Tariff Trends 2026: Expert Insights on the Evolving U.S. Tariff Landscape

The below transcript has been generated by an AI system and may contain inaccuracies, errors, or omissions. While efforts have been made to ensure the accuracy of the content, the AI-generated transcript should not be considered fully reliable or definitive record.

Marcus Eeman

Hi. Good morning. Welcome to our webinar, today. My name is Marcus. Thank you for attending, and I'm a custom director here at Flexport. So, we have a good amount of content to cover today. So before we begin, if you haven't been here before, just wanna go over a few housekeeping items for, how our webinar software works. On your screen, you see a sidebar to the right of the main stage where you can submit questions. At the end of the presentation, we host a q and a to answer audience questions. Be sure to get your questions in early. We always try to make sure there's a ton of time. Everybody wants to come to these and ask something. So, please do. That's how we know, what you care about and we can make sure we emphasize certain points. Now in that same sidebar, you also see a tab called docs, and that's where you'll be able to download a copy of today's slides and find other helpful resources like our tariff simulator and our tariff refund calculator. Above your screen, you'll also see a button called audit your customs broker. We'll explain a little bit more on this in the presentation later. But if you click on it, it will open one of our newest tools designed to help you catch tariff stacking issues and see if you've under or maybe overpaid duties, especially as we anticipate AEPA refunds coming soon. Be sure to check that out. Okay. And so now just a brief, legal note. It's very fast moving environment. So the contents of this webinar, is for information purposes only based on the current situation at this current time and may not be customized to your specific business requirements. We will always recommend reaching out to a Flexport expert to discuss your particular situation. Joining me today is Jen Park, our director of trade advisory here at Flexport, and the person to go to if you have questions about AIPA refunds. That is that is her team who who handles a lot of those. Today's agenda, we're gonna go over the latest news like we always do. We're gonna dive into two parts of that news very specifically. One, the the three zero one investigations that were initiated last week as well as give an update on IEPA refunds. We'll go over a few resources at the end and wrap up with our q and a. Okay. Latest news. So, the first one is the IEPA refunds. This is kinda working its way through, this Court of International Trade. And so far, the I have to admit that it seems a bit positive. CBP is taking steps to try to comply with this court order, which back on March 6 said, CBP, you must refund all these duties as quickly as possible. CBP wrote back and said, I can't do it quite exactly how you want, but we have this other thing that we're gonna be putting together. We call it CAPE. We should have this ready to go in about forty five days, and it'll work out really well-to-do this kind of mass refund process. Judge Eaton from the CIT said, great. Give me weekly updates on your progress. So now every Thursday, those in the trade community, including myself, look for the latest news from court listener about what actually happened, what transpired during this update here. And we got an encouraging update last Thursday from Brandon Lord at CBP telling that, yes, this seems to be on track, and there's reasons for optimism that this that this timeline and this functionality may work. Jen Park is gonna go into that in a little bit more detail later on in the slides here as well as the three zero one investigations I'm gonna talk about. And so there's been no appeal yet from the government on the order itself, but we're gonna get into the IEPA refunds on its own category a little bit deeper. Another one is that section one twenty two is still at 10%. So despite the threats, that 10% remains. Right? The day after it was announced at 10%, president said it's gonna be 15%. Well, that happened. Never actually has been officially implemented yet, and we keep going on many days without any kind of official implementation. Last week, Scott Besson said, okay. Yes. We're gonna do something about 15%, for 01/22. Again, nothing official has actually happened yet. And what we're starting to see is maybe there's a bit of an uncertain path to try to get to that 15% based on the nature of the law, section one twenty two itself. It's kind of an all or nothing law. You can't sort of apply it to some and sort of exempt it from others. Potentially, it's kind of either have to give people 10% or you give them 0%. It's kind of a short version. So they're maybe trying to find different ways around it. Do they do a different kind of balance of payments adjustment? Do they just keep it at 10% and just quietly drop the 15% threat? Unclear exactly how they're gonna get there. But regardless, last week, 24 different states and their attorneys general sued to block section one twenty two, saying very simply that section one twenty two is meant to deal with balance of payments. What is the current account surplus or deficit in United States? What is you know, how is this actually working? And it's not a question of balance of trade. And so this was just a misuse of section one twenty two. It's kind of a short version of their legal argument. So so far, no no actions there, no preventions, no stopping it. We may have another batch of refunds to talk about next year for for section one twenty two, but remains to be seen how exactly that will proceed. There are four kind of, you know, things in the works in, like, that in the realm of politics and legislation and regulation that I wanted to highlight as well. The first of all is you may have heard some some discussion from a couple weeks ago that, China's permanent normal trade relations status, PNTR status, is gonna be reviewed by the USITC. This is just a review. It's not a cancellation, but it basically is an instruction from congress saying, okay. Well, what would happen if we were to revoke China's PNTR status, permanent normal trade relations status? Well, what that would mean is that China may actually have to you know, if the if that status were to be revoked, what would happen is that China would go to what they call a column two duty rates, which are quite a bit higher than the most favored nation duty rates. Quota regime for textile could reapply to to China as well. And this will be a very interesting report. It's due to come out in August 20 or in August 2026, but the investigation and the kind of the report assembly by the ITC is happening now. So no imminent threat here to it, but it does definitely signals maybe some direction that congress wants to look into. Second, we see that there's a bill introduced to end first sale. This came from senators White House and Cassidy. That was a bipartisan bill, and this would end the first sale program. Now the first sale program isn't widely used. The last time we got real kinda hard data on this about fifteen years ago, it seemed like it's only about maybe 4% of importers could use for sale. But the short version is this has been a very popular kind of duty strategy, in recent years as people have tried to try to maybe hide from IEPA legally, or section three zero one as well by being able to declare the value, of the goods, that came from the manufacturer rather than any kind of intermediary party's value for customs purposes. Thereby, if you don't have to declare a marked up price, you can declare a lower price. You would save, therefore, on a percentage rate of duty. So this would end that practice. The, you know, the existence of first sale kinda came about as a result of a court case based on how value was defined. This came from the nineties, and they said, okay. Well, based on this letter of law, there is the possibility for first sale for export. This would be a bill that would end that, saying, no. It's about what is the sale that kinda brings us to The United States. We're gonna kind of ignore that first sale and set it aside. So there's some there's some very small but very vocal opposition, I think, to this bill, but I think is is noteworthy, especially if this is something that you currently use, or if you lose lose to your competition because of first sale, this may be something to implement or to review closer with your team. There's another one that also was introduced by senator Cassidy and then, representative Arrington to, add more restrictions to nonresident importers. So this would not necessarily end the practice of being a nonresident importer for an IOR, but it would add some more restrictions. Basically, it would require more US banking presence, would require a physical office presence, employees located in The United States, or some sort of subsidiary with a large financial resources happening in The United States. So this wouldn't block every, you know, nonresident importer altogether, but it would go after nonresident importers that are a little more than shell companies that just kind of stand up. You know, at least that's the intent of the law is to go after these these smaller companies that maybe just pop up. They import using DDP methods, then they close-up shop before CBP can get wise. That's what this is intended to to go after. So that bill is also making its way through committees at this time. The fourth one I thought was an interesting one is that the FTC is gonna be reviewing more closely made in USA made in USA claims made online. This is something that's kind of been out there for a while. It's sort of in a sore spot for many in the importing community where it's like, well, I have to have my physical products marked in a retail store with the country of origin and a clear legible place, you know, that can be easily discerned by the ultimate purchaser. But on you know, if I go to some online marketplace, I can't see that. Right? So how is that fair where maybe I might get, you know, penalized at 10%, whereas an ecommerce site maybe doesn't actually list where the country of origin is? This was a directive from the president specifically to focus on online marketplaces for places that claim to say made in USA, which is also kind of a kind of a more protected, label, more protected claim. So, more to kinda see there if you have more of that ecommerce space and you claim to have, US, US production for your products. Okay. And the last one is what I'm gonna dive into a little bit deeper here. These are the section three zero one investigations. If you've been with us for the last few months here to kinda know or seeing, like, how IEPA may end, what might replace IEPA, section three zero one has kind of been threatened as that replacement. It was kind of between section three zero one, three thirty eight. They're going with section three zero one, and they opened up two investigations last week, on Thursday, Friday, to look at, one, either structural excess capacity, overcapacity in in certain industries, and forced labor practices or at least lack of enforcement of forced labor laws. The structural excess of overcapacity affected 16 economies, which includes the EU, 27, and 15 other countries. And the forced labor affected 60 economies, which includes the EU plus many others here. So, with that, let's kinda jump into section three zero one a little bit. First of all, what is section three zero one? This is section three zero one of the Trade Act of 1974. The idea behind this portion of it is that the USTR is authorized to investigate unfair trade practices that burden or discriminate against US commerce. The most famous case you can probably think of in your recent recent past is this was the original investigation that kinda kicked off the China tariffs back in 2018. So this investigation started April 2017, and it was looking into China's specific practices about, okay. You know, there's this industrial policy in China called made in China 2025, and there's quite a lot of state support for those specific industries listed in made in China 2025, semiconductors, robotics, drones, that sort of thing. So they said, okay. Well, that's not you know, this is this is unfairly burdening US commerce. The way they're doing it is through intellectual property theft, forced technology transfer, forcing local partnerships, with Chinese firms, and that's how they're kind of out competing The US. This is an unfair burden to US commerce. And that was kind of the original one in 2018. It kind of specified both the mechanism and the outcome here. Well, this one is different. We kinda have two different cases, and I'm gonna pause here to show the map, which has both of these investigations kind of on it. This isn't just you know, the original one was just for China. Right? But these ones here are much broader. We see the ones that are forced labor only highlighted in blue on the map. We see, the forced labor and this idea of excess, you know, industrial capacity overcapacity, highlighted in green. So these have both concerns about forced labor as well as that excess capacity. We see the EU, China, India. Basically, if you were to add up all blue countries, blue or green countries, this effectively is 99% of US import value. Just by value of imports alone, all of these investigations cover 99% of the total trillions of dollars that The US imports every year. So this really is kind of the way they're looking to recreate some version of IEPA tariffs using a different statute here. So the two investigations, the first one had to do with the structural excess capacity, and this language comes right from the from the notice issued by USTR. They said they're looking into larger persistent trade surpluses in certain manufacturing sectors as well as underutilized and unused capacity. Okay. So making the argument for the USTR, their stance is that there are certain industries where there are large trade surpluses in certain countries, and this is the result of underutilized or unused capacity. Meaning, there's been some sort of likely state support, whether direct or indirect, whether it's in the form of loans or sweetheart deals or land grants, tax exemptions, whatever. Somehow they've been able to keep excess industrial capacity in their country, whereas in maybe a free market, that industrial capacity might flow to some other more productive part of the economy. The accusation goes against, you know, steel industry, mentions chemicals, mentions fertilizers, mentions semiconductors, mentions the Norwegian fishing industry. It basically says that because there's just so much of a glut of excess capacity here, no US producer can really match those prices, and, therefore, they couldn't turn a profit. And therefore, they can't even be created at all. If this sounds familiar, it's not too different than maybe a little bit of kind of antidumping perhaps. I think another way to maybe think about it is that it sounds a little bit similar to almost monopolistic behavior in such a way where the market is being dominated by a single player in this certain industry where nobody else can effectively compete because they've sort of cornered the market. In a sense, that's kind of what they're looking at here in this three zero one investigation is that there's just so much efficiency, so much overcapacity in these countries and certain industries, that nobody can compete with them, specifically nobody in The US. Right? US commerce cannot compete with them. Therefore, that is an unfair trade practice. Like I said, this affects 42 countries, which if you break out the EU into their 27 states plus another 15 ends up being 42, 16 economies, however you wanna however you wanna carve it up here. And the way they seem to be measuring this based on their orders, they're looking at what are the factory utilization percentages. Meaning, if a factory, you know, is a 100% of output, that means the production line is running twenty four seven at maximum output. Right? You know, what does that utilization look like? How how efficient are they? Are they idling their factories in some attempt to either create, you know, artificial scarcity or to kind of, limp this sort of industry along until there is demand, and then all of a sudden, they start producing again, and driving driving prices down. The second thing they're gonna look at is trade deficits in these specific sectors. Okay. The second one has to do with failures about forced labor enforcement. And so, again, taking kind of just a passage from that investigation really kind of teasing it out, they're saying that forced labor exists in a certain country or that the government of that country has not taken sufficient steps to prohibit the importation of goods produced with forced labor. So they're saying one of those blue countries back here, right, either has forced labor in it that is leading to lower wages in those countries thereby burdening US labor, US commerce, or they're saying that these countries maybe have laws against forced labor, but the enforcement is lax. It's missing. It's way too light. Right? That's what they're that's kind of the crux of the of the organization of the of the argument here. And this affects 86 countries. Right? 59 individual independent countries and the 27 EU countries. So this is actually a pretty broad group that they're looking at here, and it affects quite a few. The way they're really looking for this is they say, we want comments to come in, and we wanna investigate enforcement effectiveness of forced labor laws. Like, how successful are these laws really in kind of measuring this? And, I think for both of these, I think there's a fair number of kinda critiques to both of these investigations I think sets it apart from maybe some of the earlier investigations we saw in 2018 with China, the digital services tax against the EU, even kind of some of the Brazilian one issued last year, the Nicaraguan one in 2024. I think one of these sets us a little bit of apart is that it's a bit maybe flat and circular where instead of saying, okay. Here's this, you know, existing policy in this country, and here's the negative outcome. They're pointing more to the negative outcomes and hoping to find the policy seeming to be as part of the investigation. So rather than sort of finding proof of the accusation, they're setting a condition and now searching for a little bit more proof. And that maybe makes it a little bit thinner perhaps than the original section three zero one investigations, on China, for instance, where they said, okay. So these unfair practices here, this forced labor transfer, this kind of state sponsored industrial policy, these 0% interest loans, and that's leading to overcapacity in these places. Therefore, please place tariffs. Right? So I think that part is is missing. And I think, you know, maybe one of the reasons why is maybe something we all kind of intuitively know, but USTR would never say, is that this is really kind of meant as a replacement for AEPA. Right? All of a sudden, out of seemingly nowhere, huge investigations, sweeping investigations on 99% of US import value kinda comes out and only comes out after the end of IEPA. It's hard to ignore that kind of context and say, well, are these investigations truly legitimate or not? Right? It's a bit of a a bit of an open question, and that is something that I think is going to maybe creak open the door to more legal challenges. I think another thing that's gonna be difficult in these investigations for the USTR is there's an obligation as part of section three zero one for the USTR to try to negotiate with these countries and say, hey. You know, we've noticed you have this unfair practice. It's burdening US commerce. We'd like you to change it. Well, what if the country says, you got us. We'll change it. Does that mean now tariffs can't be implemented? Probably not, but it does make it a little bit harder for the USTR to be able to defend that case should they ever face a legal challenge. I think another one as well is that I think it's pretty easy to maybe see some a little bit of hypocrisy as well maybe on the part of The US when I think about how those trade negotiations might go. The US is a 10% owner in intel. Right? Is that a form of state support for private industry to try to fund our own excess capacity and chip design? Perhaps. How many trade deals have tried to, implement good deals for soybean farmers in The United States? Seems like that's something that's very common in many of these announced deals and agreements. Is that just our own form of structural excess capacity? Maybe it is. Maybe it's not. It kind of depends on how exactly that comes up. When it comes on the forced labor side as well, The US has had only enforced about 54, 55 withhold release orders since you flip the Uighur forced labor protection act against, you know, originally Chinese cotton, but now a couple other Chinese products as well. They're seeing all this, and they're saying, well, wait a minute. You also don't you have forced labor? The AP did that thing about, you know, Louisiana prisons. Right? Don't you guys have forced labor in your supply chains? It's a very interesting thing. As well as the USTR is not a big fan of the EU's corporate sustainability due diligence directive, CS triple b, which can be certainly seen as burdensome, but has very strong forced labor enforcement requirements for companies. Why on one hand is USTR a little bit upset about the CS triple d, but then also saying, EU, you're not doing enough to enforce, forced labor rules. A little bit a little bit hard to separate that. And I think the final thing here is we're also existing here in 2026 different than back in 2018, 2019 in a post loper bright world. Right? That took away Chevron deference from a lot of, you know, the the ambiguous statutes and laws. Right? Before that case came down, government agencies were given a little bit of deference, a little bit of preference in judicial proceedings whenever a statute is ambiguous saying, okay, the agencies can can interpret this correctly. We're gonna give a little bit more leeway to them. Well, that leeway is now gone. So what does it mean to be an unfair trade practice in this post Chevron world here? Is it a little bit easier for an importer to make a case saying the merits of this three zero one investigation is invalid? Maybe so. I think that's a very fair point that will probably get raised. I'd imagine trade lawyers are gonna be busy for quite a long time as they kind of look to maybe attack this three zero one investigation from a bunch of different angles, and we will see kind of what happens. But all those, like, kind of legal challenges, the timeline is probably far away. And as we talk about kind of the general timeline for 03/2001, both of these have public comments that you can make now if you so choose. Maybe you wanna make it directly. Maybe you wanna partner with your industry lobby group through the fifteenth, and you can even request to appear in person in front of the USTR to give testimony if you like. The USTR will take all that information. They'll make a report of their findings, and then they'll recommend to the president should tariffs be implemented on which countries and in how much. And I fully expect these investigations to go together really quickly. Usually, we've been seeing these three zero one investigations take about a year, but I strongly suspect they have a soft deadline of July 24, which is when the hundred and fifty days elapses for section one twenty two. So we should watch this carefully here. I still think there's challenges maybe to section three zero one. That isn't gonna be the case, but I'm not sure we'll see many of them be successful until after this implementation, which I expect to be on or before July 24. So that's just a little bit of background about what happened here for section three zero one, but the other main headline of the day we wanna talk about is IEPA refunds. How can I get my money back from last year? And so for that, I will hand this over here to Jen to tell us more about the refund updates.

Jenn Park

Great. Thanks, Marcus. All right. Let me start with the next slide. I know we were all anticipating the decision for the selections and learning resources being remanded back down to the Federal Circuit and the CIT to really understand what that refund mechanism will be. However, this discussion will actually be on a different case, which is at misfiltration, where we are able to get some more clarity on how the refunds may be issued back to importers. I know Marcus touched on it earlier on, giving a brief summary, but the purpose of the next few slides will kind of give you a little bit more detail in terms of what we can expect on the refund process, how and the when. And so this is just a quick snapshot of a timeline of what has happened since February 20 when the Supreme Court decision came out that these tariffs were unconstitutional. You'll see that starting February 24 is when IAPA stops were stopped on were being collected by customs. And then March 4 is kind of, like, the tipping point in terms of the latest update on how refunds will be issued. If we go to the next slide, I'll kinda walk through this in more detail. And so March 4, what happened in that case is there is a Eaton, which is now gonna be the presiding judge over all IIPA cases at the CIT, has come out basically ordering universal refunds. So even if you did not file a case at the CIT, he is saying that he wants importers to receive refunds. Also, he wanted a process where it's gonna be easy. So he what he wants to avoid is having importers file civil suits at the CIT to request their refunds, but instead, he's looking more along the lines of an automatic refund. And so what he had directed customs is that we want he wants a process where all entries that are unliquidated be liquidated without the tariffs and if all liquidated entries be reliquidated without IEPA tariffs. And he gave basically customs up until the sixth to provide a response to his decision. And so March 6 was a Friday, and I believe Friday or Thursday, where Customs came back with their proposed solution. Basically, what they said is that it's impossible for Customs to have automatic refunds. Their systems are set up. So their system is ACE. It's set up in a way where entry is automatically liquidated within this three hundred fourteen day cycle, and it's impossible for customs to go in and change that liquidation because that would need to be done manually. And so it's just systematically impossible for customs to do this. But instead, what they're proposing is a new solution, which is a new ACE functionality. Now we know that it's called Cape. They're currently building it today, and they expect it to be built within the next forty five days. So I believe the expected completion date is April 20. But this will allow importers to update their data to the ACE platform, and customs will review that data and be able to issue the refunds then. So this allows customs to not have to go in manually and reliquidate entries or look at all the entries because that would essentially take four point four million working hours, and that's gonna it's gonna be impossible for them to do that but also take forever for the refunds to happen, but they believe that through this new functionality that it will be very streamlined and efficient so that they'd be able to get their refunds back to importers more quickly. The important thing from this response is the stats that were provided. We are in from this report, Customs has updated that there are a 166,000,000,000 AIIPA tariffs that were paid. 330 over three hundred three hundred and thirty thousand importers paid AIIPA tariffs on over 53,000,000 entries. And this is why they're saying it's going to take four point four million working hours for them to process all these refunds. Another important stat is that refunds will be issued electronically. I know February 6 was that date where we were all pushing for all importers to get ACH refunds set up, but they have called out in this that only 6%, less than 10% of importers are actually set up for ACH refund. And if you do not have ACH set up, your refunds will be rejected. And so the next few slides will kind of walk through what you can prepare in the meantime, but I would say this is very important. If you do not have ACH refund set up in ACE, that is probably the one thing you wanna do to prepare as we wait for this April 20 deadline. March 12 was another update. As Marcus mentioned, their customs will be providing a progress report update on their new platform to CIT. And the latest one was from March 12, and we were able to get more insight as to the process. I wanted to kind of walk through the process in more detail so employers kind of have an idea of what that refund mechanism will look like in ACE. And so what they've done is broken it down to four specific steps. And the first step is the claim portal, which is they are going to require all importers to upload a CSV file of their data. This CSV file, we're not sure as to what information it will require, but we know that it's gonna be very specific because the claim portal will have two verification points. It's gonna be the file verification and the entry verification. The file verification is basically making sure that the information is all the required information is contained in the file, but also it's properly formatted. Once that verification step is completed, it'll go through verification step where it will make sure that the entry numbers on it are correct, it's not missing any data points, but also that these entries have 99 IPA codes tied to them. And so once that verification step second step is complete, it will go into mass processing, which is automatically removing all of the IIPA tariffs, and it will go through a verification step then. And then this the most important step is this review and liquidation step that I wanted to call out is once all of this once all the IFA tariffs are removed, what will happen to your entries is that it will there will be a scheduled liquidation or reliquidation date from the date of your CAEP acceptance date. So it's not automatically liquidated, but at this point, there is gonna be a scheduled date that you can anticipate for entries to be liquidating or reliquidating. And the purpose of this is customs is saying until that point where it's that scheduled date, they will be doing manual reviews on these entries. And so I think that's why you kinda hear the industry saying you should be auditing your entries, making sure everything is correct because customs has said over and over again, even on March 6, in their response, that Customs does have the right to review all of the entries so that there is no violation of Customs laws and correct duties and tariffs are paid. So we can anticipate that review being conducted during this process. And once this process is, validated, then it will go through the whole refund process of issuing those refunds, but also, as I mentioned, electronically. I just wanna make sure that you also understand this is a phased approach. So I know some imports are very excited that, wow, this is gonna happen for all our entries. We can start uploading our CSV at this point. But what Customs is saying that there it's gonna be a phased approach in terms of what entries they're gonna review first. So they've called out that there are some entries they are gonna exclude in this first phase, and those are, you know, entries that are subject to antidumping, any any entries that are suspended or extended under review, but also specific entry types, which are warehouse withdrawals and also drawback entries that are tied to a drawback claim. So more to come on that. It's unclear as to the exact process of how it'll work other than what's been provided today, but we can anticipate another update from CVP on their progress on the nineteenth of this week. Yep. And then the question we get a lot from importers is, do we still need to file a protest despite this whole CAPE functionality being an automatic refund process? And our answer is that, probably. If you look at the decision from Judge Eaton from the March 14 atmospheric decision, he specifically calls out that any and all unliquidated entries, they should be liquidated without the tariffs. And it says any liquidated entries for which liquidation is not final shall be reliquidated in regards to IIPA tariffs. So I think that not final is that keyword. And if you look at the entry liquidation cycle, we kind of showed you a little graph here to kind of fully understand how entries liquidate. You know, there's the entry date. Three hundred fourteen days is kind of like that automatic liquidation cycle. This is a general standard liquidation time line, but, you know, it may be diff there may be a little bit outliers for entries where there was a CF twenty eight twenty nine issued or if there was a PSC filed. Those will liquidate a lot sooner than three hundred fourteen days. And then once that liquidation happens, you have about a hundred and eighty days to file a protest. And so after that hundred and eighty days is over, that's when an entry finally liquidates. So what we're assuming is that any entries that are within this particular timeline of three and fourteen plus hundred and eighty days is what this k functionality will address. But after this, it's it's uncertain as to how refunds will be issued on these entries where it's past this hundred and eighty day protest deadline. And so what we're saying is until this functionality is up and running, there are entries that are continuing to liquidate. So for those entries that were cleared with the Mexico and Canada fentanyl tariffs that were entered in February, I believe those were liquidated starting December, and the protest deadline is about May. For the April ones, I think those are okay in terms of majority are unliquidated, and that protest deadline is not until about July. What we're saying is we don't know how soon this cave functionality will be up and running. And then what I mentioned before verification process, if customs finds that some entries don't pass that entry and file verification, they will push it back to the importer. So we don't know if that means that your entries are still gonna continue down this liquidation timeline. And so what we're just proposing is that be prepared. It's really silent in terms of what how refunds will be issued on entries that are past the final liquidation phase. So it is probably best to file a protest on any entries that are nearing that final location, so nearing that protest deadline. So in order to preserve your rights to those refunds, probably best to file a protest, especially if you're not filing a civil suit at the CIT under 1581I. All right. And then the steps on how Flexport, our trade advisory team, can support for IPER refunds. We have already started helping importers today, but, you know, some of the processes that we've outlined here is to really make sure that importers are ready, especially if once CABEs running. But in order to just manage everything for an importer, just kind of taking off the administrative burden, making sure that we can assist in being proactive on how importers can prepare for the process, We are more than happy to kind of pull your report, identify all the entries with the IPA tariffs, monitor all the liquidation timelines and protest deadlines, and file those protests as needed. But also, if there are any importers that are wanting to audit their entries to make sure that the tariffs that are paid were correctly, if there's any other errors that need to be addressed prior to requesting the IAPA refunds, you know, we do have a process.