No quarter in U.S. trade history has more overlapping compliance deadlines than April through July 2026. IEEPA refunds go live. Section 301 comment periods close. CPSC eFiling becomes mandatory. The USMCA review begins. Section 122 expires. Missing any one of these deadlines can cost your business thousands to millions of dollars in lost refunds, unexpected duties, or shipment delays. Bookmark this calendar and check it weekly.
Key Takeaways
There are at least 15 major compliance deadlines between April 3 and July 24, 2026.
Three deadlines fall in the next two weeks alone: the Section 301 comment deadline (April 15), the CAPE refund system go-live (approximately April 20), and the Section 232 auto parts inclusion window (April 14).
July is the most critical month: USMCA review begins July 1, CPSC eFiling goes mandatory July 8, and Section 122 expires July 24.
Every deadline has a specific action attached. This calendar tells you not just what is happening, but what you need to do and by when.
The Complete Calendar
April 2026
| Date | Event |
|---|---|
| What You Need to Do | April 10 |
CIT oral arguments on Section 122 lawsuits
Monitor the outcome. A ruling to suspend Section 122 could stop collections immediately. A ruling upholding the surcharge confirms it continues through July 24. Either outcome changes your tariff model.
April 14
CBP status report on CAPE refund system due to CIT
Review for updated go-live timeline and Phase 1 scope details. If CAPE launch is delayed, your refund timeline shifts.
April 14
Section 232 auto parts inclusions window closes
If you import auto parts, verify whether any new HTS codes have been added to Section 232 coverage. Confirm classification and stacking with your broker.
April 15
Section 301 written comment deadline (both investigations)
If your products, origins, or supply chains are implicated in the excess capacity (16 economies) or forced labor (60 economies) investigations, submit comments through the USTR portal by 11:59 PM EST. This is your last opportunity to influence the scope and level of potential new tariffs. See our Section 301 investigations guide.
~April 20
CAPE Phase 1 expected go-live for IEEPA refund claims
Begin submitting IEEPA refund claims through the ACE portal. Have your CSV files of affected entry summaries prepared. Confirm ACH enrollment and banking details. Phase 1 covers approximately 63% of IEEPA-affected entries. See our IEEPA refund guide.
April 28
Section 301 forced labor public hearings begin (USITC)
Monitor hearing testimony for signals about which countries and sectors face the steepest proposed tariffs. Hearings continue through May 1 as necessary.
May 2026
| Date | Event |
|---|---|
| What You Need to Do | May 4 |
Key IEEPA refund deadline to monitor
Watch for government appeal developments related to the CIT's order on IEEPA refunds. If the government appeals, refund timelines could be extended. Continue filing protests on liquidated entries to preserve refund rights.
May 5
Section 301 excess capacity public hearings begin (USITC)
Monitor hearing testimony for the 16-economy investigation. Hearings continue through May 8 as necessary. The questions USTR asks and the industries that testify will indicate which sectors face the highest proposed tariffs.
~May 12
Post-hearing rebuttal comments due (forced labor)
If you testified or submitted comments on the forced labor investigation, submit any rebuttal comments within 7 calendar days of the last hearing day.
~May 15
Post-hearing rebuttal comments due (excess capacity)
Same deadline for the excess capacity investigation.
May (ongoing)
CAPE Phase 1 processing
If you submitted IEEPA refund claims in late April, expect up to 45 days for processing. Monitor ACE for claim status updates. Address any compliance concerns flagged by CBP promptly.
May (ongoing)
CPSC Product Registry preparation
If you have not registered for the CPSC Product Registry, do so now. The 2,000 participant cap for the voluntary stage may close at any time. Upload certificate data, test your filing process, and resolve any data issues before the July 8 mandatory deadline. See our CPSC eFiling guide.
June 2026
| Date | Event |
|---|---|
| What You Need to Do | June (early) |
First IEEPA refund payments expected
If you submitted claims in late April and processing took the estimated 45 days, refunds should begin arriving via ACH in early June. Verify amounts against your records. Reconcile refunds with your financial statements and intercompany agreements.
June (ongoing)
USMCA documentation audit window
The USMCA review begins July 1. Complete your internal audit of certificates of origin, supplier declarations, regional value content calculations, and supply chain traceability documentation before the review period increases enforcement scrutiny. See our USMCA review guide and nearshoring article.
June (ongoing)
Broker readiness check for CPSC eFiling
Confirm with your customs broker that their systems are ready to transmit CPSC PGA Message Sets (Full or Reference) through ACE. Test the filing process on a live entry during the voluntary stage. Resolve any data or system issues before July 8.
June (ongoing)
Section 122 bonded warehouse strategy window
If you are using a bonded warehouse to defer entry until after the Section 122 surcharge expires on July 24, ensure all goods are admitted to the warehouse and withdrawal timing is planned. Calculate the storage cost against the duty savings for your specific inventory. See our FTZ vs. bonded warehouse guide.
June (late)
Model post-Section 122 scenarios
By late June, the Section 301 hearing record will be closed and USTR will be preparing its determinations. Model three scenarios for your top products: surcharge expires with no replacement, new Section 301 tariffs at estimated rates, and expanded Section 232 coverage. Adjust pricing, sourcing, and inventory plans accordingly. See our Section 122 expiration guide.
July 2026
| Date | Event |
|---|---|
| What You Need to Do | July 1 |
USMCA formal joint review begins
Monitor USTR announcements for the review's scope and initial positions. If you import from or export to Canada or Mexico under USMCA, confirm that your qualification documentation is complete and current. Products near the regional value content threshold are most at risk if rules tighten. See our USMCA review guide.
July 8
CPSC eFiling becomes mandatory
All importers of regulated consumer products must electronically file certificate of compliance data through ACE at the time of entry. Shipments without accurate eFiling data may face delays, examinations, and increased risk scores. More than 2,400 HTS codes are affected. See our CPSC eFiling guide.
July 24
Section 122 surcharge expires
The 10% ad valorem surcharge ends at 12:01 AM EDT unless Congress votes to extend it (unlikely). Monitor for replacement tariffs under Section 301 or expanded Section 232. If you deferred goods in a bonded warehouse, plan withdrawals for July 25 or later to avoid the surcharge. See our Section 122 expiration guide.
~July 24
Potential new Section 301 tariffs take effect
USTR has stated the intent to complete Section 301 investigations by approximately this date. New country-specific tariffs could take effect immediately upon determination. Monitor Federal Register notices for rate announcements. Update your tariff models and pricing as soon as rates are published.
The Action Checklist: What to Do This Week
If you have not already taken these steps, start today.
Confirm your ACH enrollment with CBP. IEEPA refunds and all future CBP refunds are issued electronically. If your ACE account does not have current banking details, you will not receive refunds. Verify now.
Prepare your IEEPA refund claim files. Organize entry summaries into CSV format for CAPE submission. Separate entries by liquidation status (unliquidated, within 90-day window, suspended, finally liquidated) to identify which are Phase 1 eligible.
Decide whether to submit Section 301 comments by April 15. Review the scope of both investigations. If your products or supply chains are implicated, submitting comments is the most direct way to influence the tariff outcome. Work through an industry association if individual submission is not practical.
Register for the CPSC Product Registry. If you import any of the 2,400+ regulated HTS codes, register now. The voluntary stage cap of 2,000 participants may close. Audit your certificates of compliance for completeness and accuracy.
Audit your USMCA documentation. Pull certificates of origin, supplier declarations, and RVC calculations for your top USMCA-qualifying products. Fix gaps before the July 1 review amplifies enforcement scrutiny.
Model your post-July 24 tariff scenarios. For your top 20 entries by duty value, calculate total landed cost under three conditions: current rates, rates without Section 122, and rates with estimated new Section 301 tariffs. Share results with your pricing and procurement teams.
How to Stay Current After This Calendar
The tariff landscape changes weekly. These are the sources to monitor.
CBP Cargo Systems Messaging Service (CSMS). Subscribe at cbp.gov. CSMS messages are the first official notification of operational changes to tariff collection, entry requirements, and system updates.
Federal Register. New tariff proclamations, Section 301 investigation notices, Section 232 investigation results, and regulatory changes are published here before they take effect.
USTR Comments Portal. Active investigations, comment deadlines, and hearing schedules are posted at comments.ustr.gov.
CIT Docket. Court rulings on Section 122 challenges, IEEPA refund orders, and other trade litigation appear on the Court of International Trade's public docket.
Your customs broker. A broker who monitors these sources and pushes relevant updates to you before they affect your entries is doing their job. A broker who does not is leaving you to discover changes after they have already cost you money. See our guide on choosing a customs broker.
Frequently Asked Questions
What is the most urgent deadline right now?
The Section 301 public comment deadline on April 15, 2026. This is the last opportunity for importers to submit written input on the excess capacity and forced labor investigations that could produce replacement tariffs by July 24.
When can I start filing IEEPA refund claims?
CAPE Phase 1 is expected to go live around April 20, 2026. Claims are filed through the ACE portal using CSV uploads of affected entry summaries. Processing takes up to 45 days per claim.
When does CPSC eFiling become mandatory?
July 8, 2026, for most imported consumer products. Products entering from a Foreign Trade Zone have until January 8, 2027.
When does Section 122 expire?
July 24, 2026. The surcharge cannot be extended without an act of Congress. The administration has stated it intends to replace it with new Section 301 and Section 232 tariffs by that date.
When does the USMCA review begin?
July 1, 2026. The three countries must decide whether to extend the agreement for another 16 years, negotiate revisions, or enter annual reviews.
How often is this calendar updated?
This calendar reflects deadlines and events known as of April 3, 2026. New deadlines may be added as investigations progress, court rulings are issued, and regulatory changes are announced. Check back weekly and subscribe to CBP CSMS for real-time updates.
Is there a single place to track all of these deadlines?
This calendar is the most comprehensive single resource available. For detailed guidance on any specific topic, see the linked articles throughout this guide covering IEEPA refunds, tariff stacking, Section 301 investigations, CPSC eFiling, USMCA review, Section 122 expiration, FTZ and bonded warehouse strategies, duty drawback, and customs audits.
What happens if I miss one of these deadlines?
The consequences vary. Missing the Section 301 comment deadline means you lose the opportunity to influence tariff rates. Missing the CPSC eFiling deadline means your shipments face delays and increased scrutiny. Missing IEEPA refund filing deadlines could mean forfeiting money you are legally owed. Missing the USMCA documentation audit window means entering the review period with compliance gaps that could cost you preferential treatment.
This calendar reflects U.S. trade policy deadlines, compliance requirements, and regulatory events as of April 3, 2026. All dates are subject to change based on court rulings, executive action, and agency announcements. Importers should verify current deadlines through CBP CSMS, the Federal Register, and USTR announcements, and should consult with a licensed customs broker for guidance specific to their import programs.
Tight ICP
The Importer's 90-Day Compliance Calendar: Every Deadline Between April and July 2026
No quarter in U.S. trade history has more overlapping compliance deadlines than April through July 2026. IEEPA refunds go live. Section 301 comment periods close. CPSC eFiling becomes mandatory. The USMCA review begins. Section 122 expires. Missing any one of these deadlines can cost your business thousands to millions of dollars in lost refunds, unexpected duties, or shipment delays. Bookmark this calendar and check it weekly.
Key Takeaways
There are at least 15 major compliance deadlines between April 3 and July 24, 2026.
Three deadlines fall in the next two weeks alone: the Section 301 comment deadline (April 15), the CAPE refund system go-live (approximately April 20), and the Section 232 auto parts inclusion window (April 14).
July is the most critical month: USMCA review begins July 1, CPSC eFiling goes mandatory July 8, and Section 122 expires July 24.
Every deadline has a specific action attached. This calendar tells you not just what is happening, but what you need to do and by when.
The Complete Calendar
April 2026
| Date | Event |
|---|---|
| What You Need to Do | April 10 |
CIT oral arguments on Section 122 lawsuits
Monitor the outcome. A ruling to suspend Section 122 could stop collections immediately. A ruling upholding the surcharge confirms it continues through July 24. Either outcome changes your tariff model.
April 14
CBP status report on CAPE refund system due to CIT
Review for updated go-live timeline and Phase 1 scope details. If CAPE launch is delayed, your refund timeline shifts.
April 14
Section 232 auto parts inclusions window closes
If you import auto parts, verify whether any new HTS codes have been added to Section 232 coverage. Confirm classification and stacking with your broker.
April 15
Section 301 written comment deadline (both investigations)
If your products, origins, or supply chains are implicated in the excess capacity (16 economies) or forced labor (60 economies) investigations, submit comments through the USTR portal by 11:59 PM EST. This is your last opportunity to influence the scope and level of potential new tariffs. See our Section 301 investigations guide.
~April 20
CAPE Phase 1 expected go-live for IEEPA refund claims
Begin submitting IEEPA refund claims through the ACE portal. Have your CSV files of affected entry summaries prepared. Confirm ACH enrollment and banking details. Phase 1 covers approximately 63% of IEEPA-affected entries. See our IEEPA refund guide.
April 28
Section 301 forced labor public hearings begin (USITC)
Monitor hearing testimony for signals about which countries and sectors face the steepest proposed tariffs. Hearings continue through May 1 as necessary.
May 2026
| Date | Event |
|---|---|
| What You Need to Do | May 4 |
Key IEEPA refund deadline to monitor
Watch for government appeal developments related to the CIT's order on IEEPA refunds. If the government appeals, refund timelines could be extended. Continue filing protests on liquidated entries to preserve refund rights.
May 5
Section 301 excess capacity public hearings begin (USITC)
Monitor hearing testimony for the 16-economy investigation. Hearings continue through May 8 as necessary. The questions USTR asks and the industries that testify will indicate which sectors face the highest proposed tariffs.
~May 12
Post-hearing rebuttal comments due (forced labor)
If you testified or submitted comments on the forced labor investigation, submit any rebuttal comments within 7 calendar days of the last hearing day.
~May 15
Post-hearing rebuttal comments due (excess capacity)
Same deadline for the excess capacity investigation.
May (ongoing)
CAPE Phase 1 processing
If you submitted IEEPA refund claims in late April, expect up to 45 days for processing. Monitor ACE for claim status updates. Address any compliance concerns flagged by CBP promptly.
May (ongoing)
CPSC Product Registry preparation
If you have not registered for the CPSC Product Registry, do so now. The 2,000 participant cap for the voluntary stage may close at any time. Upload certificate data, test your filing process, and resolve any data issues before the July 8 mandatory deadline. See our CPSC eFiling guide.
June 2026
| Date | Event |
|---|---|
| What You Need to Do | June (early) |
First IEEPA refund payments expected
If you submitted claims in late April and processing took the estimated 45 days, refunds should begin arriving via ACH in early June. Verify amounts against your records. Reconcile refunds with your financial statements and intercompany agreements.
June (ongoing)
USMCA documentation audit window
The USMCA review begins July 1. Complete your internal audit of certificates of origin, supplier declarations, regional value content calculations, and supply chain traceability documentation before the review period increases enforcement scrutiny. See our USMCA review guide and nearshoring article.
June (ongoing)
Broker readiness check for CPSC eFiling
Confirm with your customs broker that their systems are ready to transmit CPSC PGA Message Sets (Full or Reference) through ACE. Test the filing process on a live entry during the voluntary stage. Resolve any data or system issues before July 8.
June (ongoing)
Section 122 bonded warehouse strategy window
If you are using a bonded warehouse to defer entry until after the Section 122 surcharge expires on July 24, ensure all goods are admitted to the warehouse and withdrawal timing is planned. Calculate the storage cost against the duty savings for your specific inventory. See our FTZ vs. bonded warehouse guide.
June (late)
Model post-Section 122 scenarios
By late June, the Section 301 hearing record will be closed and USTR will be preparing its determinations. Model three scenarios for your top products: surcharge expires with no replacement, new Section 301 tariffs at estimated rates, and expanded Section 232 coverage. Adjust pricing, sourcing, and inventory plans accordingly. See our Section 122 expiration guide.
July 2026
| Date | Event |
|---|---|
| What You Need to Do | July 1 |
USMCA formal joint review begins
Monitor USTR announcements for the review's scope and initial positions. If you import from or export to Canada or Mexico under USMCA, confirm that your qualification documentation is complete and current. Products near the regional value content threshold are most at risk if rules tighten. See our USMCA review guide.
July 8
CPSC eFiling becomes mandatory
All importers of regulated consumer products must electronically file certificate of compliance data through ACE at the time of entry. Shipments without accurate eFiling data may face delays, examinations, and increased risk scores. More than 2,400 HTS codes are affected. See our CPSC eFiling guide.
July 24
Section 122 surcharge expires
The 10% ad valorem surcharge ends at 12:01 AM EDT unless Congress votes to extend it (unlikely). Monitor for replacement tariffs under Section 301 or expanded Section 232. If you deferred goods in a bonded warehouse, plan withdrawals for July 25 or later to avoid the surcharge. See our Section 122 expiration guide.
~July 24
Potential new Section 301 tariffs take effect
USTR has stated the intent to complete Section 301 investigations by approximately this date. New country-specific tariffs could take effect immediately upon determination. Monitor Federal Register notices for rate announcements. Update your tariff models and pricing as soon as rates are published.
The Action Checklist: What to Do This Week
If you have not already taken these steps, start today.
Confirm your ACH enrollment with CBP. IEEPA refunds and all future CBP refunds are issued electronically. If your ACE account does not have current banking details, you will not receive refunds. Verify now.
Prepare your IEEPA refund claim files. Organize entry summaries into CSV format for CAPE submission. Separate entries by liquidation status (unliquidated, within 90-day window, suspended, finally liquidated) to identify which are Phase 1 eligible.
Decide whether to submit Section 301 comments by April 15. Review the scope of both investigations. If your products or supply chains are implicated, submitting comments is the most direct way to influence the tariff outcome. Work through an industry association if individual submission is not practical.
Register for the CPSC Product Registry. If you import any of the 2,400+ regulated HTS codes, register now. The voluntary stage cap of 2,000 participants may close. Audit your certificates of compliance for completeness and accuracy.
Audit your USMCA documentation. Pull certificates of origin, supplier declarations, and RVC calculations for your top USMCA-qualifying products. Fix gaps before the July 1 review amplifies enforcement scrutiny.
Model your post-July 24 tariff scenarios. For your top 20 entries by duty value, calculate total landed cost under three conditions: current rates, rates without Section 122, and rates with estimated new Section 301 tariffs. Share results with your pricing and procurement teams.
How to Stay Current After This Calendar
The tariff landscape changes weekly. These are the sources to monitor.
CBP Cargo Systems Messaging Service (CSMS). Subscribe at cbp.gov. CSMS messages are the first official notification of operational changes to tariff collection, entry requirements, and system updates.
Federal Register. New tariff proclamations, Section 301 investigation notices, Section 232 investigation results, and regulatory changes are published here before they take effect.
USTR Comments Portal. Active investigations, comment deadlines, and hearing schedules are posted at comments.ustr.gov.
CIT Docket. Court rulings on Section 122 challenges, IEEPA refund orders, and other trade litigation appear on the Court of International Trade's public docket.
Your customs broker. A broker who monitors these sources and pushes relevant updates to you before they affect your entries is doing their job. A broker who does not is leaving you to discover changes after they have already cost you money. See our guide on choosing a customs broker.
Frequently Asked Questions
What is the most urgent deadline right now?
The Section 301 public comment deadline on April 15, 2026. This is the last opportunity for importers to submit written input on the excess capacity and forced labor investigations that could produce replacement tariffs by July 24.
When can I start filing IEEPA refund claims?
CAPE Phase 1 is expected to go live around April 20, 2026. Claims are filed through the ACE portal using CSV uploads of affected entry summaries. Processing takes up to 45 days per claim.
When does CPSC eFiling become mandatory?
July 8, 2026, for most imported consumer products. Products entering from a Foreign Trade Zone have until January 8, 2027.
When does Section 122 expire?
July 24, 2026. The surcharge cannot be extended without an act of Congress. The administration has stated it intends to replace it with new Section 301 and Section 232 tariffs by that date.
When does the USMCA review begin?
July 1, 2026. The three countries must decide whether to extend the agreement for another 16 years, negotiate revisions, or enter annual reviews.
How often is this calendar updated?
This calendar reflects deadlines and events known as of April 3, 2026. New deadlines may be added as investigations progress, court rulings are issued, and regulatory changes are announced. Check back weekly and subscribe to CBP CSMS for real-time updates.
Is there a single place to track all of these deadlines?
This calendar is the most comprehensive single resource available. For detailed guidance on any specific topic, see the linked articles throughout this guide covering IEEPA refunds, tariff stacking, Section 301 investigations, CPSC eFiling, USMCA review, Section 122 expiration, FTZ and bonded warehouse strategies, duty drawback, and customs audits.
What happens if I miss one of these deadlines?
The consequences vary. Missing the Section 301 comment deadline means you lose the opportunity to influence tariff rates. Missing the CPSC eFiling deadline means your shipments face delays and increased scrutiny. Missing IEEPA refund filing deadlines could mean forfeiting money you are legally owed. Missing the USMCA documentation audit window means entering the review period with compliance gaps that could cost you preferential treatment.
This calendar reflects U.S. trade policy deadlines, compliance requirements, and regulatory events as of April 3, 2026. All dates are subject to change based on court rulings, executive action, and agency announcements. Importers should verify current deadlines through CBP CSMS, the Federal Register, and USTR announcements, and should consult with a licensed customs broker for guidance specific to their import programs.
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