April 2026 Market Update
Inflation in March rose to its highest level in nearly two years.
Month-to-month, the Consumer Price Index increased by 0.9 percent, according to the Bureau of Labor Statistics, with the price of gasoline – which jumped 21.2 percent from February – accounting for nearly three-fourths of the overall increase. On an annualized basis, inflation hit 3.3 percent, up from 2.4 percent in February.
The increase in the price of gas and other energy-related goods has been driven by the military action in Iran, particularly that nation’s blockade of the Strait of Hormuz, the shipping lane for about one-fifth of the world’s oil supply. Although a ceasefire has been in place since April 8, Iran has maintained its effective closure of the narrow waterway.
“It’s going to get more painful in April,” the chief U.S. economist at Oxford Economics said regarding inflation data, according to the Associated Press.
Spikes in fuel costs can eventually drive up other prices, and a vice president at FMI – The Food Industry Association noted that “recent instability in global energy markets is contributing to rising production costs across the food supply chain and could put upward pressure on grocery prices going forward.”
“Fuel is a critical input at every stage of the food system – from powering farm equipment to processing, packaging and transporting products to store shelves,” the FMI vice president said. “As energy prices increase, the costs associated with producing and delivering food also rise.”
The uptick in inflation makes it unlikely that the Federal Reserve will reduce interest rates at its April 28-29 meeting. The central bank, which aims to achieve an inflation rate of 2 percent – a level not seen since February 2021 – has left rates unchanged since December, with the target range for the federal funds rate sitting at 3.5 to 3.75 percent.
During the Fed’s March 17-18 meeting, “Participants anticipated that, under appropriate monetary policy, inflation would gradually move down toward the Committee’s 2 percent objective after the effect of increased tariffs and higher oil prices had faded, though they assessed that the pace and timing at which these effects would fade had become more uncertain since the time of the January meeting,” according to the meeting minutes.
“Participants noted that a prolonged conflict in the Middle East would likely lead to more persistent increases in energy prices and that these higher input costs would be more likely to pass through to core inflation,” the minutes stated. “Some participants highlighted the possibility that, after several years of above-target inflation, longer-term inflation expectations could become more sensitive to energy price increases. Partly as a result of these factors, the vast majority of participants noted that progress toward the Committee’s 2 percent objective could be slower than previously expected and judged that the risk of inflation running persistently above the Committee’s objective had increased.”
The Department of Justice in April announced it would end an investigation of Federal Reserve Board of Governors Chair Jerome Powell that was related to spending on building renovations, though U.S. Attorney Jeanine Pirro said she “will not hesitate to restart a criminal investigation should the facts warrant doing so.”
The move will likely allow President Trump’s nomination of Kevin Warsh to be Powell’s successor to proceed. Warsh’s confirmation process had been blocked by Sen. Thom Tillis, R-N.C., while the investigation was ongoing. Powell’s term as chair is set to expire on May 15, but he has the option of remaining a member of the Board through Jan. 31, 2028.
The economy added 178,000 jobs in March – the biggest monthly gain since December 2024 – with notable gains in health care, construction, and transportation and warehousing, the Bureau of Labor Statistics reported. The economy has alternated between gaining jobs and losing jobs each month since May 2025. The unemployment rate is now 4.3 percent.
Consumer confidence did not change dramatically in March, though there are indications that could change if the Iran situation remains unresolved and inflation becomes even more impactful. The Conference Board’s Consumer Confidence Index inched up less than 1 percent, but the board’s chief economist said, “Consumers’ write-in responses on factors affecting the economy continued to skew towards pessimism.”
“Comments about prices and the cost of goods suggest that the cost of living remained at the top of consumers’ minds,” the chief economist added. “As the war in Iran overlapped significantly with the survey sample period, comments about oil/gas and war/conflict spiked, while specific mentions of trade and tariffs decreased notably.”
The Index of Consumer Sentiment from the University of Michigan Surveys of Consumers recorded a 6.6 percent decline from March to April, with the surveys’ director noting, “The Iran conflict appears to influence consumer views primarily through shocks to gasoline and potentially other prices.”
A measure of confidence in the manufacturing sector, the Institute for Supply Management’s Purchasing Managers Index, showed a gain of less than 1 percent in March, but, given the survey period, responses might not reflect the full impact of the oil price shocks.
Housing starts in January increased 7.2 percent over December and were 9.5 percent higher than in January 2025, according to the Census Bureau and the Department of Housing and Urban Development. Existing home sales decreased by 3.6 percent from February to March, the National Association of Realtors reported.
“Lower consumer confidence and softer job growth continue to hold back buyers,” the association’s chief economist said. “Inventory remains a major constraint on the market. The inventory-to-sales ratio, or supply-to-demand ratio, is below historical norms. An additional 300,000 to 500,000 homes for sale would help bring the market closer to normal conditions and allow consumers to make purchase decisions without feeling rushed.”
The Dow Jones Industrial Average closed at 49,230.71 on April 24, up 2.4 percent on the year. It has regained the nearly 8 percent it lost in the first month after military action began in Iran on Feb. 28. The S&P 500 Index closed at 7,165.08 on April 24, recording a year-to-date gain of 4.7 percent. The S&P also experienced an Iran dip of just under 8 percent, but it has gained about 13 percent since March 30.
The dollar on April 24 was trading at 0.86 euros, 0.74 pounds, 159.77 yen and 6.83 yuan.
April 2026 Steel Shorts
Section 232 Tariffs to Apply to Full Value of Goods Containing Metals
President Trump on April 2 issued a proclamation revising Section 232 tariffs.
Under the order, a tariff of as much as 50 percent will apply to the full value of goods containing steel, aluminum and copper, “regardless of metal content,” rather than to just the portion represented by the metals.
The proclamation also makes certain changes to how derivatives are treated, keeping some on the tariff list “to prevent circumvention of the tariffs on aluminum or steel articles or because the derivative article sufficiently contributes to the applicable national security threat,” while removing others “because continuing the tariffs does not at this time make a significant contribution to effectively addressing the identified national security threats.”
Trump imposed the Section 232 tariffs during his first administration in 2018 and has made several revisions to them since then.
E.U., U.S. Discuss Steel Tariffs
Officials from the European Union and the United States met in late April to discuss the steel and aluminum trade, among other matters.
The European Parliament in March approved a trade pact known as the Turnberry Agreement that was announced by the two sides in July, but added certain stipulations related to steel and aluminum tariffs. (The original Turnberry agreement did not address Section 232 tariffs on the metals.)
European Commissioner for Trade and Economic Security Maros Sefcovic said after meeting with Commerce Secretary Howard Lutnick and others, “We want to launch work with the U.S. on steel ringfencing, aligning our approaches towards third countries.”
“With Secretary Lutnick, we agreed to accelerate this work at technical level,” Sefcovic said. “I also welcome that immediately after our meeting, the teams began detailed technical discussions on steel derivatives. While the latest U.S. decision has improved the situation for several sectors, some issues remain, and I appreciate the administration’s genuine engagement in resolving them.”
European Parliament, Council Reach Agreement on Steel Import Limits
The European Parliament and the European Council in April reached agreement on an aggressive set of steel quotas and tariffs.
The plan would slash steel import quotas by 47 percent to 18.3 million metric tons per year, which would match the import level in 2013, and would double the duties assessed when quotas are exceeded to 50 percent. The measure also includes “melt and pour” requirements intended to thwart circumvention.
“The shape and global standing of Europe’s steel sector are fundamental to our strategic autonomy and industrial strength,” European Commissioner for Trade and Economic Security Maros Sefcovic said. “We therefore cannot afford to turn a blind eye to global overcapacity reaching critical levels.”
The plan, which would replace existing safeguards that are set to expire on June 30, now awaits approval by member states’ representatives to the European Council and the European Parliament.
Foreign Automakers Say USMCA Renewal Needed to Continue Certain U.S. Sales
Several foreign automakers, including Toyota and Nissan, said in April that they will pull their lowest-priced models from the U.S. market if the U.S.-Mexico-Canada Agreement is not renewed.
The USMCA, which President Trump signed during his first term in 2020, imposed no tariffs on vehicles made with parts from the pact’s three participating countries. During this administration, however, Trump has imposed new tariffs on the non-U.S. content of vehicles, even if the content is from Canada or Mexico. In addition, he has expressed little to no enthusiasm for renewing the trade pact, which he has said is “irrelevant” and provides “no real advantage to us.”
“U.S. automakers cannot continue to produce affordable options for American consumers without the certainty and scale provided by a trilateral USMCA,” said Jennifer Safavian, the president and chief executive of Autos Drive America, a trade association that represents 12 large international automakers that operate in the United States.
The USMCA is up for review by all parties this year. If it is not extended by July 1, it will be subject to additional reviews every year until it expires in 2036. If it is extended, it would remain in force for 16 more years without annual reviews.
CUSTOMS CORNER
Update on Proposed Refund Process for IEEPA Duties
Summary
Responding to an Order from the CIT requiring the refund to all importers of the IEEPA duties found illegal by the Supreme Court, CBP indicated that it did not currently have the current capacity to process the mass refunds. CBP proposed creating a new module in ACE which would require importers to file claims, allow for validation by CBP, and issue refunds, with interest, on a consolidated basis. The CIT placed part of its Order on hold, giving CBP time to develop the necessary programming, with continued supervision by the Court. The proposed claims process would require filing through the ACE Portal, and would only issue refunds electronically to CBP ACE Refund accounts.
Detailed Discussion
On February 20, 2026, the United States Supreme Court found that the International Emergency Economic Powers Act (IEEPA) did not authorize the President to use tariffs as a remedy, and that duties paid under the authority of IEEPA were unlawful. On March 4, 2026 the United States Court of International Trade (USCIT) issued an Order directing U. S. Customs and Border Protection (CBP) to issue refunds to the importers of record of all IEEPA duties paid on entries that have not yet liquidated, and on liquidated entries for which liquidation has not become final. Pursuant to a previous filing by the Department of Justice, those refunds should include interest from the date of payment to the date of refund.
On March 6, 2026, CBP filed a Declaration with the CIT advising that it was unable to comply with the Court’s Order as its automated systems did not allow for the type of mass refunds contemplated, and it did not have the resources or manpower to perform manual refunds for the 53 million entries involved. CBP proposed developing, within 45 days, new programming for the ACE system that would allow for mass refund processing, subject to certain inputs from importers. The CIT issued an Order pausing the March 4 Order to the extent it required immediate refunds, and allowed CBP to move forward with development of the new programming, subject to periodic status reports.
On March 12, 2026 CBP filed its first status report, indicating that the various modules for the new programming were between 40% and 80% complete, with testing procedures to follow. The CIT allowed the process to go forward pending further status reports and resolution of certain issues. The next status report is due March 19, 2026.
The procedure proposed by CBP in the March 6 and March 12 Declarations requires importers of entries on which IEEPA duties were paid to submit an accurate report through the new ACE functionality listing all subject entries. CBP would then validate the report against its records, with any rejected entries returned to the importer for further review and potential refiling. CBP would process all validated entries by removing all applicable IEEPA tariff numbers and sending the entries through the normal duty calculation validations performed on all entries. Once that step is completed, the entries will go through a liquidation/reliquidation procedure, with a specified number of days delay to allow for manual review of selected entries (similar to current procedures), which will calculate the amount of any duty refunds and automatically calculate the interest due on those refunds. Once liquidated/reliquidated, the calculated refunds will be processed through a new Mass Refund process, with refunds issued weekly on a consolidated basis for all entries processed during that week.
The procedure requires the submission of the list of entries through the ACE Portal. Importers with their own Portal can submit their claims directly. Other importers will have to work with their broker/filer to submit claims on their behalf. Refunds will all be issued electronically, only to CBP ACH Refund accounts. Importers can currently only register for an ACH Refund account through their ACE Portal. Importers without an ACH Refund account can designate a third party, normally a broker or other service provider, who does have such an account to receive refunds for them. Brokers and service providers are likely to charge fees for filing and refund services.
CBP recommends that all importers establish their own ACE Portal account, although less than 10% of the 350,000 affected importers have done so. ACE Portal accounts are free. The accounts are not always simple to use, although CBP has extensive online training and information available, and many private consultants provide training services.
https://www.cbp.gov/trade/automated/how-to-use-ace/portal-introduction
CBP has also provided information on the procedures to establish an ACH Refund account.
https://www.cbp.gov/trade/automated/ach/refund
Many aspects of the process, including whether the Court will ultimately accept it, perhaps requiring modifications, remain. The government also has the opportunity to appeal the CIT Order to the Court pf Appeals for the Federal Circuit, which could delay, modify or terminate the planned procedures.
There are a number of areas where further clarity is required. How would the process handle entries subject to Reconciliation or drawback, entries from Foreign Trade Zones, and other special transactions? CBP has indicated that it is unable to halt the ongoing liquidation of IEEPA entries, and while CBP appears to be contemplating processing all entries regardless of liquidation status, it is unclear how entries where liquidation has become final will be handled. Are Protests required (or even effective) to keep liquidations open? Will separate lawsuits before the CIT be required for some entries?
Importers using express or courier services, where the express service secured a Power of Attorney from the importer who then became the importer of record, should consult the filing broker (in house or related to the express service) regarding the preparation and filing of the required ACE report, and perhaps the handling of ACH refunds as well, unless the importer has its own ACE Portal account. Where the express service or courier acted as the Importer of Record, it will be eligible to receive any refund. The importer must pursue refund of any IEEPA duty amounts passed through the express service as a contract issue.
Recommendations
The development of a refund process for IEEPA duties is proceeding fairly rapidly, despite the issues that remain unresolved. The Court and CBP both seem to be proceeding with a plan that would reduce or eliminate the need for individual Protests and/or lawsuits, both for judicial economy and administrative convenience. The majority of entries on which IEEPA duties were paid have not yet liquidated, or are within 90 days of the liquidation date. Except for entries where the 180 day period following liquidation is nearly expired, I recommend holding off on filing Protests or lawsuits in the USCIT (which both have their own costs) at least for a while, to see if they will be effective or necessary. The Statute of Limitations for the lawsuits that have been used to challenge the duties is two years from the date of duty assessment, so there is still time to see if they will actually be necessary. (I understand that there are some other legal opinions on the best way to protect possible refunds.)
I agree with CBP that importers should set up their own ACE Portal accounts, and from there ACH refund accounts. This will not only provide some control over the IEEPA refund issue, but also allows for a wide range of information regarding entries filed and other transactions with CBP on all of the importer’s activities. Although the specific requirements for the ACE report required to file refund claims are not yet finalized, Portal account holders should prepare by generating an ACE report covering entries on which IEEPA duties were paid, and their liquidation status.
Importers without ACE Portal accounts will have to rely on their broker/filer. Making arrangements for that activity should be initiated as soon as possible.
Steven W. Baker
AMSCI Customs Committee Chair
swbaker@swbakerlaw.com
CUSTOMS CORNER
CBP Issues Guidance on April 6, 2026 Changes to Section 232 Duties on Imports of Aluminum, Steel, and Copper
U. S. Customs and Border Protection (CBP) issued Guidance in a CSMS message providing detailed information on the modifications to Section 232 duties on steel, aluminum, and copper required pursuant to President Trump’s April 2, 2026 Proclamation. The Proclamation establishes 16 new Chapter 99 tariff provisions, effective on April 6, 2026, with duty changes ranging from additional products subject to the 50% rate on their full value, others subject to a 25% rate, and special rates for the UK, Russia, certain products of trade agreement countries, motorcycle parts, and products incorporating metals that are melted and poured or smelted and cast in the United States. Temporary rates are established for certain industrial equipment. The Guidance lists the new Chapter 99 numbers and the applicable duty rates.
The complex Guidance includes as an attachment a 23 page list, by Chapter 99 number, identifying the products covered by each provision.
The document also provides information on Russian aluminum duties, interaction with prior trade agreements, drawback (allowed for a restricted list of products), Foreign Trade Zone restrictions, and applicability to Chapter 98 provisions.
Steven W. Baker
AMSCI Customs Committee Chair
swbaker@swbakerlaw.com
CUSTOMS CORNER
President Trump Announces Changes to Section 232 Effective April 6, 2026
President Trump issued a Proclamation on April 2, 2026 significantly changing the treatment of numerous items subject to Section 232 duties for steel, aluminum and copper. The changes, effective on April 6, 2026, particularly affect the treatment of derivatives.
Steel, aluminum and products made entirely or almost entirely of aluminum, steel, or copper will continue to be subject to the 50% duty rate on the full value of the product. This will include an expanded list of derivative products. Derivative articles substantially made of steel, aluminum, or copper will pay a flat 25% on their full value. A list of other derivative products previously subject to duty on the metal content value will be removed from the derivatives list and not subject be to Section 232. Derivative products that are not classifiable in Chapters 72, 73, 74, and 76 that are made of 15% or less (by weight) of steel, aluminum, or copper will no longer be subject to Section 232 metals tariffs. Articles covered by more than one metal shall only be subject to the respective duty rates once.
A list of metal-intensive industrial equipment and electrical grid equipment will pay a 15% duty through 2027. This is intended to assist building the industrial base in the U. S. Products made abroad entirely with American steel, aluminum, and copper composed entirely of aluminum content that was smelted and cast in the United States, steel content composed entirely of steel that was melted and poured in the United States, or copper content composed entirely of copper that was smelted and cast in the United States, will be subject to lower tariffs of 10%.
Imports that are products of the United Kingdom continue to enjoy a 25% rate rather than 50%, and a 15% rate rather than the 25% rate for certain derivative articles. The Proclamation does not alter or supersede certain agreements providing for reduced Section 232 duties on specified civil aircraft and parts.
Imports subject to Section 232 must be entered into Foreign Trade Zones as privileged foreign merchandise. Manufacturing drawback is available under specified conditions for products of Trade Agreement countries.
The Proclamation ends the use of metal content value for Section 232 purposes, and terminates the existing procedures for periodic inclusion of additional derivatives. The Secretary and USTR, however, are empowered to add additional derivatives as necessary for national security purposes based on a joint determination.
The lengthy Proclamation includes a number of other specific provisions. None of the provisions of the Proclamation are retroactive.
U. S. Customs and Border Protection is expected to issue implementing instructions.
Steven W. Baker
AMSCI Customs Committee Chair
swbaker@swbakerlaw.com
AMSCI 2026 Events Calendar
AMSCI Annual Gulf Region Golf Outing
Date: Tuesday, May 12, 2026
Location: Point Clear, Alabama
AMSCI 75th Annual Dinner
Date: Wednesday, November 18, 2026
Time: 5:00 PM – 7:00 PM | Cocktail Networking Reception (Cambridge Room)
7:00 PM – 9:00 PM | Dinner (Harvard Hall)
Location: The Harvard Club of NYC
Formal dinner and networking in a historic New York venue.
🎄 AMSCI Annual Gulf Region Christmas Dinner
Date: Thursday, December 10, 2026
Time: 6:00 PM – 10:00 PM
Location: Aspen Ballroom, The Houstonian Hotel, Club & Spa | Houston, TX
Celebrate the season with industry peers in a festive setting.