Issue 3. Status as of November 2, 2026. Covers items published or taking effect October 27 to November 2, 2026, plus dates coming up over the next few weeks (U.S. Eastern time).

The one thing to know: Section 232 robotics and industrial machinery: a finding, talks, and no new duty yet

Status as of November 2, 2026. Proclamation 11077 was signed October 28 and is published at 91 FR 69199 (Nov. 2, 2026), FR Doc. 2026-22385. When we checked on November 2, we found no CBP CSMS message on it, which fits a proclamation that sets no duty.

What it does. The President agreed with the Commerce Department’s finding that imports of robotics, industrial machinery and their parts and components threaten to impair national security, and decided it is “necessary and appropriate to enter into negotiations with trading partners” (Proclamation 11077). The White House posted a fact sheet on October 28.

What it does not do. The proclamation imposes no duty, has no annex, lists no HTS codes, changes nothing in the tariff schedule and sets no effective date. It says that, depending on how the negotiations go, the President “may consider alternative remedies in the future, including imposing or modifying tariffs, duties, quotas, and fees,” as well as an investment incentive program (clause (1)).

About the 180 days. This is not a 180-day negotiating window. The proclamation sets no fixed period for talks. Commerce and USTR must give the President an update on the negotiations within 180 days of October 28, which is about April 26, 2027 (our calculation; the proclamation gives no calendar date) (clause (2)). Separately, the proclamation notes that the President may take other actions if an agreement is not entered into within 180 days, is not being carried out, or is ineffective, citing 19 U.S.C. 1862(c)(3)(A) (paragraph 11). Commerce also keeps monitoring imports (clause (3)).

What products? The proclamation names only “robotics, industrial machinery, and their parts and components.” For a sense of what Commerce studied, its 2025 investigation notice said the investigation “includes, among other things, robots and programmable, computer-controlled mechanical systems,” CNC machining centers, turning and milling machines, grinding and deburring equipment, industrial stamping and pressing machines, tool changers, jigs and fixtures, and machine tools for cutting, welding and handling work pieces, and excluded unmanned aircraft systems (90 FR 46382). That is the investigation’s description, not a tariff scope, and it gives no HTS codes either.

The size of it. The proclamation cites “approximately $7.1 trillion in shipments of manufactured goods in 2024” supported by the sector, and “approximately $86 billion worth of equipment” produced in 2024 (paragraph 2).

Compared with wind turbines. Proclamation 11074 on wind turbines, signed October 22 and now at 91 FR 68001, has the same structure: agreement with the finding, negotiations, an update within 180 days and possible future remedies. One difference: the wind proclamation says certain wind components are already subject to the existing steel, aluminum and copper Section 232 tariffs and that it does not change them. Proclamation 11077 has no such clause.

What small and medium importers may want to consider. General information only, not legal or customs advice. Talk to a licensed customs broker or trade attorney about your own entries.

1. Nothing changes on your entries today because of this proclamation.
2. If you buy machine tools, robots or parts from abroad, note the update deadline of about April 26, 2027 in your planning calendar.
3. Ask your broker which Section 232 duties already apply to your machinery, for example on steel, aluminum or copper content, since this proclamation does not address them.

What to watch. Any Federal Register notice or CBP CSMS message that adds duties, quotas or fees, and any announced agreements with trading partners.

Running story: IEEPA refunds

Status as of November 2, 2026. In the class action Freestyle World, Inc. v. United States (CIT Court No. 26-01088), Judge Richard K. Eaton issued an order on October 29 after the closed October 27 conference (order, ECF No. 66). As of November 2, the docket shows no entries after this order.

Protests and CAPE Phase 3. Citing the CBP declaration filed October 26 (ECF No. 65, ¶8), the court wrote that “it is the court’s understanding that plaintiffs in individual cases are eligible to process their [IEEPA] refund claims for their finally liquidated entries that are the subject of a protest, in CAPE Phase 3, (1) even if the protest has not been withdrawn, and (2) no matter if the protest relates exclusively to IEEPA duties or includes other issues as well” (ECF No. 66). Note the scope: it refers to “plaintiffs in individual cases,” meaning importers with their own CIT cases. A footnote adds that, so far, no FAQ on CBP’s IEEPA refunds page says a protest need not be withdrawn before filing a Phase 3 CAPE declaration.

The numbers. The order repeats CBP’s figures as of October 23: about 15.8 million entries accepted in Phase 3, about $137.9 billion in potential and certified refunds accepted for processing, and about $127.7 billion (duties plus interest) sent to the Treasury. In the court’s words, “This represents the refund of more than 80% of the $166 billion in IEEPA tariffs collected” (ECF No. 66).

Error codes. The order says error codes that block CAPE processing were discussed and points filers to the CBP IEEPA mailboxes listed on CBP’s refunds page.

Next dates. The government must file a short report on CAPE’s progress by 5 p.m. Eastern on Tuesday, November 10, and a closed settlement conference is set for 2 p.m. Eastern on Thursday, November 12 (ECF No. 66). The joint proposed scheduling order is still due November 5 (ECF No. 63).

Two ACE notes from CBP. CBP said from October 29 the ACE Portal would have a new “Financial Transactions” tab, including the ACH Refund Authorization sub-tab used to manage ACH refund information (CSMS # 70297853). CBP also said some filers may have received ACE statements in error on October 28 and 29; it says statements for July 29 or 30 should be ignored, and points to the REV-104 report to confirm the correct statement number (CSMS # 70329550).

What it means for you. If you have your own CIT case and protested, finally liquidated entries, ask your trade attorney how the court’s understanding applies to you. If you filed in CAPE and are waiting, check your ACH details under the new tab. CBP does not charge fees to process refunds (CBP).

Still pending. The government’s Federal Circuit appeal (No. 26-1895) is undecided; its reply brief is due November 9 (as of November 2) (Fed. Cir. No. 26-1895 docket).

Deadlines

Date	What	Source
Mon Nov 9, 2026, 11:59 p.m. ET	The current suspension of the Section 301 maritime action (fees on maritime transport services and Annex V.A duties on ship-to-shore cranes and intermodal chassis and parts) ends unless USTR finalizes its proposed extension through Jan 9, 2027. As of November 2, we found no final USTR notice in the Federal Register or on USTR’s site.	91 FR 67388; 90 FR 48320 (Oct. 16, 2025), Annex V.A
Thu Nov 5, 2026	Joint proposed scheduling order in the IEEPA class action	CIT order, ECF No. 63
Mon Nov 9, 2026, 5:15 p.m. ET	Comments to the ITC on implementing Section 338(g) (docket MISC-053). An ITC press release gave Nov 8; the Federal Register says Nov 9	91 FR 57387
Mon Nov 9, 2026	Government’s reply brief in Fed. Cir. No. 26-1895. Shopping carts: entries of appearance and APO applications	Fed. Cir. No. 26-1895 docket; 91 FR 68969
Tue Nov 10, 2026, 5 p.m. ET	Government’s CAPE progress report due at the CIT	CIT order, ECF No. 66
Thu Nov 12, 2026, 2 p.m. ET	Closed settlement conference in the IEEPA class action. Same day: government’s response and reply brief in the Section 122 appeal (Fed. Cir. No. 26-1804)	CIT order, ECF No. 66; Fed. Cir. No. 26-1804 docket
Wed Nov 18, 2026, 9:30 a.m. ET	ITC preliminary conference, shopping carts from China	91 FR 68969
Mon Nov 30, 2026	Requests for AD/CVD administrative reviews of orders with November anniversary months. Also: comments to Commerce on subsidy programs of countries exporting softwood lumber (Softwood Lumber Act of 2008)	91 FR 68936, FR Doc. 2026-22345; 91 FR 68109 (Oct. 29, 2026)
Mon Dec 14, 2026	ITC preliminary determinations, shopping carts from China (views to Commerce by Dec 21)	91 FR 68969
Fri Jan 29, 2027	2027 customs broker permit user fee of $190.88 due	91 FR 67594

Carried dates from Issue 2 that still apply: comments on the CAPE information collection due Nov 4 (91 FR 63299); cardboard boxes scope comments due 5 p.m. ET Nov 9, with rebuttals due 5 p.m. ET Nov 19 (91 FR 67276); quartz quota Nov 15, polyester fiber quota Nov 23, Low-Value Shipments comments Dec 7, FDA comments Dec 22 and Dec 28, USMCA review comments Jan 12, 2027, and Entry Type 13 on Jan 20, 2027; and the two-year limit for IEEPA suits at the CIT under 28 U.S.C. 2636(i). Details are in Issue 2’s table.

What changed

1. Canada Section 338: the new list is in force, and CBP’s guidance is out

The October 23 proclamation that Issue 2 led with is now Proclamation 11076, 91 FR 68861 (Oct. 30, 2026). CBP’s filing guidance, CSMS # 70314289, was sent October 29. From 12:01 a.m. ET October 30, 22 classifications are no longer subject to the 50 percent duty under HTSUS 9903.03.14, and 100 added classifications are, shown in bold on the CSMS attachment. CBP says there are no changes to the lists under 9903.03.12 or 9903.03.13. On drawback, the CSMS says: “The additional duties imposed by headings 9903.03.12 to 9903.03.14 are eligible for drawback.”

What it means for you. CBP’s attachment to the CSMS is the list CBP points filers to; confirm your codes with your broker. Questions go to TradeRemedy@cbp.dhs.gov.

General information only, not legal or customs advice. For your situation, talk to a licensed customs broker or trade attorney.

2. November AD/CVD administrative review requests are due Monday, November 30

Commerce’s monthly notice opens the window for orders with November anniversary months. Interested parties may request a review “Not later than the last day of November 2026,” which is Monday, November 30 (91 FR 68936, FR Doc. 2026-22345). Listed orders include oil country tubular goods (Argentina, Mexico, Russia), aluminum foil (several countries), thermal paper (Germany, Japan, Korea, Spain), paper file folders, forged steel fittings, and from China fresh garlic, diamond sawblades, paper clips and PET film. Check the full list in the notice.

Also in the November 2 Federal Register: Commerce started sunset reviews of mobile access equipment from China, potassium permanganate from China, and polyester textured yarn from Indonesia, Malaysia, Thailand and Vietnam (91 FR 68945, FR Doc. 2026-22312), and no sunset reviews are scheduled for December initiation (FR Doc. 2026-22313).

What it means for you. If you import goods under one of these orders, a review can change the final duty on your entries. Ask your broker or trade attorney whether a review request covering your supplier makes sense for you.

General information only, not legal or customs advice. For your situation, talk to a licensed customs broker or trade attorney.

3. Van-type trailers from China: AD/CVD orders in force, and chassis orders stay

Commerce issued antidumping and countervailing duty orders on van-type trailers and subassemblies from China (91 FR 67815). The China-wide antidumping cash deposit rate is 129.73 percent, and the countervailing duty cash deposit rate is 134.75 percent for the listed companies and all others. Deposits run from publication of the ITC’s final determinations on October 20 (91 FR 66359, FR Doc. 2026-21382). Typical HTSUS numbers include 8716.39.0040, 8716.39.0090 and 8716.90.5060, but the written scope controls. Chassis subassemblies covered by the existing chassis orders are excluded from the trailer scope.

Those chassis orders stay in place for now: the ITC found that revoking the AD/CVD orders on chassis and subassemblies from China would likely lead to continued injury (91 FR 68983).

What it means for you. Depending on scope, trailer and chassis parts from China may fall under one set of orders or the other. Ask your broker which scope your parts fall under.

General information only, not legal or customs advice. For your situation, talk to a licensed customs broker or trade attorney.

4. New case: shopping carts and parts from China

Precision Wire Products, Inc. and Wanzl North America filed antidumping and countervailing duty petitions on October 28, and the ITC opened preliminary investigations (701-TA-811 and 731-TA-1813) on goods under HTSUS 8716.80.50 (91 FR 68969). Requests to appear at the conference are due by noon November 16, testimony by 4 p.m. November 17, the conference is November 18 at 9:30 a.m. ET, and post-conference briefs are due 5:15 p.m. November 23. The ITC’s preliminary determinations are due December 14. As of November 2, Commerce had not published an initiation notice.

What it means for you. No AD/CVD duties apply yet. Retail and grocery-equipment buyers may want to follow the case.

General information only, not legal or customs advice. For your situation, talk to a licensed customs broker or trade attorney.

Also this period.

• Mattresses orders continue. The ITC found that revoking the CVD order on mattresses from China and the AD orders on Cambodia, Malaysia, Serbia, Thailand, Turkey and Vietnam would likely lead to continued injury (91 FR 67611).
• Broker permit fee. CBP set the 2027 customs broker permit user fee at $190.88, due January 29, 2027 (91 FR 67594).

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Previous issues

• Issue 2: status as of October 26, 2026 (published October 27, 2026)
• Issue 1: status as of October 23, 2026 (published October 23, 2026)

Not advice. Importer Weekly is general information only, not legal, customs-brokerage, tax or financial advice. For decisions about your entries, refunds or filings, consult a licensed customs broker or a trade attorney.

How this is made. Produced with AI assistance. Each item links to the official source we relied on; tell us if you spot an error. Questions, tips or corrections? Email hello@importerweekly.com.