March 2026 Market Update
The military action in Iran continues to upset the world economy after its first month.
The United States and Israel began attacking sites in Iran on Feb. 28, though no ground troops have engaged in operations to this point. Iran responded by firing missiles not only at Israeli locations and U.S. bases in the region, but also at energy infrastructure in neighboring countries. In addition, it has largely shut down shipping through the Strait of Hormuz, through which about one-fifth of the oil and liquefied natural gas consumed in the world transit.
As a result, oil prices increased more than 50 percent in March, reaching their highest point since July 2022, when pandemic-era inflation and supply chain issues and Russia’s invasion of Ukraine a few months earlier were applying upward pressure. Gas prices in the United States increased by about a third during that time, according to the American Automobile Association (AAA).
Given the broad impact of energy costs throughout the economy, the prices of many other goods could also be affected, from food to semiconductors, the latter because their manufacture uses helium, and a third of the world’s helium supply comes from the Middle East nation of Qatar.
The Trump administration has given conflicting messages about its approach to and goals in the war, and some analysts say that price shocks are likely to get worse.
“We haven’t seen the brunt of it yet,” Samantha Gross, director of energy security and climate at the Brookings Institute, told NBC News. “I feel like markets are so far underestimating the effect of the war. It seems that they expect this war to go quickly, and they expect that we can go back to the world before when it’s over. And I don’t think either of those ideas is true.”
The Dow Jones Industrial Average dropped 7.8 percent in the war’s first month, closing at 45,166.64 on March 27. The S&P 500 Index, similarly, fell 7.4 percent during that time, ending March 27 at 6,368.85.
The annualized inflation rate in February, as measured by the Consumer Price Index (CPI), was 2.4 percent, the same as in January. Energy costs over the previous 12 months increased by 0.5 percent, while prices for all types of gasoline fell by 5.6 percent. March data is scheduled to be released in early April.
Federal Reserve Chair Jerome Powell said on March 30 that the central bank will not rush to increase interest rates based on what could be short-term price hikes.
“We feel like our policy is in a good place for us to wait and see how that turns out,” Powell said, adding, “Monetary policy works with long and variable lags, famously, and so, by the time the effects of a tightening in monetary policy takes effect, the oil price shock is probably long gone.”
The Federal Reserve’s target rate for inflation is 2 percent, a goal that has not been reached since February 2021. The Fed’s Federal Open Market Committee has left interest rates unchanged at its past three meetings following three quarter-point cuts in a row to end 2025. The target range for the federal funds rate is now 3.5 to 3.75 percent.
The economy in February lost 92,000 jobs, the fifth month since June in which job creation was negative. About one-third of the reduction resulted from the nurses’ strike at Kaiser Permanente. CBS News reported in March that “Some analysts noted that the strikes and recent winter storms may have distorted the latest employment data, overstating the weakness last month.”
One economic indicator that captures at least part of the impact of the war is the Index of Consumer Sentiment from the University of Michigan’s Surveys of Consumers, which conducted interviews between Feb. 17 and March 23 for its current report. The March index slid 5.8 percent from February, and the survey’s director noted that “Consumers with middle and higher incomes and stock wealth, buffeted by both escalating gas prices and volatile financial markets in the wake of the Iran conflict, exhibited particularly large drops in sentiment.” The director added, however, that “declines in long-run expectations were more subdued” than short-term pessimism, suggesting that “consumers may not expect recent negative developments to persist far into the future.”
The Consumer Confidence Index from The Conference Board increased 2.4 percent in February, though the organization’s chief economist said – before operations began in Iran – that “Consumers’ write-in responses on factors affecting the economy continued to skew towards pessimism. Comments about prices, inflation, and the cost of goods remained at the top of consumers’ minds. Mentions of trade and politics also increased in February.”
Confidence in the manufacturing sector, as measured by the Institute for Supply Management’s Purchasing Managers Index, was largely unchanged from January to February, holding on to sizable gains from December.
“In February, U.S. manufacturing activity remained in expansion territory, although growing at a slower pace than the month before,” the chair of the institute’s Manufacturing Business Survey Committee said.
Housing starts in January increased 7.2 percent from 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, meanwhile, increased 1.7 percent from January to February, but were down 1.4 percent year over year, the National Association of Realtors reported.
“Housing affordability is improving, and consumers are responding,” the association’s chief economist said. “Still, there is a long way to go to return to pre-pandemic levels of transaction activity.”
The dollar on March 27 was trading at 0.87 euros, 0.75 pounds, 159.73 yen and 6.91 yuan.
March 2026 Steel Shorts
Aluminum Producers in Middle East Struck by Iran
The aluminum sector is taking direct hits as a result of the military action against Iran.
Iran has responded to attacks by the United States and Israel by firing missiles into neighboring countries, and aluminum producers in the United Arab Emirates and Bahrain were struck in late March.
An aluminum research analyst at S&P Global Energy told CNBC that “The attacks have sent shockwaves through the global aluminum market, raising the risk of a supply crisis that could reshape the industry.”
Global aluminum supply has also been restricted by Iran’s closure of the Strait of Hormuz, since about 9 percent of the world’s supply of the metal comes from Persian Gulf states.
Other metals are also being affected by the war. Newsweek reported in late March that “Nickel producers in Indonesia, heavily reliant on Gulf‑sourced sulphur, may soon be forced to cut output.”
European Lawmakers Set Conditions for Trade Pact with U.S.
The European Parliament approved a trade pact reached with the United States in July – with conditions related to steel and aluminum added.
The move advances the Turnberry agreement, which would cut tariffs on many goods shipped between the trading partners, but Parliament members stipulated that Europe will implement the deal only when the United States reduces to a maximum of 15 percent its tariffs on E.U. products with a steel and aluminum content below 50 percent. (The original Turnberry agreement did not address Section 232 tariffs on the metals.) The revisions also state that, if the United States does not reduce to 15 percent the tariffs imposed on E.U. goods with more than 50 percent steel and aluminum content, then E.U. tariff preferences for U.S. products with those metals will expire after six months.
In addition, the entire pact could be suspended under certain conditions, such as if the United States imposes new tariffs of more than 15 percent.
European Parliament members “will only be able to sign up to the trade terms of the deal if the regulation contains very strong and clear safeguards, and only after the U.S. has fully respected the terms of the deal,” Parliament member Bernd Lange of Germany said.
The Parliament’s approval allows negotiations with E.U. member states on the final version of the legislation to begin.
U.K. Reducing Steel Import Quotas, Increasing Tariffs
The United Kingdom, echoing a move by the European Union, is preparing to tighten rules regarding steel imports, according to published reports.
The U.K. government is planning to slash the amount of steel that can be imported without tariffs by 60 percent and to double to 50 percent the tariffs applied to imports that exceed the limit. Officials also set a goal of having half of the steel used in the country to be produced domestically.
“Making steel in the U.K. is vital for national security, critical infrastructure and the wider economy,” U.K. Business Secretary Peter Kyle said.
A measure is advancing through the European Union government that would cut steel import quotas by 47 percent to 18.3 million metric tons per year, which would match the import level in 2013, and that would double the duties assessed when the quotas are exceeded to 50 percent.
OECD Notes Widespread Steel Circumvention
The circumvention of steel shipments is inhibiting efforts to reduce the impact of overcapacity, according to the Organisation for Economic Co-operation and Development (OECD).
The OECD Steel Committee brought together 42 delegations to discuss the global steel crisis on March 23-24 and concluded that:
Global steel demand continues to decline while excess capacity increases, reaching 640 million metric tonnes in 2025.
Steel exports from China nearly doubled from 2022 to 131 million metric tonnes in 2025.
In 2024, comparing firms of similar size, Chinese steel companies received 15 times more subsidies than companies elsewhere.
“Exporters are increasingly resorting to a widening range of circumvention techniques in response to OECD countries’ trade measures, including by slightly modifying the products, by investing in steel plants abroad to change the origin of the steel, and by exporting steel in the form of steel-intensive downstream products that are not subject to the trade measures,” OECD Steel Committee Chair Sheryl Groeneweg said.
The OECD stressed the importance of international cooperation on new approaches, given that “Current trends reveal that existing policy approaches and toolkits are insufficient to fully address global excess capacity and its harmful impacts on steel industries.”
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
CBP Base Metals Center 03/15/2026
Below is the CBP position on Section 232 “content value” that we have been sharing for the last several months.
Steel and Aluminum
References to “steel” and “aluminum” includes steel and aluminum alloys. Do not break down the chemistry of an imported article to remove the value of alloying elements to arrive at the Section 232 steel or aluminum content. Non-Section 232 content refers to non-steel/aluminum components that are part of the imported article.
Steel articles of chapter 72 are 100% steel. Section 232 duty is assessed on the full entered value of the article. There is no backing out of any costs not allowed by the Customs Value laws. Manufacturing, labor, coating, etc. costs are not subtracted.
For steel articles of chapter 73, aluminum articles of chapter 76, and articles classified elsewhere (not including chapter 72):
o If the articles are 100% steel or 100% aluminum, there is no non-steel or aluminum content to separate and Section 232 duty is assessed on the full entered value of the article. There is no backing out of any costs not allowed by the Customs Value laws. Costs of production, manufacturing, machining, fabrication, labor, overhead, profit, packaging, coating, etc., are not subtracted.
o If the articles are not wholly of steel or aluminum (meaning there are non-steel or non-aluminum parts/components), and there is legitimately non-steel or aluminum content to separate, the Section 232 duty is assessed on the value of the steel/aluminum content of the article.
o HQ has said this would be based on “the invoice paid by the buyer of the steel/aluminum content to, or for the benefit of the seller of the steel/aluminum content”. The current position is, this is what the importer paid for the steel/aluminum content of the finished article and is the entered value of the imported article minus the cost of the non-steel/aluminum part/component of the finished article. Non-steel/aluminum content does not refer to costs of production, manufacturing, machining, fabrication, labor, overhead, profit, packaging, coating, painting, galvanizing, plating, etc.*
o If allowed to separate steel/aluminum and non-steel/aluminum content value, identify the cost to the importer of the non-steel/aluminum part/component. Again, there is no backing out of any costs not allowed by the Customs Value laws. Costs for production, manufacturing, machining, fabrication, labor, overhead, profit, packaging, coating, painting, galvanizing, plating, etc., are not subtracted.*
* For costs that are attributable to both the non-steel/aluminum/copper content and the steel/aluminum/copper content, like labor, overhead, profit, packaging, etc., an acceptable method is to apportion the costs to both lines based on a value ratio.
If the value of the steel/aluminum content cannot be determined, then report the duty based on the total entered value, on only one entry summary line.
· If the article is composed of US steel/aluminum and foreign steel/aluminum, Section 232 duty is still assessed based on the article’s country of origin. The value of the US steel/aluminum cannot be separated out.
· Likewise, the exemptions from Section 232 duty for articles made from US melted and poured steel and US smelted and cast aluminum (9903.81.92 and 9903.85.09) are all or nothing provisions. If only a portion of the source steel/aluminum was melted and poured/smelt and cast in the US, the article cannot be split into a US content line and a non-US content line. If the imported article is not exclusively made of US melted and poured steel and US smelted and cast aluminum, the Section 232 duty is assessed on the article’s entire value.
· As far as documentation goes for separating out steel/aluminum content value from non-steel/aluminum value, we would say, “documentation sufficient to support the importer’s claimed steel/aluminum content value”, if CBP asks.
· New If an obviously non-steel or aluminum article like perfume or lotion is on a Section 232 derivatives tariff numbers list, it is the article’s container that is the target of Section 232, and it is the importer’s cost of the container, if made of aluminum or steel, that is subject to the Section 232 duty (like HTS 2203.00.0060 and 2203.00.0090 for malt beer in an aluminum can).
Example
Aluminum windows are imported—
· What did the importer of record pay for the finished windows?
· If the windows have non-aluminum components/parts like glass, what was the cost of that to the importer?
· Minus the cost to the importer of the non-aluminum parts from the total window cost to the importer and that equals the Section 232 steel content value.
So if—
· The importer paid $100 for the window.
· $20 of the cost is attributable to glass or other component/parts.
· The entered value of the window is $100. It may be separated into two lines, a non-aluminum content line of $20 and an aluminum content line of $80.
* For costs that are attributable to both the non-aluminum content and the aluminum content, like labor, overhead, profit, packaging, etc., an acceptable method is to apportion the costs to both lines based on a value ratio.
Copper
References to “copper” includes copper alloys (including brass and bronze).
· Unless we receive guidance otherwise, our current understanding is copper, copper alloys, and copper derivatives are treated the same as steel and aluminum and their alloys and derivatives. Do not break down the chemistry of an imported article to remove the value of alloying elements to determine the Section 232 copper content. Non-Section 232 content refers to non-copper or copper alloy components that are part of the imported article.
· The copper content value is determined in the same manner as steel and aluminum.
New Section 232 and articles of iron
· For iron articles subject to Section 232, the iron content value is determined in the same manner as steel and aluminum.
· Certain articles of iron, like cast iron, wrought iron, pig iron, etc., may not be subject to Section 232 duty. That does not refer to the iron present in all steel. There is no breaking down the chemistry of a steel article to arrive at a separate, non-Section 232, iron content.
Until 6/4/25, no distinction was made between steel and iron, and Section 232 assessment was based on tariff number alone. The HTSUS Section XV notes state iron and steel are generally treated as the same metal. Here is a timeline for Section 232 and iron:
o March 2018 through March 11, 2025: no distinction. Iron or not, if the article was classified under a Section 232 tariff number it had to pay Section 232 duty.
o March 12, 2025 – June 3, 2025: only steel content (not iron content) appearing in Section 232 derivative articles classified outside of chapter 73 and 76 was subject to Section 232 duty. Not including articles classified outside of Chapter 73 in pre-March 12 Section 232 derivatives* or chapter 72 (there are no derivative articles in chapter 72).
o June 4, 2025 onward, only steel content (and not iron content/articles) appearing in articles classified in chapter 73, and in derivative articles classified anywhere (except chapter 72 and not including articles classified outside of Chapter 73 in pre-March 12 derivatives*), is subject to Section 232 duty.
*Not including articles classified outside of Chapter 73 in pre-March 12 derivatives” refers to these “existing Section 232 derivatives” added in 2020:
(C) bumper stampings of steel, the foregoing comprising parts and accessories of the motor vehicles of headings 8701 to 8705 (described in subheading 8708.10.30); and
(D) body stampings of steel, for tractors suitable for agricultural use (described in subheading 8708.29.21).
In other words, for Section 232 subject tariff numbers:
o March 2018 – present: iron articles classified in chapter 72 pay Section 232 duty (there are no derivatives in chapter 72 and no separation of content value)
o March 2018 – March 11, 2025: iron articles pay Section 232 duty.
o March 12, 2025 – June 3, 2025: derivative iron articles and iron parts classified outside of chapter 73 do not paySection 232 duty (except for chapter 72, 8708.10.30 and 8708.29.21, where iron does pay).
o June 4, 2025 onward: iron articles and iron parts classified in chapter 73 and in derivative articles classified elsewhere do not pay Section 232 duty (except for chapter 72, 8708.10.30 and 8708.29.21, where iron does pay).
(“parts” refers to subject steel/aluminum/copper articles with non-subject iron parts)
Continue to monitor the CSMS messages, Trade Remedy FAQs, and CBP rulings posted on cbp.gov, or any changes from the Department of Commerce.
Cargo Systems Messaging Service | U.S. Customs and Border Protection
Trade Remedies | U.S. Customs and Border Protection
CROSS Custom Rulings Online Search System
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.