CAPE Phase 3 Requires IOR Matching as Korea Aluminium Faces a Conditional 105.80% AD Assessment
The two immediate files require different work. CAPE plaintiffs need counsel-to-CBP IOR matching before Phase 3 declarations can be accepted, while importers with covered 2024-2025 Korea Aluminium entries should quantify the conditional 105.80% assessment scenario before Commerce issues final results.
Two files need immediate but different work. The July 15 Court of International Trade order requires covered CAPE Phase 3 plaintiffs to complete counsel-to-CBP IOR matching before declarations can be accepted. Separately, importers with subject Korea Aluminium entries from the 2024-2025 review period should quantify a conditional 105.80% assessment scenario while Commerce's final results remain pending.
Existing U.S. law can carry some tariff and non-textile origin changes from a USMCA amendment, but it does not resolve who holds authority to approve a binding amendment on behalf of the United States. That unresolved approval question is a threshold issue - implementation mechanics are secondary until it is answered.
Read the full analysis: USMCA Amendment Approval Is Separate From U.S. Implementation.
EO 14326's 40% IEEPA transshipment duty, not a blanket Vietnam rate, ended in February. Vietnam-routed entries still require an origin analysis to determine whether China-origin Section 301 duties apply, and false origin claims can create Section 1592 exposure. A temporary 10% Section 122 surcharge remains in place through July 24 and applies on a product-specific basis, so the rate picture is not uniform across Vietnam-origin goods.
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