquaculture sample shipments from Latin America and the Caribbean typically need to reach Canadian testing facilities within a 5 to 7 day window while maintaining a stable chilled temperature.
Direct routing via specialized medical couriers is effective but costs multiple times more than common-carrier alternatives.
A transit solution with ice-pack refresh maintains cold-chain integrity while using dedicated air options
Dry ice is usually not required for our routings

Inbound Transit

2 to 3 Days

To Montreal hub

Hub Handling

Same Day

Ice-pack refresh

Outbound Transit

Next Day

To Maritimes

Cost Profile

Common Carrier

Not specialty rates

In This Article

What aquaculture samples typically need to ship
The shipping challenge for tropical and sub-tropical origins
Transit cold-chain solution
How to pack aquaculture samples for this routing
Regulatory and documentation considerations
Common carrier versus specialty courier economics
Who benefits from this routing

What Aquaculture Samples Typically Need to Ship

Aquaculture sample shipping supports a narrow but critical set of scientific and commercial workflows. Companies operating fish farms, hatcheries, feed trials, and water quality programs across Latin America and the Caribbean routinely send the following types of shipments to Canadian testing facilities:

Tissue samples — muscle, liver, gill, or kidney tissue for histopathology, disease surveillance, genetic testing, or residue analysis.
Whole fish specimens — typically juvenile or sentinel fish preserved chilled or in fixative for diagnostic workups.
Water samples — for microbial, chemical, or environmental DNA (eDNA) analysis.
Blood and serum samples — for antibody titre, hematology, and immune-function studies.
Feed samples — for nutritional, mycotoxin, and contaminant analysis, often paired with tissue samples from fed fish.
Microbial cultures and swabs — for bacterial and viral pathogen identification.

Quick Answer

Most aquaculture samples ship at refrigerated (2 to 8 degrees C) temperatures, not frozen. Gel packs typically hold this range for 48 to 72 hours in a properly prepared insulated container.

The Shipping Challenge for Tropical and Sub-Tropical Origins

Aquaculture operations concentrated in Mexico, Honduras, Colombia, Ecuador, Brazil, and the Caribbean face a specific logistics problem when samples need to reach Canadian testing labs. Canada's leading aquaculture testing facilities are concentrated in Atlantic Canada — Prince Edward Island, New Brunswick, and Nova Scotia — which are geographically distant from every major air gateway serving Latin America.

A sample originating in, say, coastal Mexico or the Dominican Republic and destined for a Maritime Canada laboratory typically faces one of three shipping patterns:

Specialty medical courier direct. End-to-end temperature controlled service, generally 2 to 4 days, at premium pricing.
Common carrier direct to Atlantic Canada. Often 5 to 7 days with multiple transfers, and the gel-pack cold chain frequently fails before arrival.
Common carrier to a US or Canadian hub, then onward. The viable middle path if the hub can refresh ice packs and re-dispatch quickly.

Direct routing to Atlantic Canada on a common carrier is the pattern most operations try first and most often find inadequate. The transit time plus the number of handling touches means samples frequently arrive fully thawed and temperature excursions that invalidate the analysis.

The In-Transit Cold-Chain Solution

Jet Worldwide operates a two-leg routing specifically for this class of shipment. The solution works because receipt in a major Canadian gateway with more direct flight access from Latin American and Caribbean origins. Our facilities are set up to receive, refresh, and re-dispatch temperature-controlled shipments on the same day they arrive.

How the routing works

Origin pickup and inbound leg. Samples are collected at the origin (farm, hatchery, or testing lab) and shipped to Jet Worldwide via air freight or common express carrier. Typical transit from Mexico, Central and South America, and the Caribbean is 1 to 3 days.
Montreal arrival and inspection. On arrival at Jet Worldwide, the shipment is inspected, temperature is verified, and any necessary customs formalities are completed.
Ice pack refresh. Thawed or partially thawed gel packs are replaced with fresh pre-conditioned packs. The insulated shipper is re-closed and re-sealed. This typically happens within hours of arrival.
Outbound leg to Atlantic Canada. The refreshed shipment is handed via dedicated drives, air freight, or overnight express to laboratories in PEI, New Brunswick, or Nova Scotia.
Delivery and confirmation. The receiving laboratory confirms arrival with gel packs still cold and sample integrity intact.

Total end-to-end timeline typically from origin to Maritimes laboratory satisfy the need for lowest possible costs and temperature control.

Why Dry Ice Is Usually Not Needed

For standard chilled (2 to 8 degrees C) samples, the refreshed gel packs from our hubs hold temperature reliably for the outbound leg to Atlantic Canada. Dry ice is only required when the sample protocol demands frozen transport (minus 20 degrees C or colder), which applies to a minority of aquaculture sample types. Avoiding dry ice eliminates IATA dangerous-goods handling charges and simplifies carrier acceptance.

How to Pack Aquaculture Samples for This Routing

Packing quality at origin is a critical first step.

Recommended packing configuration

Use a quality molded insulated shipper. Expanded polystyrene (EPS) or polyurethane with a minimum wall thickness of 1.5 inches. Avoid thin styrofoam coolers.
Pre-condition gel packs for at least 24 hours in a freezer before packing.
Place gel packs above, below, and alongside samples. Typical ratio is at least 50 percent pack weight to sample weight. For a small tissue shipment, use four to six 500-gram packs.
Wrap samples in absorbent material with absorbent pads sufficient to contain the entire liquid volume if a container were to break. This is a regulatory requirement under IATA and Transport Canada for UN3373 Biological Substance Category B.
Use secondary watertight packaging such as sealable plastic bags or screw-top containers inside a rigid secondary container.
Include a temperature logger if the protocol requires documented cold-chain verification.
Label the outer packaging correctly.

Jet Worldwide can provide conditioned gel packs and IATA-compliant shippers for clients setting up a regular sampling program, which simplifies packing at origin.

Regulatory and Documentation Considerations

Aquaculture sample shipments into Canada intersect with several regulatory frameworks. The specific requirements depend on the sample type, the species, and the declared end use. Common considerations include:

CFIA import permits may be required for samples from certain species or regions, particularly where aquatic animal disease surveillance is in scope. The Canadian Food Inspection Agency administers these under the Health of Animals Act.
IATA Packing Instruction 650 governs most Biological Substance Category B (UN3373) shipments by air. Compliance is the shipper's responsibility, although carriers and brokers can advise.
CITES documentation may apply to samples from regulated species.
Commercial invoice and value declaration must identify the samples as non-commercial research specimens where applicable, with a nominal value declared for customs purposes.
Receiving laboratory authorization letter is often required by CBSA and CFIA to confirm the samples are destined for analytical testing rather than commercial distribution.

As a licensed Canadian customs broker, Jet Worldwide handles the CBSA clearance and coordinates with CFIA where required. For recurring sampling programs, we can establish standing clearance protocols that reduce the per-shipment documentation burden.

Common Carrier Versus Specialty Courier Economics

The cost difference between specialty medical couriers and common express carriers is the single most important driver for operations running regular sampling programs. Specialty couriers are engineered for end-to-end temperature control with dedicated handling, chain-of-custody documentation, and GxP-compliant workflows. This is the right choice for regulated clinical trials and validated pharmaceutical cold chain. For aquaculture samples where the protocol needs reliable chilled transport but not pharmaceutical-grade validation, the common-carrier routing via our hub delivers comparable temperature integrity at a lower cost.

Factor	Specialty Medical Courier	Jet Montreal Transit
Transit time	2 to 4 days	3 to 4 days
Cost profile	Premium	Common-carrier rates plus hub handling
Temperature control	Active, validated	Passive with hub refresh
Best fit	Clinical trials, GxP pharma	Research, surveillance, QC testing
Volume scalability	Limited	High

Cost comparison is directional. Exact pricing depends on origin, weight, frequency, and service options. Request a quote for a specific lane and volume.

Who Benefits from This Routing

The Montreal-transit cold-chain solution fits several categories of aquaculture operations:

Commercial tilapia, shrimp, and salmonid producers in Latin America running routine disease surveillance with Canadian reference laboratories.
Aquaculture technology companies developing fish health diagnostics, environmental monitoring systems, or feed additives who need to send validation samples to Canadian partners.
Hatcheries and broodstock operations sending genetic or health samples for third-party verification.
Research partnerships between Latin American universities and Atlantic Canada aquaculture research institutes.
Contract testing arrangements where a Canadian lab performs analytical services for international aquaculture clients on a recurring basis.

For any operation sending more than a handful of shipments per year on this lane, the cost savings versus specialty couriers compound quickly. Operations running weekly sampling programs can often recover the cost of an entire research project's logistics budget within a few months of switching routings.

Have a Sample Lane to Quote?

Tell us your origins, destinations, and typical volumes. We can map a routing, estimate transit, and provide a cost comparison against your current approach.

Request a Lane Review

Disclaimer: This article is for informational purposes only. Specific regulatory requirements for aquaculture sample imports to Canada depend on species, sample type, origin country, and end use, and should be confirmed with CFIA and a licensed customs broker. Transit times are representative and not guaranteed.

The Two-Leg Routing

🌎

Origin

Mexico / LatAm / Caribbean farm or lab

✈️

Leg 1: 2 to 3 Days

Common carrier to Montreal

🧊

Hub: Same Day

Jet Worldwide ice-pack refresh

🚚

Leg 2: Next Day

Overnight express to Maritimes

🔬

Destination

PEI / NB / NS laboratory

Frequently Asked Questions

How long does it take to ship aquaculture samples from Latin America to Canada?

Using the Montreal-transit routing, typical end-to-end transit is 3 to 4 business days: 2 to 3 days inbound, same-day ice-pack refresh, and next-day express to Atlantic Canada.

Do I need dry ice?

Usually not. For chilled samples (2 to 8 degrees C), refreshed gel packs hold temperature through the 24-hour outbound leg. Dry ice is only needed for frozen samples.

What documentation is required for CFIA and CBSA clearance?

Typically a CFIA import permit (depending on species), a commercial invoice identifying samples as non-commercial research specimens, and a receiving laboratory authorization letter. Jet Worldwide handles the CBSA clearance and coordinates with CFIA.

Is this routing cheaper than a specialty medical courier?

Yes, significantly. Specialty medical couriers are engineered for GxP pharma and clinical trials. For aquaculture research and surveillance, common-carrier rates via Montreal deliver comparable cold-chain integrity at a fraction of the cost.

What if a sample arrives warm?

The Montreal-transit design minimizes this risk by refreshing gel packs mid-journey. If a temperature excursion occurs, we work with clients to review packing configuration, transit routing, and carrier handling to prevent recurrence.

Origin	To Montreal	End-to-End to Maritimes
Mexico City, Mexico	2 days	3 to 4 days
Santo Domingo, DR	2 days	3 to 4 days
Bogota, Colombia	2 to 3 days	4 days
Guayaquil, Ecuador	3 days	4 to 5 days
Sao Paulo, Brazil	3 days	4 to 5 days

IEEPA Tariffs Paid Through DHL, FEDEX, UPS Part 128 Informal Entries

Timothy Byrnes — Thu, 23 Apr 2026 19:34:27 GMT

Trade Compliance IEEPA Refunds Small Business

Express carrier shipments (imports via FedEx, UPS, and DHL) under USD 2,500 rarely make the headlines. However, during the eleven months of IEEPA tariffs, they carried a meaningful share of the duty bill — mostly paid by individuals and small businesses.

By Timothy Byrnes, Jet Worldwide | 8 min read | Updated April 2026

Key Takeaways

IEEPA tariffs were collected from March 2025 through 24 February 2026. Roughly USD 166 to 175 billion was collected across all entry types.
Informal entries under 19 CFR Part 128 covered most FedEx, UPS, and DHL imports valued at USD 2,500 or less.
The importer of record on an express informal entry is the ultimate consignee, not the carrier.
Informal entries liquidate at clearance, which complicates the refund path for previously paid IEEPA duty.
Phase 1 of CBP's CAPE refund system does not currently address informal entry refunds.

IEEPA in Force

~11 Months

Mar 2025 to Feb 2026

Total Collected

USD 166 to 175B

All entry types

Informal Entry Cap

USD 2,500

19 CFR 128.24(a)

Refund System

CAPE Phase 1

Live since 20 Apr 2026

In This Article

What Part 128 actually covers
How IEEPA applied on an informal entry
Estimating the informal entry share
Who was the importer of record
What the Supreme Court ruling changed
Refunds on informal entries
What the ACH system is
What happens now

What Part 128 Actually Covers

19 CFR Part 128 is the CBP framework governing express consignment operators and carriers. It covers the hub operations run by FedEx, UPS, DHL, plus a few independent facilities (IBC, Micom). Under 128.24(a), informal entry procedures are generally used for non-restricted shipments not exceeding USD 2,500 in value. These shipments are most often consolidated on a single entry. The entry is filed on CBP Form 3461 or its electronic equivalent, with the advance manifest serving as a supporting document.

This was the "de minimis" workhorse for individual parcels shipping into the United States. Before the de minimis suspension took hold in August 2025, a large share of these parcels cleared duty-free under Section 321. Once de minimis was suspended for all countries, an informal entry was used for most imports under USD 2,500.

Quick Answer

Most FedEx, UPS, and DHL shipments valued at USD 2,500 or less clear as informal entries under 19 CFR Part 128. The carrier filed on behalf of the consignee. The carries are expected to refund IEEPA duty of informal entries directly to the person or entity through which the initial payment was made. Most informal entries are not part of Phase 1.

NOTE: We will continue to update this post as information on the next phase of IEEPA refunds becomes available for duty paid via FedEx, UPS, and DHL.

READ ABOUT IEEPA REFUNDS VIA CAPE →

The headlines have mostly involved large importers such as Toyota, Costco, Elizabeth Arden, and Reebok who proactively filed suit in the Court of International Trade. But there are thousands of small businesses who have paid anywhere from a couple hundred dollars to tens of thousands of dollars in IEEPA tariffs. Many of these goods arrived via FedEx, UPS, and DHL.

The complicating part is that most of these imports qualified as informal entries. The carriers made entry on behalf of the consignee. And these entries are typically not individual entries but are consolidated with thousands of other shipments. In other words, there is not a single entry number attached to each waybill. Rather, there is one entry linked to thousands of individual shipments.

The other complicating part is that the refund itself is issued via the ACH payment system. Most companies who receive goods via FedEx, UPS, and DHL do not have an ACH refund account set up.

How IEEPA Applied on an Informal Entry

There was nothing special about IEEPA via an informal entry. The same rules applied. The Chapter 99 headings — 9903.01.25 for China, 9903.01.10 for Canada, 9903.01.01 for Mexico, and the reciprocal tariff headings for other origins — were reported on the entry like any other ad valorem duty. The rates stacked on top of the standard MFN (column 1) rate plus other section tariffs such as Section 301 and Section 232.

What makes express informal entries distinctive is that carriers can make an entry on behalf of the consignee without securing authorization to do so. For formal entries, by contrast, a power of attorney is required.

Informal Entries and IEEPA Refunds: Three Issues to Know

1. Nominal Consignee versus Importer of Record

The nominal consignee designation exists in Part 128 for scenarios where the US-based party shown on paperwork is the carrier, forwarder, or consolidator itself, not the ultimate buyer. In that case, a carrier's IRS EIN can appear on the entry, but this is for manifest identification, not IOR status.

2. Informal Entries Liquidate Immediately

Under 19 CFR 159.10(a), the effective date of liquidation for an informal entry is the date of duty payment or the date of release. Nearly every informal entry that paid IEEPA duty was already finally liquidated by the time the Supreme Court ruled. A Court of International Trade (CIT) amendment issued 27 March 2026 extended refund relief to finally-liquidated entries. This extension may be challenged on appeal.

3. Delivery Duty Paid (DDP) Shipments

Under DDP terms, the commercial arrangement often has the shipper outside the USA paying the IEEPA duty along with other import charges. This does not change who CBP records as the IOR on the entry. The duty-payer and the IOR are legally distinct. For the purposes of CBP, the consignee remains liable for compliance even on DDP shipments. DDP terms apply to formal entries as well but are much more common on lower-value imports for product samples and warranty parts.

Representative Duty Math on Typical Informal Entries

Origin and Tariff Type	Declared Value	IEEPA Rate	Duty Paid
China (fentanyl plus reciprocal)	USD 500	30%	USD 150.00
Canada (non-USMCA)	USD 1,200	25%	USD 300.00
EU (reciprocal)	USD 900	15%	USD 135.00
Vietnam (reciprocal)	USD 2,200	20%	USD 440.00

Rates shown are representative of peak periods during the IEEPA window. Actual rates varied over time as executive orders were amended and country-specific pauses took effect.

Estimating the Informal Entry Share

CBP does not publish a clean breakdown of IEEPA duties by entry type, so actual figures are not known.

Informal entries account for a minority of duty dollars but a large share of entry count. The bulk of IEEPA collections sat on formal entries clearing full commercial shipments.
After August 2025, when de minimis was suspended, express informal entries absorbed hundreds of millions of parcels per month that had previously cleared on a manifest.
Assuming informal entries represent roughly 3 to 5 percent of IEEPA duty dollars, the range lands at approximately USD 5 billion over the eleven-month window.

Average Declared Value

The estimated average value of Section 321 de minimis entries was only around USD 40. However, many of these were imported with under-declared values and, in any case, lost their duty-free status when de minimis was suspended. Courier-classified B2C shipments and B2B replenishment parcels for commercial consignees likely resulted in a higher average declared value, but the exact number is not known.

Who Was the Importer of Record

This is the part that trips up a lot of importers, and it matters enormously for the refund process. On an express informal entry, the importer of record is the ultimate consignee — the business or person in the United States to whom the goods are consigned. The express carrier is not the IOR even if their identification number is used as a header on the consolidated entry.

19 CFR 143.26 governs who may make entry on an informal shipment:

The parties eligible to enter are the owner, the purchaser, or the consignee of the goods. On an express informal entry, the carrier is almost never the owner or purchaser, so by default the ultimate consignee fills the IOR role.

What makes express carriers look like the IOR is a separate mechanic: the carrier is the entry filer acting as a customs broker. FedEx, UPS, and DHL each hold customs broker licenses and file the CBP Form 3461 on behalf of the consignee using their own filer code. In ACE, the entry shows the carrier's broker as the filer, but the IOR field carries the consignee's name, US address, and IRS employer ID number, SSN, or CBP-assigned number.

ACE — Automated Commercial Environment: The US customs electronic system used by customs brokers for processing of import entries.

How the IEEPA Line Appears on Carrier Invoices

IEEPA duties on express informal entries were billed to the consignee on the carrier's duty and tax invoice, typically ten to twenty business days after delivery. The IEEPA portion is identifiable on carrier duty invoices by the Chapter 99 HTS reference (9903.xx.xx) alongside the MFN classification. In some cases, mostly with respect to imports via UPS, the details of the entry are not always provided.

What the Supreme Court Ruling Changed

On 20 February 2026, the Supreme Court held IEEPA tariffs to be invalid. Duties were no longer charged beyond 24 February 2026. A Section 122 surcharge was imposed almost immediately under separate authority, so shipments entering the US today still incur additional duty beyond the standard MFN rate. The IEEPA line is gone, and tariffs paid under this authority are now starting to be refunded for formal entries to importers with an ACH refund account on file.

Refunds on Informal Entries: What to Expect

Phase 1 of CBP's Consolidated Administration and Processing of Entries (CAPE) system is active. CBP pushes refunds via ACH to the importer's bank details on file. However, Phase 1 does not currently address refunds on informal entries. Phase 2 is expected to extend the process.

Most consignees on express informal entries, particularly small businesses and individual consumers, never registered an ACH account with CBP because they never expected to be treated as an importer of record. The express carrier handled everything. Consignees will need to sign up for electronic refunds, as CBP no longer issues paper checks.

A further complication: when the shipper paid the duty under DDP terms through the carrier's account, the commercial reality is that the shipper absorbed the cost, not the consignee. But the refund goes to the IOR, which is the consignee. How shippers recover duty they effectively paid on behalf of their customers is a commercial question between the parties, not a CBP question.

What the ACH System Is

Automated Clearing House (ACH) Refund from CBP

ACH is the CBP payment system for duty payments and refunds. As of 6 February 2026, CBP no longer issues paper checks. Enrolment is completed through the ACE Portal. ACH Debit enrolment uses CBP Form 400, and ACH Credit enrolment uses CBP Form 401.

How to Enrol in ACH Refunds with CBP

Confirm your CBP Form 5106 record. This is the importer identity record CBP needs before any portal access works.
Create an ACE Portal account. Apply for an account tied to your 5106 record, with the Importer sub-account view enabled.
Authorize ACH refund in ACE. Provide a US bank account routing and account number along with your TIN, SSN, or CBP-assigned number.
Verify by email. CBP sends a verification code to the email address on file in your 5106 record. Coordinate with whoever owns that inbox.

What Happens Now for Informal Entries

There is an expectation that IEEPA refunds will eventually be applied for informal entries through Phase 2 of CAPE. For businesses using express informal entries, the action now is to record what was paid, confirm your importer identity record, and prepare the bank details of a US-based account that can be linked to ACH.

Practical Next Steps

Pull carrier duty invoices from March 2025 through February 2026, isolate the Chapter 99 IEEPA lines, and keep that reconciliation in a format you can produce on demand.
Confirm your business is registered with CBP as an importer (CBP Form 5106) and that ACH refund details are on file.
If you imported under DDP terms and your shipper absorbed the duty, document the commercial arrangement now in case a refund reconciliation is needed.
Monitor CSMS messages and your carrier's communications for CAPE Phase 2 filing instructions.

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Disclaimer: This article is for informational purposes only and does not constitute legal or customs brokerage advice. Specific entry, refund, and recovery strategies should be confirmed with a licensed customs broker or trade counsel based on the facts of your shipments.

Frequently Asked Questions

Who is the importer of record on an express carrier informal entry?

On an express informal entry under 19 CFR Part 128, the importer of record is the ultimate consignee. This is governed by 19 CFR 143.26. The express carrier is the filer of record, acting as a licensed customs broker, but is not the IOR.

Do informal entries liquidate immediately?

Yes. Under 19 CFR 159.10(a), the effective date of liquidation for an informal entry is the date of duty payment or the date of release. Unlike formal entries, which liquidate on a roughly one-year cycle, informal entries liquidate at clearance.

How will IEEPA refunds be distributed on informal entries?

CBP issues refunds via ACH to the importer of record on file. Phase 1 of CAPE launched 20 April 2026 but does not currently address informal entry refunds. Phase 2 is expected to extend the process. We expect consignees will have to enrol in ACH refunds through the ACE Portal.

How do I identify IEEPA duty on a FedEx, UPS, or DHL invoice?

IEEPA duty appears on carrier invoices as a Chapter 99 HTS reference in the format 9903.xx.xx, alongside the article's primary MFN classification.

Who receives the refund on a DDP shipment?

CBP refunds the importer of record, which is the consignee, not the shipper. If the shipper paid duty under DDP terms, recovering that amount from the consignee is a commercial matter between the parties.

Updated 23 April 2026 — CAPE Phase 1 is now live

In This Article

What Part 128 actually covers
How IEEPA applied on an informal entry
Estimating the informal entry share
Who was the importer of record
What the Supreme Court ruling changed
Refunds on informal entries
What the ACH system is
What happens now

Summary

Between March 2025 and February 2026, IEEPA tariffs were collected on most FedEx, UPS, and DHL shipments entering the United States at or below USD 2,500. These cleared as informal entries under 19 CFR Part 128, with the ultimate consignee recorded as the importer of record. After the Supreme Court invalidated IEEPA on 20 February 2026, CBP began refunds through the CAPE system, but Phase 1 does not yet cover informal entries. Consignees must register for ACH refunds through the ACE Portal in preparation for Phase 2.

Timothy Byrnes

Logistics Specialist, Jet Worldwide

Timothy runs Jet Worldwide, an international logistics support company. His work spans cross-border Canada-US and international shipping, HTS classification, USMCA compliance, and trade policy analysis.

IEEPA Refund Using CAPE

Timothy Byrnes — Wed, 15 Apr 2026 12:56:15 GMT

$165-175B Total Refunds

330,000 Affected Importers

53M+ Entries Filed

April 20 CAPE Launch Date

Key Takeaway: The CAPE system launches April 20, 2026. Most importers think they are preparing for a refund. They should be preparing for a review. CAPE is not a payment tool. It is a review engine with a refund function attached.

Background: The Supreme Court Ruling That Started It All
What CAPE Actually Does
CAPE Filing Guidelines
CAPE Error Messages
The Review Engine No One Is Talking About
The Real Risk: What Happens When Your Data Does Not Tie
The Day One Bottleneck (not so bad!)
Fedex, UPS, DHL IEEPA Refunds
Beyond Refunds: The Enforcement Horizon
What Canadian Exporters and US Importers Should Do Now
IEEPA and CAPE Refund FAQs

The result of the Supreme Court's decision*, an estimated $165 to $175 billion in unlawfully collected duties must be returned to roughly 330,000 importers across more than 53 million entries. The Court of International Trade directed CBP to begin processing refunds, and CBP responded by building a purpose-built system called CAPE -- the Consolidated Administration and Processing of Entries -- inside its Automated Commercial Environment (ACE) portal.

Summary: US Customs has defined a way to secure refunds for IEEPA tariffs. The refunds will be paid to the importer of record and managed via the same customs systems through which the duties were processed. Definitions to know.

What is most unclear is how "Express Carriers" (FedEx, UPS and DHL) will manage IEEPA refunds.

UPDATE: The First Day of CAPE was largely a success!

CBP Confirms CAPE Is Working: Inside the April 28 Court Filing

The first sworn accounting of CAPE Phase 1 performance, straight from the U.S. Court of International Trade docket.

On April 28, 2026, U.S. Customs and Border Protection (CBP) filed a declaration with the U.S. Court of International Trade. This provided the first official accounting of how CAPE refund tool has performed since its April 20 launch.

The numbers tell a clear story of a system that is working.

Phase 1 Launch — The Numbers

On launch day (April 20, 2026) ACE recorded a nearly 70 percent increase in daily log-ins compared with its previous all-time record.

CAPE Phase 1 — First Six Days

CBP figures as of 8:00 p.m. ET, Sunday, April 26, 2026

CAPE declarations submitted	75,306
Declarations that passed file validations	47,315
Entries accepted for IEEPA duty removal	11,222,927
Entries already liquidated and in refund pipeline	~1,740,000
Entries rejected at entry-specific validation	2,124,394
Total downtime since launch	18 minutes

What the Numbers Mean

The volume is enormous. More than 11.2 million individual entries cleared CAPE's entry-specific validations in the first six days.

Refunds are actually moving. Roughly 1.74 million entries — about 15.5 percent of the accepted pool — have already been liquidated and entered the formal refund pipeline.

Rejections are real, but recoverable. Roughly 2.12 million entries failed entry-specific validation — close to one in six. Importers (or their brokers) can resubmit corrected declarations.

System Reliability

The only interruption since launch was an 18-minute pause on April 20, during which CBP briefly reconfigured resources to optimize processing capacity. The uptime record of +99.9% percent over the first six days is proof that CAPE is running strong.

Source

*Supreme Court Background: The Supreme Court's landmark 6-3 ruling in Learning Resources v. Trump on February 20, 2026 determined that the International Emergency Economic Powers Act (IEEPA) was not a valid basis for imposing tariffs. The Court held that the IEEPA's broad "regulate" language does not convey taxing authority via tariffs.

What is CAPE: Consolidated Administration and Processing of Entries (CAPE) is the refund process built within the ACE Portal. CAPE is not a payment tool. It is a review engine with a refund function attached.

Phase 1 is limited to certain unliquidated entries and certain entries that are no more than 80 days past liquidation.

On the surface, the process looks straightforward: upload a CSV of entry numbers, wait 60 to 90 days, receive your refund electronically via ACH. But trade compliance professionals who have studied the mechanics of the system are sounding alarms.

What Are IEEPA, CAPE, ACE, ACH and Liquidation? The Key Systems Behind US Tariff Refunds

IEEPA DUTY: International Emergency Economic Powers Act: Import duty collected between March 2025 and February 24, 2026 ruled unlawful.
CHAPTER 99 TARIFFS: The section of the US Harmonized Tariff Schedule (HTS) used to charge IEEPA tariffs. This section exists specifically for such temporary or special tariff measures.
ACE -- Automated Commercial Environment: The US customs electronic system used by customs brokersfor processing of import entries.
CAPE -- Consolidated Administration and Processing of Entries:The refund system in ACE purpose built to manage IEEPA tariffs refunds.
ACH -- Automated Clearing House: The electronic funds transfer network through which CBP disburses all refunds, including IEEPA duty refunds processed through CAPE. As of February 2026 all CBP refunds are electronic.
Liquidated Entry: The liquidation process is the period - usually around 10 months - between the entry date and when CBP finalizes an entry. Importers usually then have a 180-day window to flag any issues or disputes with the finalized tariff bill. Most entries with IEEPA tariffs have either not been liquidated or within 80 days of liquidation. (Under 19 CFR Part 159, liquidation is the final determination of duties based on tariff classification, value, origin and admissibility.)

CAPE Phase 1 Is Live: What to File and When

Importers of record and licensed customs brokers may now file CAPE Declarations through ACE.

Quick Answer

Phase 1 covers entries that are either unliquidated or were liquidated less than 80 days before the date the Declaration is submitted. The filing vehicle is a CSV file of entry numbers, submitted through ACE.

Steps to Prepare for an IEEPA Refund

Consider, but do not rush into, a CIT filing. Some importers with large exposure have filed protective actions at the Court of International Trade. The CIT Orders purportedly apply to litigants and non-litigants alike (so even if you do not file, you can benefit from the decision). For most small importers a costly CIT filing is not practical.
Create an ACE importer account if you do not already have one. This is the prerequisite for everything that follows.
If you have an ACE account but have not logged in within the past 45 days, contact ACE Support immediately. Dormant accounts deactivate and must be reactivated before you can file. ACE Support runs 24/7.
Enrol in ACH refunds inside the ACE Portal using a US bank account. CBP no longer issues paper checks. Refunds flow only via ACH. How refunds for FedEx, UPS and DHL informal entries will be managed is not clear.
Pull an ACE report of all entries with IEEPA duties paid. Cross-reference the liquidation dates and flag any entries that error out. These become the raw data for your CAPE Declaration.

Filing a Phase 1 CAPE Declaration

A Phase 1 CAPE Declaration is a CSV (comma-separated values) file containing only entry numbers. Two conditions must be met for each entry included:

IEEPA duties were paid on the entry.
The entry is either unliquidated, or was liquidated less than 80 days before the Declaration submission date.

Important for Informal Entry Holders

Informal entries liquidate at clearance under 19 CFR 159.10(a). This means virtually every informal entry that paid IEEPA duty during 2025 is now far outside the 80-day window required for Phase 1. Small importers and consumers who received goods via FedEx, UPS, or DHL will most likely need to wait for Phase 2 of CAPE, which is expected to extend refunds to finally-liquidated entries. The preparation steps above still apply — having your ACE account, ACH enrolment, and duty-paid reconciliation ready now means you can file as soon as Phase 2 opens.

For importers with recent formal-entry exposure that falls inside the 80-day window, Phase 1 is worth acting on now. The CSV itself is simple, but the preparation — confirming IOR status, cleaning entry data, and resolving ACE errors — takes time.

What CAPE Actually Does

CBP has described CAPE as having four integrated components:

Claim Portal

Importers or their authorized brokers upload a CSV file listing entry numbers (up to 9,999 per declaration). The system validates the file format, confirms the filer's authorization, and checks each entry number against ACE records.

Mass Processing

For validated entries, the system strips the IEEPA-specific Chapter 99 HTS codes, removes the corresponding duties, and recalculates what is owed without IEEPA. This creates a new version of the entry summary inside ACE.

Review, Liquidation, and Re-liquidation

CBP reviews the updated entries and initiates liquidation (for unliquidated entries, scheduled 45 days from acceptance) or reliquidation (for recently liquidated entries within the 80-day window).

Refund Processing

After liquidation, refunds are consolidated by importer of record and liquidation date, then disbursed electronically through ACH.

The critical distinction is in the third step. The real process is not "upload then refund." It is "upload, then review, then liquidation or reliquidation, then refund."

Understanding Error Messages in CAPE

Importers are started to question error messages in CAPE. The error codes provide information necessary to fix the problem.

The early system-driven ones were driven by high volume. Message "not started" is not a failure but rather informing the user that the batch is in queue. In this case, resubmitting is the wrong move because it creates duplicate filings.

Errors like "unable to calculate duty" or entries flagged as under review, suspended, or unfindable mean CBP isn't ready to touch the entry yet and CAPE won't override that.
The more serious ones are the tariff construction errors — no valid IEEPA Chapter 99 line. This occur occurs when the chapter 99 number isnot aligning with the underlying HTS, or 9903.03 Section 122 codes showing up where they don't belong. This indicates an incorrect entry.
Errors saying the entry can't be found, doesn't match your account, or fails batch validation usually trace to EIN mismatches, entry number formatting, or the wrong filer submitting. If you're not the recognized party tied to that entry in ACE, you don't get the refund.
Then there are the hard stops: entries that are finally liquidated, tied to drawback, flagged for reconciliation, or under protest or litigation will be rejected outright. Two specific codes are already repeat offenders — Error 864 effectively locks your submission once accepted (no PSC cleanup afterward, so what you submit is what you're stuck with), and inactive ACE account errors mean you can't play at all until reactivation.

See US CBP CAPE Messaging Definitions

CAPE Filing Guidelines for IEEPA Tariff Refunds

Key System Requirements

Filing Authorization

Only the Importer of Record (IOR) or the broker who filed the original entry may submit CAPE Declarations. No third parties are authorized to request these refunds.

Account Prerequisites

Filers must maintain an active ACE Portal account and complete ACH enrollment with current banking information before any refunds can be processed.

File Format

CSV uploads should contain only entry numbers (without dashes) and filer codes.

Filing Process and Timing

System Availability

CAPE filing became available on April 20, 2026, accessible through a tab in the ACE Portal.

No Filing Deadline

Unlike Post Summary Corrections (PSC), CAPE has no submission deadline. PSC cannot be used for IEEPA refunds. New ACE Entry Summary Error Code
Condition Code: 864: PSC NOT ALLOWED – REFUND REQUESTED
Explanation: PSC is not allowed due to a CAPE Refund in process

Error Handling

Individual entry rejections will generate error codes but will not halt processing of remaining valid entries. Corrections and resubmissions are permitted.

Refund Processing Details

Processing Schedule

Refunds are processed Monday through Thursday with expected completion within 60 to 90 days of CAPE Declaration acceptance, unless compliance reviews are required.

Batching Method

Refunds are consolidated by liquidation (or reliquidation) date and grouped by IOR or CBP Form 4811 designee. A PSC can be filed to modify the 4811 party if needed.

Interest Calculation

Interest accrues from the liquidation date, not the entry date.

Payment Method

All refunds are issued electronically via ACH to the designated bank account registered in the ACE Portal.

Special Considerations

Litigation Cases

Importers with pending Court of International Trade (CIT) cases may still file through CAPE.

Compliance Period

The 80-day compliance review period includes calendar days, not business days.

Legal Compliance

All refunds will be issued in accordance with applicable laws and any relevant court orders.

The Review Engine No One Is Talking About

Trade professionals who have been tracking the CAPE development through court filings and CBP declarations from Brandon Lord, Executive Director of Trade Programs at CBP. The features that reveal CAPE's intent to only refund correctly admited entries.

Scenario-Based Testing

CBP has been conducting intensive testing across the four CAPE components. Stress-testing how the system handles entries where the data does not align cleanly -- mismatched classifications, inconsistent country of origin declarations, or duty calculations that do not reconcile.

Manual Processing for AD/CVD Entries

Entries subject to antidumping or countervailing duties are excluded from Phase 1 automation entirely. When they are eventually processed, it is expected to be a much more manual process. For importers with complex duty structures, this is a probably something to expect.

Workload and Resource Constraints

CBP has been candid with the Court about the operational challenge. The agency is not going to review every single entry with the same intensity. Instead, the system is designed to flag entries that warrant closer examination -- the ones that look worth reviewing.

A Centralized Audit Trail Inside ACE

Every CAPE claim, every adjustment, every recalculation, and every decision is now recorded in one place. CBP has not characterized this as an audit mandate. But it is a system that evaluates claims before money is refunded.

CAPE is essentially an audit of the original entry with a refund function.

The Real Risk: What Happens With Data

The CSV upload starts the entire process. The complexity begins once ACE starts recalculating your entries without IEEPA duties.

When the system strips the IEEPA Chapter 99 codes, it does not just reduce your total. It recalculates the entire entry through ACE's standard validation logic -- the same logic that reviews every commercial entry filed in the United States. That means your HTS classifications, your declared values, your country of origin determinations, and your duty calculations are all exposed to fresh scrutiny.

Importers with clean entries and accurate classifications should move through the process without incident. But those who may have used IEEPA tariff codes to sidestep obligations under other programs -- Section 232 steel and aluminum duties, Section 301 China tariffs, or country of origin requirements -- face real exposure.

Social Media Comment from a licensed customsbroker: "The portal process is relatively straightforward. You submit the required information, and if something needs to be corrected, it is returned for revision and resubmission. That is very different from the idea that you only get one chance and need extensive paid help just to avoid losing the refund."

One trade expert put it bluntly: if CBP catches incorrect tariff classifications where importers were paying IEEPA to avoid 232, 301, or proper country of origin determinations, the consequences extend well beyond a delayed refund.

Each piece of data submitted through CAPE flows into ACE, where it runs against audit criteria that CBP has been building and refining for years. CAPE uses ACE internal tools to flag anomalies and concerns on entries. Newly recalculated entries will undergo the same data reviews.

Uploading into CAPE, Verify the following data is correct:

* The country of origin

* The HTS classification(not just the product HTS but the 99's as well).

* The declared value is correct (Taking deductions for transportation and insurance?)

* There are no material omissions or false statements

The Day One Bottleneck

Beyond compliance risk, there is a practical operational concern that is not getting enough attention: System capacity! But the initial reports are encouraging.

There is no advantage to being first in line if the system is overwhelmed. A measured approach -- ensuring data quality before uploading -- will serve importers far better.

The Carrier Question: How Millions of FedEx, UPS, and DHL Entries Will Be Managed

There is a massive category of IEEPA-affected entries that is not getting enough attention in CAPE discussions: the millions of shipments where FedEx, UPS, or DHL acted as the Importer of Record.

The IEEPA Refund Process for Express Consignment Shipments (CFR Part 128) are not clearly defined

Imports cleared via an informal entry (under $2,500): FedEx, UPS and DHL acted Importer of Record
Imports cleared with a Power of Attorney given to FedEx, UPS and DHL (many such importers are not registered for ACH).

Throughout the IEEPA tariff period -- roughly March 2025 through February 24, 2026 -- these carriers collected and remitted IEEPA duties on behalf of shippers and consumers across millions of transactions. The question of how those duties get returned to the people who actually paid them is layered. This includes how each entry was filed, conditions of carriage, and contractual obligation.

Three Categories, Three Different Refund Paths

Not all carrier-handled entries are the same. The refund path depends on the filing relationship and entry type:

Carrier as Customs Broker Only

Where the shipper or consignee was listed as the Importer of Record and the carrier acted only as the customs broker, the refund responsibility falls on the IOR. The IOR (or their broker) files the CAPE Declaration.

Carrier as Importer of Record (Formal and Informal Entries)

Where the carrier itself was listed as the IOR on formal or informal entries filed in ACE, the carrier must file the CAPE Declaration and receive the CBP refund.

Section 321 and De Minimis Entries Without Entry Summaries

Usually duty free so not affected by IEEPA

What Each Carrier Has Said

FedEx has publicly committed to issuing refunds for IEEPA tariffs paid to shippers and consumers who originally bore those charges. FedEx has also filed its own lawsuit in the Court of International Trade seeking a full refund of all IEEPA duties it paid as IOR.

DHL has stated it will continue to engage with relevant authorities for entries where it acted as IOR -- whether formal or informal -- but has not committed to a specific pass-through timeline or mechanism.

UPS has focused its public guidance on advising importers to ensure their ACE Portal access and ACH are current. UPS has noted that Non-Resident Importers unable to provide NACHA-compliant US bank details can designate UPS Supply Chain Solutions as the notify party for refund handling.

The legal pressure is real. Multiple class action lawsuits have already been filed against both FedEx and UPS in federal courts across the country. The customs law is clear: The refunds go to the importer of record. The issue for FedEx, UPS and DHL relate more to contract law.

Post-suspension low-value entries (after de minimis was suspended through February 24, 2026): Once the de minimis exemption was removed, shipments that previously cleared duty-free were forced into informal (Type 11) or formal (Type 01) entry processes. IEEPA duties were collected on these entries, and the carriers typically served as IOR or broker. These entries should have entry summaries in ACE and should be CAPE-eligible -- but the carriers need to file the CAPE Declarations.

Non-ABI entries with no entry summary lines in ACE: CBP has explicitly identified this as a category deferred to future CAPE phases. Some entries processed outside standard ACE channels -- including certain postal entries and legacy manifest clearances -- may lack the data structure that CAPE requires. The Court of International Trade has also specifically noted that its refund order does not address de minimis treatment under 19 U.S.C. Section 1321, which is the subject of separate litigation.

The Pass-Through Problem at Scale

Even where the CAPE mechanics work -- where the carrier files the declaration, CBP processes the refund, and the money flows to the carrier via ACH. Consider the scale of FedEx, UPS, and DHL who processed millions of IEEPA-dutiable shipments. Each shipment was invoiced to an individual recipient or business. Reconciling those invoices, matching refund amounts to individual transactions, and distributing credits or payments across that volume is a significant IT, accounting, and customer service undertaking.

If a Carrier Collected IEEPA Duties on Your Behalf

✓

Preserve All Shipping Invoices and Receipts

Retain every invoice showing IEEPA tariff charges, import duty fees, customs fees, or tariff-related surcharges from FedEx, UPS, or DHL for shipments between March 2025 and February 24, 2026. Look for line items labeled "customs duty," "tariff surcharge," or "IEEPA fee."

✓

Determine Your Filing Relationship

Were you listed as the Importer of Record, or was the carrier? If you were the IOR, you (or your broker) need to file the CAPE Declaration. If the carrier was the IOR, the carrier must file and then pass the refund through to you.

✓

Contact Your Carrier Directly

Ask your carrier what their specific plan is for filing CAPE Declarations and returning refunds. FedEx has established dedicated support lines for tariff refund inquiries. Get a commitment in writing if possible.

✓

Monitor Class Action Developments

Multiple class action lawsuits have been filed against carriers seeking refunds of IEEPA duties and associated processing fees. If you paid significant IEEPA charges through a carrier, you may be a potential class member. Keep records organized in case they are needed.

✓

If You Are a Business IOR, Act Independently

Do not wait for a carrier if you were listed as the IOR on formal entries. Confirm your ACE Portal access, verify your ACH enrollment, and prepare your own CAPE Declaration for eligible entries.

Why This Matters for the Broader CAPE Process

The carrier-as-IOR issue is not a footnote. Express carriers handle a substantial share of all US import entries by volume. When FedEx, UPS, and DHL file CAPE Declarations for entries where they served as IOR, those filings will represent millions of entry numbers flowing into a system already processing claims from 330,000 individual importers. The processing burden -- on CBP, on ACE, and on the carriers themselves -- is enormous.

For Canadian exporters shipping to US customers through express carriers, this has direct implications. If your US buyers received goods through FedEx, UPS, or DHL during the IEEPA period and the carrier was listed as IOR, the refund path runs through the carrier. Your buyers should be in contact with the carrier to understand timing and mechanics.

The bottom line: CAPE was designed around the traditional IOR-broker relationship. The carrier-as-IOR model -- particularly at the scale of millions of parcel and low-value entries -- is a layer of complexity that neither CAPE nor the carriers have fully solved yet.

Beyond Refunds: The Enforcement Horizon

The compliance community is also watching for longer-term consequences. Several legal experts have noted that the CAPE process could generate referrals for formal audit activity or even enforcement actions.

Refund claims of this magnitude will attract scrutiny. Large-scale recovery efforts tied to a high-profile Supreme Court decision are precisely the kind of activity that draws focused reviews. Companies that proactively validate their import practices and documentation will be far better positioned than those who treat CAPE as a simple administrative exercise.

Some attorneys have raised the possibility that the review process could eventually feed enforcement through mechanisms like the False Claims Act, particularly where refund claims are found to rest on inaccurate underlying data. The key shift in thinking is that refunds trigger scrutiny, not closure. The process does not end when money moves -- it starts there.

As one observer noted, this is CBP's opportunity to demonstrate that its audit capabilities can identify discrepancies efficiently. The agency has been investing in auditors and data analytics for years. CAPE gives them a structured, centralized dataset to work with.

What Canadian Exporters and US Importers Should Do Now

For businesses shipping goods into the United States -- including Canadian companies managing US import compliance -- the action items are clear:

Pre-Filing Action Checklist

✓

Confirm ACE Portal Access and ACH Enrollment

CBP no longer issues paper refund checks. All refunds are electronic. If your banking information is not on file in ACE, your refund will sit in reject status until it is. As of late March, roughly 78 percent of affected importers had completed ACH enrollment.

✓

Audit Your Entries Before You File

Do not submit a CAPE declaration until you have reviewed the underlying data. Verify HTS classifications, country of origin declarations, and duty calculations. If any entries relied on questionable classification strategies, address those issues before they are exposed during recalculation.

✓

Separate Phase 1 Eligible Entries from Complex Scenarios

Phase 1 covers most unliquidated entries and entries liquidated within the last 80 days -- approximately 63 percent of all affected entries. Entries involving AD/CVD duties, drawback claims, reconciliation, or final liquidation beyond the 80-day window are excluded and will be addressed in future phases.

✓

Coordinate Across Compliance, Finance, and Legal Teams

This is not a task for any single function. The refund has financial planning implications, compliance risk implications, and potential legal exposure. Treating it as a cross-functional project is the only responsible approach.

✓

Plan Your Filing Timing

There is no benefit to filing on day one if your data is not clean. A well-prepared submission filed in the second or third week will process more smoothly than a rushed filing that triggers rejection or review flags.

IEEPA and CAPE Refund FAQs

How do I access IEEPA refunds if I do not have access to the Automated Commercial Environment (ACE)?

Low-volume importing businesses not enrolled in ACE can still apply for an IEEPA refund through their customs broker that submitted the entry on their behalf.

What is the timeline for IEEPA refund requests processed through CAPE?

Based on the tentative CAPE refund timelines, refunds for approved requests are expected within 45 days. However, the timeline is subject to change.

Which IEEPA-related refunds will be given priority?

In Phase 1, only refund requests for unliquidated entries and entries that have liquidated within the past 80 days will be processed. Complex entries -- those flagged for reconciliation, with drawback claims, a protest, and entries with antidumping or countervailing duty orders -- will be processed in a later phase. Some estimates imagine the process stretching out into 2027.

Should a protective protest be filed on all liquidated IEEPA customs entries?

This depends on the age and date of liquidation of the entry. Entries with a protest are -- by definition -- more complex, and this may delay the timing of the refund. However, some recommend this step to protect the refund itself. That decision ultimately rests with each importer.

Will Customs subtract IEEPA refunds against outstanding balances an importer has with CBP?

There is nothing to suggest that IEEPA refunds will be netted out against an outstanding balance. Yet this remains a possibility.

How will customs manage IEEPA refunds for liquidated entries outside the protest period that have not been protested?

There is no clear guidance on how customs will manage liquidated entries that fall outside the protest period but have not been protested. While the U.S. International Court of Trade (CIT) ruled that all entries must be refunded, there is still a lack of clarity as to whether that includes un-protested, liquidated entries.

What is CAPE and how does the four-step process work?

CAPE stands for Consolidated Administration and Processing of Entries. It is a purpose-built system inside the ACE Portal that processes IEEPA tariff refunds through four steps: (1) a Claim Portal for CSV upload of entry numbers, (2) Mass Processing to strip IEEPA Chapter 99 codes and recalculate duties, (3) a Review and Liquidation step where CBP evaluates recalculated entries, and (4) Refund Processing where approved amounts are disbursed electronically through ACH. The critical distinction is that CAPE is a review engine with a refund function -- not a simple payment tool.

The Bottom Line

CBP deserves credit for building CAPE as quickly and logically as they have. Returning $165 billion or more to 330,000 importers across 53 million entries is an unprecedented operational challenge, and the phased, systematic approach reflects serious institutional effort. Importers need to understand that CAPE is not a refund portal in the way most businesses are imagining it. It is a structured process with a review engine at its core.

Those who treat this as a compliance exercise -- with defensible positions, clean data, and coordinated preparation -- will recover their money efficiently.

Jet Worldwide provides international logistics, customs brokerage, and trade compliance services for businesses shipping to and from the United States and Canada. For guidance on cross-border trade strategies, contact our team.

12 min read Updated April 16, 2026 Trade Compliance

Shipping Parcels to the USA in 2026

Timothy Byrnes — Fri, 10 Apr 2026 01:19:37 GMT

There has been a lot of changes in 2025 regarding the import of e-commerce parcel of the United States. Mostly this affects the duty free status of goods valued under $800. The processes have changed, become more involved and require more knowledge.

We have we've updated this blog (April 2026) by basically taking away all the old information. If you wish to develop e-commerce processes to the United States, contact our team.

April 2026: Verify refunds for IEEPA tariffs via CAPE

In general, we recommend using an express consignment facility or ECCF. Or, even better, set up as a US import of record and import your goods in bulk. Most important is that you have a knowledgable trusted partner. That is where Jet Worldwide consulting can be of assistance.

ENG Blog

Section 301 Forced-Labor Duties and Canadian exports to the USA

What changed on July 24

The rate tiers and all 60 economies

Other Exemptions, general and country-specific

General exemptions available to all 60 economies

Filing mechanics: sequence, Chapter 98, and FTZ

HTSUS reporting order on the entry summary line

Chapter 98 treatment

Frequently asked questions

Sources

EU Product Identifiers (PID): The 1 November 2026 Rule Canadian Exporters Need to Know.

The change is not the code. It is the transmission.

More Granular Oversight

The direction is not uniquely European

The sequence

M-PID, NS-PID, S-PID: who owns what

Distributed responsibility, concentrated exposure

TARIC document codes

What this means for Canadian exporters

A six step readiness sequence

Where this is heading

Frequently asked questions

Shipping parcels from Canada into the EU

Related reading

About the author

Get help

The EU's New €3 Parcel Duty: What Canadian Sellers Need to Know Before July 1st

Service Alert:Canada Post has suspended parcel service to most of Europe

Canadian Registered Customs Representatives (RDE)

FedEx, UPS and DHL Shipments to Europe and 3 euro minimum charge

What the EU Is Changing — and Why It Matters Now

Direct-to-consumer flows into the EU and Tariff Classification:

Why Postal Operators Themselves Are Raising the Alarm

The Honest Problem With Canada Post and Postal Solutions for EU Shipping

Parcel Consolidation into Europe

Prepaid Duty and VAT — Delivered Duty Paid

Proprietary Import Process — Your Program, Not a Shared Network

Direct Shipping to Europe — No Postal Handoff

If You Are Still Shipping to Europe Through Canada Post, It Is Time to Change That

Frequently Asked Questions

What exactly is the EU's new €3 parcel duty and when does it start?

Does this new EU duty apply to Canadian sellers?

Why are so many postal operators saying they are not ready for the July 1st deadline?

Why is Canada Post not a good solution for shipping to the EU under the new rules?

What is Delivered Duty Paid (DDP) shipping and does my business need it for the EU?

What does Jet Worldwide offer as an alternative to Canada Post for shipping to Europe?

How do I know if my current EU shipping setup is ready for the July 1st changes?

CUSMA USMCA Review 2026: What Happens on July 1st and What to Expect

What Does Article 34.7 of CUSMA Actually Require?

What Are the Three Possible Outcomes of the CUSMA Review?

Where Do Things Stand Right Now?

How Have Tariff Measures Changed the Landscape?

What Does the Shift in US Trade Strategy Mean for CUSMA?

What Should Canadian Exporters and Importers Expect?

Frequently Asked Questions: CUSMA USMCA Review 2026

EU E-Commerce Customs Rules 2026: What Canadian Sellers Need to Know

The New 3 Euro Per Item Customs Duty (Effective July 1, 2026)

How the 3 euro duty is calculated

Options now that Canada Post has suspended service to Europe?

H7 vs H1: Two Customs Entry Pathways into the EU

H7 — Simplified Low-Value E-Commerce Declaration

H1 — Traditional Full Customs Declaration

H7 vs H1 comparison at a glance

Send direct to Europe from Canada and get H1 clearance

IOSS (Import One-Stop Shop) for Canadian Sellers

Why IOSS matters for Canadian Shopify and e-commerce sellers

Will IOSS be available for shipments over €150?

How a Canadian seller registers for IOSS

How the New Customs Duty Will Be Paid

Option 1 — Charged at checkout (DDP / Delivered Duty Paid)

Option 2 — Charged on delivery (DAP / Delivered at Place)

Impact on Returns and Refunds

CETA and Preferential Origin: When the 3 Euro Duty Does Not Apply

Shopping Within the EU: Identifying Where Goods Actually Ship From

Action Steps for Canadian E-Commerce Sellers

EU VAT Rates by Member State (2026 Reference)

Related Resources

The 10% Section 122 Tariffs Just Got Struck Down. Here Is What Comes Next

Section 122 Tariffs Ruled Invalid