CBP Rules on AI Classification Tools, CAPE Refund Portal Progress, Ecuador Trade Deal Signed, Made in America scrutiny, Updated 232 guidance
CBP Draws a Hard Line on AI in Customs
CBP issued a ruling this week that reshapes the AI customs technology market. The ruling is direct: if software extracts entry data, generates HTS classifications tied to live shipments, or files 5106s, that is customs business. It requires a licensed broker underneath it. No exceptions.
This is not a new law. It is CBP clarifying that existing law applies to platforms that have been operating in a gray zone for years. Classification tools, document extraction platforms, and entry prep software that operate without licensed broker infrastructure are now on notice.
From day one we built Importal on one belief: AI and customs clearance are inseparable. That is why we are a licensed customs brokerage with AI at our core. Our AI owns the compliance layer. Our licensed brokerage owns the execution layer. This ruling solidifies that vision. If you are using a standalone AI classification or entry prep tool, ask your vendor one question: who is the licensed broker on your platform?
Read the ruling: https://www.strtrade.com/trade-news-resources/str-trade-report/trade-report/march/cbp-clarifies-limits-for-importer-services-tech-platforms
CAPE Refund Portal: Progress Update Filed Today with the Court of International Trade
Brandon Lord, Executive Director of CBP's Trade Programs Directorate, filed a declaration today with the Court of International Trade updating the court on CAPE development. This is the most current data available. Here is where each component stands as of March 19:
Claim Portal (73% complete): CBP is actively testing the substantially-developed capabilities before deployment to the live ACE environment. Importers and brokers will upload a CSV of entry summaries subject to IEEPA tariffs and CBP will validate the submission and confirm the filer is the importer of record or the broker that filed the entries.
Mass Processing (45% complete): CBP is building two critical functions inside this component. ACE validations will ensure automated entry summary updates are processed correctly and will flag entries that cannot be fully processed in Phase 1, including entries subject to AD/CVD suspension orders where Commerce has instructed CBP to hold liquidation. Event history tracking will create an audit trail on every entry summary touched by CAPE. CBP plans to complete remaining validations and begin testing within the next week.
Review and Liquidation (80% complete): CBP has begun testing the liquidation and reliquidation function. Completion depends on progress in the other components.
Refund Processing (63% complete): CBP has completed development of CAPE-specific refund processing within the ACE Collections framework and is actively testing refund consolidation functionality. Refunds will be consolidated by liquidation date and importer of record. The IOR can designate a third party to receive refunds on their behalf.
CBP indicated on March 6 the full system would be ready within 45 days, putting the earliest start date around April 20. The government has confirmed it will pay interest on all refunds owed.
What importers should do now:
File protests immediately for any liquidated entries still within the 180-day window. This keeps entries live regardless of what happens with appeals or CAPE delays.
Set up ACE portal access if you do not have it and register for ACH direct deposit. CBP will not cut paper checks.
Audit your entries going back to April 5, 2025 and calculate your total refund exposure by duty category.
Finally liquidated entries are not covered by the current court order. Their refund path depends on further court or agency action.
If your entries are subject to AD/CVD orders, they will not be processed in Phase 1 of CAPE. Plan accordingly.
Importal is tracking the CAPE portal build in real time. Follow the latest completion percentages, expected go-live date and action items on our CAPE refund countdown
US Signs Trade Agreement with Ecuador
On March 13, US Trade Representative Jamieson Greer and Ecuador's Minister of Production, Foreign Trade, and Investment signed the US-Ecuador Agreement on Reciprocal Trade. The deal finalizes a framework first announced in 2025 and takes effect 30 days after both governments complete their respective legal procedures. No firm effective date yet.
Under the agreement, the US agreed to apply most-favored-nation duty rates on a range of Ecuadorian goods including flowers, coffee, fruits, spices, and select chemicals. Ecuador agreed to eliminate import restrictions on US remanufactured and refurbished goods, accept FDA-approved products without additional conformity assessment, strengthen intellectual property protections, and prohibit imports of goods produced with forced labor.
The US has now signed reciprocal trade agreements with Ecuador, El Salvador, Guatemala, the UK, and Argentina. Implementation timelines vary and several remain subject to legal procedures. Do not reclassify or re-rate entries based on any of these agreements until effective dates are confirmed in the Federal Register.
Full agreement text: https://ustr.gov/about/policy-offices/press-office/press-releases/2026/march/ambassador-greer-signs-united-states-ecuador-agreement-reciprocal-trade
President Trump Signs Executive Order Targeting Fraudulent "Made in America" Claims
On March 13, President Trump signed an Executive Order directing the FTC to prioritize enforcement actions against sellers and manufacturers making false "Made in America" claims, with particular focus on foreign sellers and digital marketplaces.
The EO does not change the underlying FTC standard. The "all or virtually all" test still applies. To make an unqualified Made in USA claim, final assembly must occur in the US, all significant processing must occur in the US, and all or virtually all components must be made and sourced in the US. What changed is enforcement priority. The FTC now has a direct mandate to pursue violations. Civil penalties run up to $53,000 per violation.
The EO also directs the FTC to consider new regulations holding online marketplaces liable if they fail to establish procedures for verifying country-of-origin claims. For federal contractors, misrepresentation cases will be referred to the DOJ for potential False Claims Act liability.
If your supply chain touches foreign inputs and you are making origin claims on product labeling or digital listings, review your exposure now. The standard is strict and enforcement is about to get more active.
CBP Base Metals Center Clarifies Section 232 Content Value Rules for Steel, Aluminum, Copper, and Iron
CBP's Base Metals Center issued updated guidance on March 15 clarifying how Section 232 duties are calculated when an imported article contains both subject metal and non-subject components. This has been a persistent source of confusion and CBP is now putting the position in writing.
The core rule: Section 232 duty is assessed on the value of the metal content only, not the full entered value, when an article contains legitimately separable non-metal components. But the definition of what you can back out is narrow and strict.
What you cannot subtract: costs of production, manufacturing, machining, fabrication, labor, overhead, profit, packaging, coating, painting, galvanizing or plating. None of those reduce your Section 232 dutiable value. The only deduction allowed is the cost of actual non-steel or non-aluminum parts and components.
How to calculate it: Start with what the importer paid for the finished article. Identify the cost of the non-metal parts or components. Subtract that from the total. What remains is the Section 232 dutiable value. CBP gives a clean example in the guidance: a $100 aluminum window with $20 in glass and other non-aluminum components results in an $80 aluminum content value subject to Section 232 duty. For costs that touch both the metal and non-metal content like labor or overhead, an acceptable method is to apportion them based on a value ratio across both lines.
If you are importing mixed-material articles with steel, aluminum, copper, or iron content and you have not reviewed your duty calculations against this guidance, now is the time. The rules on what is and is not deductible are stricter than most importers assume.
CBP Trade Remedies guidance: https://www.cbp.gov/trade/programs-administration/trade-remedies
Need help managing your customs compliance? Importal is the first AI-native licensed US customs brokerage. Our platform tracks every CSMS message, Federal Register notice, and executive order so you know exactly where your entries stand and what action is required.
Talk to a licensed broker today
Subscribe to the Entry Summary. We track the regulations. You take action.
