Tariff whiplash, round two: the Canada reshuffle and the refund money you might be owed

In the same month, a brand buying from Canada can see a packaging input drop off a duty list, a finished product land on it, and a refund for duties paid under an earlier regime start moving through a government portal.

The Canada list changed on October 30

On October 23, 2026, the White House issued a proclamation that changes which products of Canada carry the additional 50% ad valorem duty under Section 338 of the Tariff Act of 1930. The change applies to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern on October 30, 2026, and the duty applies on top of any Section 232 duties. The White House fact sheet adds that these tariffs apply whether or not a good qualifies under the USMCA.

The official annex splits the change in two. Part A removes the extra duty from lines that matter to anyone shipping physical goods, including:

• Corrugated cartons, boxes, and cases (HTS 4819.10.00) and paper sacks and bags (4819.40.00).
• Molded or pressed paper pulp articles (4823.70.00), the trays and inserts many brands use to protect product.
• Certain plastic boxes, cases, and crates (3923.10.90) and ethylene sacks and bags (3923.21.00).
• Thin plywood sheets in several lines, plus filling, sealing, and labeling machinery (8422.30.91) and packing or wrapping machinery (8422.40.91).

Part B adds lines, and several land squarely on consumer brands:

• Shampoos (3305.10.00).
• Certain toilet soaps in bars and cakes (3401.11.50).
• Wooden packing boxes and cases with solid sides, lids, and bottoms (4415.10.30).
• Unprinted pressure-sensitive paper labels (4821.90.20).

The annex says its descriptions are for information only and do not limit the scope of the action, so a product that sounds like a listed item is not covered or cleared until the full HTS code on your entry is checked against the list.

Landed cost now moves by the week

A 50% duty is charged on customs value, not on retail price, so the math is blunt: a Canadian product with a $20 customs value carries $10 of extra duty if its line is now covered, before ordinary duty, brokerage, freight, and fulfillment. For a personal care brand whose shampoo or bar soap is made in Canada, that can turn a profitable SKU into a loss on every order. The reverse is also true: a duty buffer built into carton or insert costs can come out once a broker confirms the treatment. The $20 figure is illustrative arithmetic, not a quote from any source.

The operator lesson is that landed cost is no longer a number you set at the start of the year and revisit at the next buy. It has to live in a sheet that is updated when a rule changes, keyed by SKU and by full HTS code, with the source of each duty rate written next to it.

A tariff refund is a cash line someone has to chase

The second change is money coming back. CBP built the Consolidated Administration and Processing of Entries function, called CAPE, inside its ACE system to process refunds of duties imposed under the International Emergency Economic Powers Act, as authorized by court order or applicable law. According to CBP's IEEPA refunds page, the process works like this:

• Only the importer of record, or the licensed customs broker who filed the entries, can file a CAPE Declaration, which is a CSV list of entry numbers uploaded in the ACE Portal.
• Phase 1 covers certain unliquidated entries and entries liquidated within the preceding 80 days, and Phase 2 covers entries flagged for reconciliation where the reconciliation entry is not yet filed.
• Refunds are paid by ACH only, to bank details stored in the ACE Portal, and CBP generally expects to pay within 60 to 90 days of accepting a declaration, with interest included.
• A declaration cannot be amended once accepted, refunds are netted against any other duty owed on the same entry, and a CAPE filing can even produce a bill if other duties were underpaid.
• If you disagree with the amount, a protest must be filed within 180 days of liquidation or reliquidation.

In a court filing summarized by Cherry Bekaert, CBP reported that as of October 2, 2026 about $126 billion had been transmitted to the Treasury for payment, and about $1.1 billion was still pending because ACH payment details were missing or not validated. That last figure is the operator's warning: a refund you are owed does not reach your bank account until someone sets up the portal and the bank details.

Phase 3 and the class action, in plain terms

As reported by trade counsel and trade press, CAPE Phase 3 opened on October 6, 2026 for finally liquidated entries, but only for importers who sued at the Court of International Trade and received a reliquidation order, and at first only those who gave CBP a valid importer of record number by July 30. On October 20, according to International Trade Today, CBP widened access to plaintiffs whose numbers reached CBP between July 31 and August 13, and said Phase 3 accepts entries more than 80 days past liquidation and entries under open or suspended protests.

On October 8, the court certified a class in Freestyle World, Inc. v. CBP covering importers who did not file their own refund suits. As Cherry Bekaert notes, that does not create refund eligibility today: if the class wins on the merits, members may later be able to file through CAPE, but the government can appeal, so it is a reason to keep records ready, not a reason to book the cash.

What to do this week

• Pull every open Canadian purchase order and entry. Match the full HTS code against Parts A and B of the annex, and get your broker's conclusion in writing.
• Reprice the affected SKUs. Rebuild landed cost on customs value for anything newly covered, and ask suppliers to requote anything that came off the list.
• Check entry timing for goods in transit or in a bonded warehouse. The entry or withdrawal date decides the rate, not the order date.
• Name one owner for IEEPA refunds. Give that person the entry list, the broker relationship, and a weekly line on the cash forecast.
• Set up the ACE Portal and ACH refund details now. Without them, CBP holds the refund.
• Sort entries by status. Unliquidated and recently liquidated entries may fit Phases 1 and 2, while finally liquidated entries without a court order wait on the courts.
• Book refunds as receivables only when accepted. Carry claims you have not filed or that depend on the class action as upside, not cash.
• Ignore anyone asking for a fee. CBP says it charges nothing for refunds and warns about scams that ask for company or bank information.

This is general information from a finance and operations seat, not legal or customs advice. Confirm classification, entry dates, and refund eligibility with your licensed customs broker or trade counsel before you act.

Questions operators ask about the October tariff changes