Global Trade and Tariffs Brief, Sep 24

01Key takeaways

The US tariff wall now rests on Section 232 and Section 301, refunds are flowing, and the summit's tariff cuts are announced but not implemented

Between Sep 24 and Oct 23, 2026, the US tariff system settled onto new legal ground, refunds moved at scale, and the US–China summit produced announcements that are not yet implemented. Pick a conclusion to see its evidence and the module that proves it.

Five conclusions

The US tariff wall rests on Section 232 and 301, not on IEEPA

The Supreme Court held on Feb 20, 2026 that IEEPA does not allow tariffs, and the Section 122 bridge expired on Jul 24. A Section 301 action with 10% and 12.5% tiers has applied to about 60 economies since then. Section 232 carries the product rates: 50% on steel and aluminum under Annex I-A, and on patented pharmaceuticals 100% general, 15% for the EU, Japan, Korea and Switzerland, and 0% for the UK. Penn Wharton puts the effective rate at 7.1% in August, 24.3% for China.

Section 301 · 10% and 12.5% tiers · in effect since Jul 24 (context)Section 232 steel and aluminum · 50% · in effectEffective rate 7.1% · reported, Aug 2026

See module 2 →

Refunds are flowing, with gaps

By Oct 2, CBP had accepted $136.6B and sent $126.0B (92%) through CAPE, with $1.1B on hold for missing bank details. A class was certified on Oct 8 in Freestyle World, but certification is not a refund order, and non-filers with finally liquidated entries stay outside CAPE.

$136.6B accepted · $126.0B sent · Oct 2 · in effect$1.1B on hold · missing bank detailsClass certified Oct 8 · not a refund order

See module 3 →

The summit announced cuts; none is implemented

After the Sept 23–25 visit, the two sides announced that goods worth about $30B each way (2024 trade) would be recommended for reduced tariffs, and the truce was extended from Nov 10, 2026 to Jan 10, 2027. Washington calls the cuts recommendations and Beijing calls them an agreement; the sources show no implementing notice from either government. Capital Economics puts the average US tariff on China at about 22% falling to 20.5% (estimate).

$30B each way · announced, not implementedTruce to Jan 10, 2027 · announced22% to 20.5% · estimate (Capital Economics)

See module 4 →

Agreements moved slowly

The only dated formal act in the window was USTR's Oct 2 consultation on the 2027 USMCA review, with comments due Jan 12, 2027. The US–Mexico talks are reported as stalled, and Secretary Rubio said on Oct 20 that a "small number of items" remain on the India deal, which is still unsigned.

USMCA consultation · Oct 2 · open · comments due Jan 12, 2027US–Mexico · reported stalled (Reuters, Oct 15)India · framework, unsigned

See module 5 →

Trade grows on AI goods, and remedies keep widening

The WTO raised its 2026 merchandise volume forecast to 3.9% from 1.9% in March (estimate), with AI-enabling goods behind 47% of value growth, and the US August deficit was $105.6B on record imports of $420.8B. A US petition on Chinese amine compounds was filed on Sep 29, and the ITC made a final affirmative solar finding on Oct 14.

WTO 3.9% · estimate · Oct 8US deficit $105.6B · Aug 2026 · BEA/CensusAmine petition Sep 29 · ITC final solar finding Oct 14

See modules 6 and 7 →

Measures at a glance

Issuer	Measure and scope	Effective	Status on Oct 24	Source
USTR	Section 301 forced-labor action10% and 12.5% tiers, about 60 economies	Jul 24, 2026	In effect Context	Argents
Commerce	Section 232 pharmaceuticals100% general; 15% EU, Japan, Korea, Switzerland; 0% UK	Final phase Sep 29, 2026	In effect	WilmerHale
BIS	"U.S. content" notice for metal tariffs25% on non-U.S. content, 15% floor	Oct 14, 2026	In effect	Diaz Trade Law
CBP	IEEPA refunds through CAPE$136.6B accepted by Oct 2	Phase 3 from Oct 6	In effect	StartBusinessByState
US and China	Reduced tariffs on about $30B each wayRecommended	Not implemented	Announced Not implemented	White House
US and China	Truce extensionNov 10, 2026 to Jan 10, 2027	Announced	Announced	MOFCOM via Global Times
USTR	USMCA 2027 review consultationComments due Jan 12, 2027	Oct 2, 2026	Open	USTR
Commerce, ITC	Amine compounds from ChinaAD and CVD petition	Filed Sep 29, 2026	ITC preliminary phase	Federal Register

Count only the in effect rows as changes. The summit cuts and the truce extension are announced; the USMCA consultation and the amine petition are open procedures, not tariffs.

02US rates by category

Section 232 sets the product rates up to 100% and Section 301 sets the country rates of 10% and 12.5%

Since IEEPA fell, the US tariff wall rests on Section 232 (by product, up to 100%) and Section 301 (by country, 10–12.5%). Measures dated before Sep 24 are labelled context, those dated Sep 24 to Oct 23 are window, and later dates are upcoming.

Headline rates by category

Section 232 (by product)Section 301 (by country)Section 338 (Canada)

All rows are in effect. Rates are those given in the sources, and the bases differ: the rows must not be added across legal bases. Section 301 tiers apply to most goods from about 60 economies; the 12.5% tier is inclusive of MFN for Japan, Korea and Switzerland. Dates: Section 232 pharmaceuticals Sep 29, 2026 (window); steel and aluminum Apr 6, 2026, Canadian goods Sep 15, 2026, Brazil Jul 22, 2026 and Section 301 tiers Jul 24, 2026 (context).

Three measures, one by one

100%

In effect general rate on patented drugs and ingredients (Proclamation 11020, signed Apr 2, 2026). Final phase Sep 29 for firms outside Annex III; listed firms started Jul 31.

15% / 0%

15% total, inclusive of Column 1, for the EU, Japan, Korea, Switzerland and Liechtenstein; UK 0% per CBP's Aug 1 guidance (the April summary said 10%; we follow CBP).

20% / 0%

20% plus Column 1 for firms with approved onshoring plans through Apr 1, 2030, then 100% from Apr 2, 2030; 0% through Jan 20, 2029 with an HHS pricing agreement.

The rate is not added to the ordinary duty; Column 1 applies where it is higher. Generics and biosimilars are 0%, to be reviewed within a year. BIS guidance of Sep 21 (another source says Sep 23) added 0% for specialty products from 19 listed jurisdictions or groupings. WilmerHale reports that listed firms are now generally at 100% unless an exclusion applies.

Oct 14

In effect BIS notice FR Doc. 2026-20938, effective for entries from 12:01 a.m. ET that day (window). It defines U.S. content for USMCA-qualifying Canadian and Mexican goods.

25% → 15%

25% on non-U.S. content with a 15% floor. With the 0% line capped at 40% of value, 25% × (100% − 40%) = 15%, exactly the floor.

2.5 pts

Each extra 10 points of U.S. content credited cuts the duty by 2.5 points (Forwarder News), so the wider definition only helps goods below the cap.

"U.S. content" means value from parts wholly obtained, entirely produced or substantially transformed in the US, plus US-melted steel or US-smelted aluminum and copper not already counted. The notice sets no filing procedure, CBP's Jun 5 message (CSMS #68855869) still caps the 0% line at 40% of value, and Diaz Trade Law expects CBP may update its guidance. Base rates: 50% Annex I-A and 25% Annex I-B on steel, aluminum and copper (Apr 6, 2026, context).

37.5%

Legal stack on China List 1–3 goods: 25% legacy Section 301 plus the 12.5% tier (25 + 12.5). List 4A carries 7.5% (in effect, context).

178

Upcoming China exclusion lines (164 general, 14 solar equipment) run through Nov 9, 2026. No extension announced (Thomson Reuters).

Dec 4

Scheduled Polysilicon under Section 232: minimum price plus 15% from Dec 4, 2026.

Two dates need care: Argents and Summit Sourcing say the exclusions run "through 11:59 p.m." on Nov 9, while Thomson Reuters, Gateway Lines and The Russo Firm give Nov 10. Both fit: Nov 9 is the last day covered and Nov 10 the first day without cover. Suspended port fees on Chinese-built vessels also run to Nov 9, with a decision due Nov 10 (Argents). The Sep 27–28 "30-for-30" lists have no Federal Register notice yet (module 4). USTR opened a second four-year China review on May 6.

Rate comparison by product category

Category	Measure (issuer, basis)	Rate	Effective	Status on Oct 24
Most goods, about 60 economies	USTR, Section 301 forced-labor action	10% tier (incl. Canada, Mexico, India, UK); 12.5% tier (incl. China, Vietnam). EU, Taiwan 10% and Japan, Korea, Switzerland 12.5%, inclusive of MFN	Jul 24, 2026	In effect Context two CIT suits pending
Same goods, before Jul 24	President, Section 122	10% global surcharge	Feb 24 to Jul 23, 2026	Expired Jul 24 (context) CIT ruled it unlawful May 7, stayed on appeal
Reciprocal and fentanyl tariffs	President, IEEPA	Several rates; held unlawful	Collection stopped Feb 24, 2026	Terminated (context) refunds under way
Brazil	USTR, Section 301	25% on most imports	Jul 22, 2026	In effect Context
China, legacy	USTR, Section 301 Lists 1–4A	25% (Lists 1–3), 7.5% (4A); up to 100% on EVs. Adding 12.5% gives 25 + 12.5 = 37.5% on List 1–3 goods	2018–Jan 1, 2026	In effect Context
China, 178 excluded lines	USTR, Section 301 exclusions (HTS 9903.88.69, .70)	Exclusion from 301 duty	Through Nov 9, 2026	Upcoming expiry; no extension announced
Steel, aluminum, copper, derivatives	Commerce/President, Section 232 (Proc. 11021)	50% Annex I-A; 25% Annex I-B; 15% combined cap, Annex III; 200% Russian aluminum	Apr 6, 2026	In effect Context Annex III relief to Dec 31, 2027
Canada/Mexico USMCA metals (Annex I-C)	Section 232 (Proc. 11032)	25% on non-U.S. content, floor 15%	Jun 8, 2026–Dec 31, 2027	In effect U.S.-content definition Oct 14 (window)
Patented pharmaceuticals	Section 232 (Proc. 11020)	100% general; 15% EU, Japan, Korea, Switzerland; 0% UK	Jul 31 (listed firms); Sep 29, 2026 (others)	In effect final phase Sep 29 (window)
Vehicles, trucks, buses	Section 232	25% / 25% / 10%	Apr 3 and Nov 1, 2025	In effect Context
Polysilicon	Section 232	Minimum price plus 15%	Dec 4, 2026	Scheduled upcoming
Canadian goods	President, Section 338	Additional 50%, scope modified; stacks on 232	Sep 15, 2026	In effect Context

Sources: Argents, WilmerHale, Diaz Trade Law, Thomson Reuters, Summit Sourcing, Gateway Lines, The Russo Firm, Airlift USA, RVIA.

03Refunds and revenue

Refunds of IEEPA duties have reached $126.0B sent, but acceptances are flattening and about $30B sits outside CAPE

The Supreme Court held 6 to 3 in Learning Resources, Inc. v. Trump on Feb 20, 2026 that IEEPA does not allow tariffs. Only the IEEPA layer is being repaid; Section 301 and Section 232 duties stay in place.

CAPE refunds: accepted and sent

CBP court filings as compiled by StartBusinessByState, in $ billion. Accepted vs sent to Treasury on Jun 29, Jul 31, Aug 21, Sep 11 and Oct 2, 2026. Acceptances are flattening: +$3.8B, +$2.2B and +$1.9B over the three-week gaps. A court order put the Sep 11 figure at $134.2B; we use CBP's filing.

Share of accepted refunds sent to Treasury. 68% on Jun 29, 78% on Jul 31, 80% on Aug 21, 91% on Sep 11 and 92% on Oct 2 (126.0 ÷ 136.6). Source: CBP court filings as compiled by StartBusinessByState.

The refund path and the revenue picture

$166B

Paid by 330,000 importers on 53 million entries, as CBP told the Court of International Trade.

Phase 3

In effect Opened Oct 6 for importers that sued and hold court-ordered reliquidation; 477 declarations covering 425,517 entries accepted by noon.

~$30B

Gap between $166B paid and $136.6B accepted (166 − 136.6 = 29.4), close to the figure Peacock Tariff Consulting attributes to the court.

Phase 1 (since Apr 20) covers unliquidated entries and those liquidated within 80 days; Phase 2 began Jun 29. About 20,362 refunds worth $1.1B were on hold for missing bank details on Oct 2. On Oct 8 Judge Eaton certified a class of importers that paid IEEPA duties and have not sued (Freestyle World); Troutman Pepper Locke notes that certification is not a refund order. Per Peacock Tariff Consulting, the government's appeal against relief for non-plaintiffs is pending at the Federal Circuit, so non-filers with finally liquidated entries stay outside CAPE. Section 122 duties are outside CAPE (Great Lakes Customs Law), and the Section 301 forced-labor challenge awaits a first CIT decision.

7.1%

Reported Penn Wharton average effective tariff rate, Aug 2026, up from 6.7% in July and 2.3% in Jan 2025.

24.3%

China's effective rate (duties ÷ imports); steel and aluminum 39.8%, vehicles 13.8%. USMCA exemption claims reached 81.4% of Canada–Mexico imports.

$173B

Reported Net tariff income, down 11%, with about $145B refunded in fiscal 2026 (Treasury figures reported by Reuters via Newsweek).

The 24.3% China figure is duties ÷ imports; the 37.5% legal stack in module 2 is a different measure. Implied gross receipts are about 173 + 145 = $318B. Eco3min's reading of Treasury statements shows June refunds of $49.18B and negative net customs receipts in May (−$0.04B), June (−$25.56B) and July (−$8.55B). The Congressional Budget Office estimated in August that fiscal 2026 net customs revenue would be about $250B below its February projection (Estimate).

04US–China summit

The summit produced a framework and a calendar, not a tariff change: the $30B-for-$30B cuts are announced and not implemented

Xi Jinping arrived in Washington on Sept 23, 2026 and left on Sept 25; the leaders' talks were on Sept 24 and 25. One law firm dates the summit Sept 24–26; this page follows Sept 23–25. The sources show no implementing notice from either government.

Two readouts, one framework

Item	US position	China position	Date	Status on Oct 24
Board of Trade and Board of Investment	White House: "operationalized"; Bessent and Greer oversee	MOFCOM: Board of Trade set up; mandate details "released subsequently"	Leaders, Sept 23–25	In operation deputies meet at least quarterly
$30B-for-$30B tariff cuts	"Recommendations" for more favorable treatment	"Agreed to reduce"; takes effect simultaneously after domestic procedures	Lists: Sept 27 (US), Sept 28 (MOFCOM)	Announced Not implemented
Truce extension	Bessent on Fox, Sept 23: conditions stay until Jan 10, 2027; the White House had not documented it	MOFCOM: extends the "Kuala Lumpur trade arrangement" from Nov 10, 2026 to Jan 10, 2027	Sept 23 (US); Sept 28 (China)	Announced by both
Coal	China to import at least 10 million metric tons in 2027 and 2028	Coal tariffs sit inside the framework; no tonnage in this account	Sept 27–28	Announced
AI	"Super Intelligence" Dialogue; incident channel; next exchange by Nov 2026	"AI dialogue" led by He Lifeng and Bessent; first session held; next before end of November	Sept 25 (US); Sept 28 (China)	Dialogue running channel "agreed to establish", not yet running

Announced versus implemented. Washington calls the cuts "recommendations", to be implemented under each side's domestic legal processes; Beijing calls them an agreement taking effect simultaneously. Neither side gave a timetable. According to Thomson Reuters, the US had issued no Federal Register notice, proclamation or HTSUS Chapter 99 amendment (date of that check not stated).

What the two lists cover

Bloomberg figures. The US list has 77 entries and China's list 1,619 (we follow AP, Bloomberg, CNN and Thomson Reuters; Anadolu reverses the counts). Covered imports fell 28% for the US list and 35% for China's list from 2024 to 2025. The 2025 figures sum to $42.5B, about 10% of the $415B the two countries exchanged in 2025.

Estimate (Capital Economics). The average US tariff on China falls from about 22% to 20.5%, a drop of 1.5 points. It is the only estimate tied to these lists; the stack itself is module 2's. CNN describes the truce level as 30% on Chinese goods and 10% on US goods; Thomson Reuters puts the effective rate on most Chinese goods at about 37.5%.

Goods, rates and the truce calendar

1,619

China's list (US goods): agricultural goods, fish and seafood, logs and wood, cosmetics and medical devices. Reuters adds corn, wheat, sorghum, meat, dairy and vegetable oils; non-seed soybeans are excluded. MOFCOM adds coal.

US list (Chinese goods): small appliances, toys, holiday decorations and children's car seats. AP adds fireworks, tableware, glassware and soccer balls.

Left out

Chips, electric vehicles and batteries. According to Thomson Reuters, rare earths, aircraft, steel, pharmaceuticals, crude and LNG are excluded too, as are toys with Wi-Fi, Bluetooth or Ethernet.

~90%

MOFCOM says about 90% of products on each side move to most-favored-nation (MFN) rates. What happens to the other ~10% is not stated.

22% → 20.5%

Estimate Capital Economics: average US tariff on China, a drop of 1.5 points.

No per-line rate

No per-line rate appears in the sources. AP says MFN rates are the WTO standard and often in single digits.

The summit produced a framework and a calendar, not a tariff change: both sides announced $30B-for-$30B lists and a truce to Jan 10, 2027, but the sources show no implementing notice from either government.

What the truce suspends

China's rare earth export controls, including the 0.1% extraterritorial threshold, are paused, and the US BIS Affiliates Rule (50% ownership) is suspended. As of Oct 21, neither the White House nor BIS had issued a statement or rule confirming the extended Affiliates Rule suspension.

Two framings of the extra two months

Greer called them "compliance periods" to test China's farm and rare earth commitments. MOFCOM called them room to "review and assess" and expects a "positive solution" on a further extension before year-end. Bessent said he did not know whether a bigger deal would be reached by Jan 10.

Date	Event	Status on Oct 24
Nov 9, 2026	Section 301 pause on fees for China-linked vessels ends unless extended, according to DSCP; NRF asked for an extension on Sept 23	Upcoming
November 2026	APEC summit, Shenzhen (day not stated); second AI dialogue by end of November	Upcoming
December 2026	G20, Florida	Upcoming
By end-2026	First meeting of the agricultural working group	Upcoming
Jan 10, 2027	New truce expiry	Upcoming

05Agreements and negotiations

Agreements moved slowly: one dated formal act, a stalled Mexico round and India close but unsigned

The sources record no newly signed US trade agreement in the window. The only dated formal step is USTR's Oct 2, 2026 USMCA comment request (deadline Jan 12, 2027). In force means legal text applies; framework means an outline without final text; under negotiation means talks continue. The last two are not tariff changes.

Agreements at a glance

Partner	Status on Oct 24, 2026	Key terms and tariff rate	Date	Source
USMCA (Canada, Mexico)	In force annual reviews	US declined a 16-year extension; term ends Jul 1, 2036. Rate: rules unchanged (NFFS)	Review Jul 1, 2026 (context); consultation Oct 2 (window)	USTR; GHY; NFFS
US–Mexico	Under negotiation reported stalled	Autos, steel, aluminum disputed. Autos 25%; steel, aluminum 50%	Reuters Oct 15	RFD-TV; MSCI
US–Canada	No agreement; tariff dispute	Section 338 vs Canadian counter-tariffs. US 50%; Canada 15%, 25%, 50%	Aug 19 and Sep 8 (context, in effect)	Benesch; RVIA
EU–US	Framework (2025) applied in tariff schedule	15% autos, patented drugs; metals 50%. Section 301 top-up to 10%	Aug 21, 2025 (context); snapshot Oct 8	Legal500; Airlift
Switzerland–US	Agreement terms not stated in the sources	Rates only. Section 301 top-up to 12.5%	Snapshot Oct 8	Airlift
India–US	Framework (Feb 2026) unsigned	"Small number of items left". Framework 18%; in effect 10%	Rubio, Oct 20	AP; Airlift
Canada–India	Under negotiation reported	Target: G20 Miami, December. Rate not stated	Date not stated	WWD
EU–Philippines	Under negotiation "substantial agreement" on FTA talks	Not signed. Rate not stated	Date not stated	EY

Three negotiation tracks

Oct 2

Open USTR announced a public consultation ahead of the 2027 joint review, "as directed by Congress", plus a hearing whose date and location are still to be published.

Jan 12, 2027

Upcoming Comments (Docket USTR-2026-0595) and hearing requests with a testimony summary (Docket USTR-2026-0596) are due by 11:59 p.m. EST.

Jul 1, 2036

Term end if no extension is confirmed. At the Jul 1, 2026 review (context) the US did not agree to a new 16-year term; NFFS notes this does not terminate the agreement or change its rules.

According to the SBA Office of Advocacy, the Federal Register request followed on Oct 5 (cited as 91 FR 63379 by C.H. Robinson). According to GHY, rebuttals are due seven calendar days after the hearing ends and remarks are capped at five minutes.

Stalled

Reuters reported on Oct 15 that US–Mexico progress had stalled, though talks continued. MSCI (Oct 5): the fourth round was postponed from late September to October. Whether it took place is not stated.

+50%

In effect Section 338 on Canada-origin motor vehicle, alcohol and dairy goods from Aug 19 (three proclamations of Jul 20; context). Scope changed Sep 15; the duty stacks on Section 232.

C$27.6B

Canada's Finance Department listed 874 items at 15%, 25% or 50%, effective Sep 8 (context). Rio Times (Oct 15): the US applies 50% to roughly US$20B of Canadian goods.

An RFD-TV commentator says Commerce Secretary Lutnick opposes deep cuts to the 25% auto and 50% metals tariffs; that is his claim, not an official statement. Section 338 excludes energy, potash and goods already under Section 232 but applies to USMCA-qualifying goods, so the agreement is the baseline while the US acts outside it. No new Canada measure dated Sep 24 to Oct 23 appears in the sources.

EU 10%

Airlift snapshot (Oct 8): Section 301 duty in force since Jul 24, 2026 tops EU goods up to 10% in total, with 43 exempt HTS lines. EU cars and parts, patented drugs and upholstered furniture pay 15% in total; steel and aluminum 50%.

Swiss 12.5%

Top-up to 12.5% with 134 exempt HTS lines and a 15% cap on patented drugs. No US–Swiss agreement text is in the sources. USAFacts: Swiss average effective rate 3.2% in Aug 2026 against 6.9% for all imports.

India 10%

India pays a 10% Section 301 duty plus its ordinary duty; the Feb 2026 framework (18%) is "not yet in force". Sitharaman said talks had "plateaued"; Greer said an announcement was not "imminent".

The EU framework (announced Aug 21, 2025; Executive Order 14346; Federal Register notice Sep 25) is context; the sources have no October 2026 implementation notice. On Oct 21 PwC reported that the Court of International Trade heard a challenge by four small businesses and 25 states to the Section 301 tariffs on 60 partners, with a ruling expected "in the coming weeks". On Oct 20 Rubio said "a small number of items" remained on India. India is closest, but only as a statement; the EU and Switzerland have rates but no new text in the window.

06Trade remedies

Remedy numbers this month are mostly allegations and estimated dates, and only solar and one steel review carry final rates

"Alleged" means a petitioner's figure, not a Commerce or MOFCOM rate. Dates marked est. are law-firm schedules, not agency orders. The solar orders had not been published in the sources.

Case table: what moved in the window

Product	Country	Authority	Stage (date)	Rate or finding	Next date
Amine compounds	China	ITC / Commerce, AD+CVD	Petition 29 Sep; ITC preliminary phase (window)	Alleged AD 261.34–476.13%; CVD "above de minimis"	ITC vote 13 Nov (est.)
Crystalline silicon PV cells	India, Indonesia, Laos	ITC, then Commerce	ITC final, affirmative, 14 Oct (window)	Final Injury found; Commerce final rates set 11 Sep (context)	Orders ~2 Nov; ITC report by 23 Nov
Seamless pipe (SSLPP)	Georgia (AD); India (AD+CVD)	Commerce / ITC	Petition 14 Oct (window)	Alleged AD Georgia 113.87–281.24%, India 41.03–63.57%	Initiation 3 Nov (est.)
Wooden fence pickets; railway tank cars	China; Mexico	Commerce / ITC	Petitions 24 Sep; 30 Sep (window)	Not stated in the sources	Not stated
Chassis, subassemblies	China (Vietnam-made scope)	Court of International Trade	Remand 7 Oct (window)	Deposits stay Scope ruling rejected	Redetermination due 5 Jan 2027
Chassis; diamond sawblades	China	ITC	Sunset reviews, affirmative, 21 Oct (window)	Orders stay in place	Reports by 27 Nov / 25 Nov
Hot-rolled steel flat	Japan	Commerce	Final review results 14 Oct (window)	Final NSC 13.96%; Tokyo Steel 0%	Not stated
p-Nitrotoluene	EU	MOFCOM	Initiated 3 Oct (window)	Alleged No duty; alleged margin above 100%	Conclude by 3 Oct 2027

Most numbers in this month's remedy news are allegations or estimated dates. Only the solar investigations and one steel review carry final Commerce rates.

Solar ceilings and the amine price signal

Final Commerce rates (Sep 11, context), per pv magazine. India: AD 123.04% + CVD 126.09% = 249.13%. Indonesia: AD 94.36% + top CVD 173.7% = 268.06%. Laos: AD 65.43% + top CVD 153.67% = 219.10%. Sums use the top CVD rate, so they are ceilings. The ITC voted affirmative on 14 Oct (window).

Computed from the petition's import data (Datamyne and USITC DataWeb): value ÷ quantity. Unit value fell (9.92 − 5.86) ÷ 9.92 ≈ 41% from 2023 to Jan–Jun 2026. The petition figures are allegations; no cash deposit applies yet.

Case detail

Sep 29

Open Evonik Corporation and Huntsman International LLC filed AD and CVD petitions; the ITC preliminary phase notice was published Oct 5 (91 FR 63307).

Nov 13

Estimate ITC vote. Then Commerce preliminary CVD Dec 23, 2026 and preliminary AD Mar 8, 2027 (all est.).

261–476%

Alleged AD margin range; CVD "above de minimis". The goods are polyurethane-foam catalysts, used mostly in spray insulation (Clark Hill).

The schedule runs ITC conference Oct 20 and briefs Oct 23. Commerce initiation was expected Oct 19; the sources do not confirm it happened. No cash deposit applies yet.

Nov 2

Upcoming Petitioners' counsel Tim Brightbill (Wiley Rein) expects Commerce solar orders; pv magazine says "early November". ITC report due Nov 23.

221.37%

In effect China-wide chassis deposits stay: 177.05% AD + 44.32% CVD. Judge Kelly remanded Commerce's scope ruling on Oct 7 (Slip Op. 26-121).

Jan 5, 2027

Upcoming Commerce redetermination due; the decision is not final. On Oct 21 the ITC found revocation of the China chassis and diamond sawblade orders likely to bring back injury, so both stay.

The court found no "unfinished subassembly" category and held that welding is not "any other processing" (law-firm blog). On Oct 14 Commerce published final Japan hot-rolled results (review period 1 Oct 2023–30 Sep 2024): NSC 13.96%, Tokyo Steel zero. Preliminary results for Korean and Taiwanese corrosion-resistant steel and Malaysian nails were published on 8 and 14 Oct; their rates are not in the sources.

Oct 3

Open MOFCOM Announcement No. 44 of 2026 opened an AD investigation after a Sep 14 application by Jiangsu Huaihe Chemical and Hubei Dongfang Chemical. No provisional or definitive duty exists.

~60%

MOFCOM says EU prices fell nearly 60% cumulatively over 2022–2025; the alleged margin above 100% comes from the applicants.

6,565 t

EU imports in 2025 (about $3.66 million) against 9,817 t in 2024, a fall of about 33% (Geopolitechs).

Registration closed Oct 23. MOFCOM expects to finish by Oct 3, 2027, extendable six months. The spokesperson tied the case to 28 EU remedy investigations against China since 2025, about half on chemicals. The notice text is not in the sources.

07Trade data and supply-chain shift

The 2026 trade recovery is narrow: AI goods supply 47% of value growth, Asia supplies all of the volume gain, and US import figures for China are contested

Two official data sets landed in the window: the WTO outlook (Oct 8, 2026) and the BEA/Census August trade release (Oct 6, 2026). A PIIE analysis questions whether the US import figures for China can be trusted.

Three views of where trade moves

BEA/Census, Oct 6, 2026, $ billion, goods and services, seasonally adjusted. Mexico and Vietnam together ran a deficit of $51.7B, 51.7 ÷ 16.4 ≈ 3.2 times the deficit with China. This ranks bilateral balances; one month shows ranking, not displacement of production.

WTO forecast (estimate), percentage points of 2026 merchandise volume growth. Asia 4.0, North America about 0.5, Europe 0.1 and other regions −0.7 sum to 3.9 (editor's check), so Asia supplies about 103% of world growth. The negative bar is drawn below the axis.

PIIE, citing Census and Chinese data, $ billion, Jan–Jul 2026. The $99.8B gap is about 63% of US-recorded imports, nearly five times its 2021–24 average. PIIE concludes the drop in US-recorded imports from China "should not be treated as a clean measure" of decoupling.

Indicators, periods and basis

Indicator	Value	Period	Source	Basis
World merchandise trade volume growth, forecast	3.9% (March: 1.9%)	2026	WTO	Estimate volume
Same, next year	4.1%	2027	WTO	Estimate volume
World merchandise trade, actual	+15% value; +3.5% volume	H1 2026, year on year	WTO	Current US dollars vs volume
AI-enabling goods share of value growth	47%	H1 2026	WTO	Value; WTO's revised, narrower HS6 list
US goods and services deficit	$105.6B (July revised: $92.8B)	Aug 2026	BEA/Census	Balance of payments, seasonally adjusted
US goods and services imports	$420.8B, record	Aug 2026	BEA/Census	Balance of payments, seasonally adjusted
US goods deficit with Mexico / Vietnam / China	$27.7B / $24.0B / $16.4B	Aug 2026	BEA/Census	Census basis, seasonally adjusted
US imports from Mexico / Vietnam	$60.6B / $26.5B, both records	Aug 2026	BEA/Census	Census basis, not seasonally adjusted
US-reported imports from China (incl. Hong Kong) vs China-reported exports to US	$158.3B vs $258.1B	Jan–Jul 2026	PIIE, citing Census and Chinese data	Two national statistics
Average US effective tariff rate on China / all countries	22.8% / 6.9%	Aug 2026	USAFacts	Duties collected ÷ import value
Global trade growth, goods and services	about 4%	2026	UNCTAD	Estimate constant prices; projection

The two US country series differ by basis: the release text gives the deficit with Mexico as $27.7B and with Vietnam as $24.0B, while the press highlights list $27.0B and $25.0B as record deficits on a not-seasonally-adjusted basis. We use the seasonally adjusted figures for rankings and the highlights for "record" claims.

Outlook, origins and evasion

47%

AI-enabling goods supplied 47% of the rise in world merchandise trade value in H1 2026 while being under 15% of trade (14.8% per ActuIA). UNCTAD's different yardstick gives 42% for 2025.

67%

Value growth of AI-enabling goods in H1 2026, after 31% in 2025 and 16% in 2024 (WTO). Taiwan (14.7%) and China (14.3%) were top exporters in H1 2026.

~11%

Estimate Implied price effect: 15% value gain against 3.5% volume gain, 1.15 ÷ 1.035 − 1 (editor's estimate).

The WTO outlook of Oct 8, 2026 lifted 2026 merchandise volume growth to 3.9% from 1.9% in March and expects 4.1% in 2027 (up from 2.9%, per AP); commercial services were cut to 3.3% from 4.8%. The 2027 figures depend on a timely resolution of the Middle East conflict. Export growth is forecast at 9.9% for Asia and −0.1% for Europe. The 47% cannot be re-derived outside the WTO because the revised HS6 list is not reproduced. The WTO names the risk itself: a reversal of AI investment "could also have a significant impact on trade".

63%

PIIE: the $99.8B gap between Chinese-reported exports and US-recorded imports (Jan–Jul 2026); annualised about $171B, matching PIIE's "exceed $170 billion" projection (estimate).

$70B

Estimate Coalition for a Prosperous America (an advocacy group): gap over 13 months from April 2025 between statutory and collected duty on Chinese goods; $4B evasion and $66B structural leakage.

>20%

UNCTAD: China–US trade down more than 20% since 2024, with East Asia expanding trade with both China and North America. USAFacts: China's rate 22.8% in Aug 2026 against 30.6% in 2025.

BEA/Census (Oct 6): the deficit rose $12.7B (13.7%) to $105.6B as imports rose $17.2B to a record $420.8B; capital goods imports hit a record $146.4B. The deficit is still $138.2B (19.9%) below the same period of 2025, against a 33.8% gain through June. The next release is Nov 4, 2026 (upcoming). A Research Square preprint (posted Oct 9; peer-review status not stated) warns against reading Mexican growth as diversion. The full August ranking is a ranking of bilateral balances, not a measure of where production moved.

08What companies should do

Manage cost with refunds, exclusions and content rules, treat summit cuts as pending, and watch the dated calendar

Evidence

Law-firm summary of the amine schedule; Utility Dive on solar orders; Court of International Trade on the chassis remand.

What changed, in rates

Category	Measure	Rate	Status
Most goods	Section 301 forced-labor action	10% or 12.5% tier	In effect since Jul 24
Steel and aluminum	Section 232	50% (Annex I-A); 25% (Annex I-B)	In effect since Apr 6
Patented pharmaceuticals	Section 232	100% general; 15%; UK 0%	In effect, final phase Sep 29
China, goods on the cut lists	Summit recommendation	About $30B each way	Announced Not implemented
Whole economy	Effective rate (Penn Wharton)	7.1% overall; China 24.3%	Reported Aug 2026

Key dates

Date	Event	State on Oct 24, 2026	Source
Oct 6, 2026	CAPE Phase 3 opens	In effect	StartBusinessByState
Oct 8, 2026	Class certified in Freestyle World; WTO forecast published	In effect	Troutman Pepper Locke; WTO
Oct 14, 2026	BIS "U.S. content" notice; ITC final affirmative on solar	In effect	Diaz Trade Law; USITC
About Nov 2, 2026	Solar duty orders expected	Upcoming	Utility Dive
Nov 4, 2026	Next BEA and Census trade release	Upcoming	BEA
Nov 9, 2026	Section 301 exclusions' last covered day; ship-fee pause ends unless extended	Upcoming	Argents; DSCP
Nov 10, 2026	Original truce expiry, extended to Jan 10, 2027	Announced extension	MOFCOM via Global Times
Nov 13, 2026	ITC preliminary vote on amine compounds	Upcoming Estimate	Law-firm summary
Dec 4, 2026	Polysilicon Section 232 measure	Scheduled	Airlift USA
Jan 5, 2027	Chassis redetermination due	Upcoming	CIT
Jan 12, 2027	USMCA review comments due	Upcoming	GHY

!The tariff wall is now product and country specific; use the refund, exclusion and content rules to manage cost, and treat summit cuts as pending until published.