Law Library

Trade & Tariff Update #16 - India Deal Reached, Oil Sales to Cuba and More

APPA Team — Tue, 03 Feb 2026 21:49:28 GMT

Taking Aim at Oil Sales to Cuba

After a busy last week, the Administration continued its tariff activities this week by issuing an executive order imposing tariffs on countries selling oil to Cuba. This order could likely impact Mexico, one of Cuba’s oil suppliers. Meanwhile, there has yet to be official confirmation through executive orders of last week’s threatened secondary tariffs against countries doing business with Iran and against Canada in response to a prospective trade deal with China. The wait also continues for a formal announcement on the trade deal with Taiwan.

Electronic Refunds Interim Final Rule Effective February 6, 2026

APPA Team — Mon, 02 Feb 2026 16:55:26 GMT

ACH Electronic Refunds Will Be Required For Duties, Taxes, and Fees By CBP on Feb 2, 2026

We are available to assist Importers that are having trouble getting started. Please note that this is not optional for most Importers. Very few exceptions to this requirement for electronic refunds. In preparation for possible IEEPA and Reciprocal tariff refunds these updates must be made. Recommend that this be prioritized ahead of the February 6 deadline.

U.S. Customs and Border Protection (CBP) is requiring all importers to transition to electronic refunds via Automated Clearing House (ACH) for duties, taxes, and fees, effective February 6, 2026. This change, implemented under an Interim Final Rule (IFR), will eliminate paper check refunds.

To receive electronic refunds, importers must enroll through their ACE Portal by adding banking information using the new ACH Refund Authorization tool. ACH refunds offer faster processing (typically 1–2 business days) and enhanced security. Limited waivers for paper checks may be available in exceptional circumstances.

Next Steps

Trade & Tariff Update #15

APPA Team — Wed, 28 Jan 2026 21:45:04 GMT

In the Absence of a Supreme Court Decision, Some Tariff Tensions Ease Slightly While Others Continue to Escalate

As the wait continues for the Supreme Court’s IEEPA decision, rumors have begun circulating that the ruling may not be issued until next month.  Meanwhile, tariff threats aimed at eight European countries opposing the Administration’s aspirations to acquire Greenland appear to have eased following discussions between President Trump and NATO leadership.  The E.U. had postponed a vote to confirm its trade deal with the United States, but it is expected to be rescheduled.

APPA Trade Talks January Office Hours: 5 Takeaways For Pet Businesses to Consider

APPA Team — Tue, 27 Jan 2026 21:28:24 GMT

During the first Trade Talks Open Office Hours of 2026, APPA’s trade experts discussed the rapidly – and recently -- evolving tariff landscape as well as what we might expect from the long-awaited Supreme Court decision on the IEEPA tariffs when it is announced. Some seemingly positive signals of a more moderate and predictable tariff system going forward was also discussed. Our panel further provided some proactive steps that pet businesses can start taking now to accelerate and maximize the opportunity for tariff refunds should the Court strike down the IEEPA tariffs.

Here are the key takeaways APPA members should keep front and center as they move further into 2026:

Trade & Tariff Update #14

APPA Team — Thu, 22 Jan 2026 21:40:22 GMT

Policy of Bluster and Contradiction

In response to Iran’s violent crackdown on protests against the regime, last week President Trump posted on Truth Social that the United States would immediately impose a 25% tariff on all countries doing business with Iran. Such a proposal would have a major impact on countries like China and Brazil, as well as potentially derail the fragile trade agreement between the United States and China, Tehran’s largest trading partner. So far, however, no order has been released, so any applicable terms or authority for such a tariff remain unclear. Moreover, any attempt by the Administration to attribute its authority for these secondary tariffs to IEEPA could be invalidated by the Supreme Court should it issue an opinion to that effect on the original tariffs. The timing of that ruling also remains in limbo.

APPA Trade Talks December Office Hours: 5 Takeaways Pet Businesses Need to Act On

Patrick O'Brien — Wed, 14 Jan 2026 17:46:02 GMT

As we turn the page into a new year, 2026 is already shaping up to be a pivotal moment for the pet industry. New tariff actions, shifting trade alliances, evolving monetary policy, and continued pressure on small businesses are all on the horizon. Before we move full speed into what is coming next, it is important to pause and recap where we ended 2025, and what APPA members should be carrying forward into their planning and decision-making.

Reciprocal Tariff Update #13 - Waiting on the Supreme Court While Continuing Protective Measures

APPA Team — Fri, 09 Jan 2026 17:15:00 GMT

The Trump Administration: Waiting on the Supreme Court While Continuing Protective Measures

*Updates from Rafe Morrissey, Morrissey Strategic Partners, LLC & Craig Brightup, The Brightup Group, LLC

While most eyes are focused on the United States Supreme Court in anticipation of its decision over the legality of President Trump’s IEEPA tariffs, the Administration continues moving to protect its position regardless of the high Court’s judicial outcome. While much depends on the Court’s clarity regarding the specific process for refunds should it rule that that the tariffs are illegal, the Administration has signaled that it has been developing a substitute regime to keep any duties in place. Without clear instruction from the Court, the road to refunds most likely would be both lengthy and complicated. Moreover, it has been reported that experts do not anticipate a de-escalation of the tariff regime anytime soon.

Costco’s Tariff Refund Lawsuit

APPA Team — Fri, 19 Dec 2025 18:15:00 GMT

In the opening minutes of APPA’s Decmber Trade Talks tariff update, our experts zeroed in on one headline: Costco’s new federal lawsuit challenging Trump’s emergency tariff orders on imported goods. For pet product importers, this case is more than political theater, it’s a playbook for how to protect your own tariff refund rights.

2025 Regulatory Update Part 2: What We Are Watching In The CBD & Hemp Pet Product Sector

APPA Team — Thu, 18 Dec 2025 20:11:49 GMT

Overview

As in the past, we are monitoring proposed state and federal legislation, as well as any FDA and AAFCO discussions and/or research which may lead to pet food labeling changes and regulatory requirements for the sale of products containing hemp or cannabidiol (CBD).

2025 Regulatory Update Part 1: What We Are Watching In The Pet Food Sector

APPA Team — Thu, 18 Dec 2025 19:46:10 GMT

Overview

Regarding the regulation of pet food, we have been monitoring the following: