Generic-Drug Tariff Identity Gap + 3 More Analyses
Open the analysis that changes an entry, sourcing decision, or litigation record today. Each includes the full reasoning and source trail.
Good morning. Yesterday, the analysis desk published four source-backed reads on pharmaceutical origin, forced-labor enforcement, Canadian Section 338 tariffs, and downstream IEEPA refund claims.
The announced 2028 generic drug tariff cannot reward a U.S. plant until the government decides how API origin and ANDA sites identify an American product. Entry records add a third test, making the two-year runway a qualification and site-transfer clock.
Read it in full: 2028 Generic Drug Tariff Still Lacks a Product Identity Rule.
Jordan signed a U.S. trade deal after USTR proposed a 12.5 percent Section 301 tariff in its forced-labor investigation. Annex I leaves the rate open, while treatment of U.S. Section 307 entity determinations may provide early implementation evidence.
Read it in full: Jordan Deal Links Customs Action to Forced-Labor Section 301.
Three Section 338 tariffs on Canadian goods take effect August 19, but the proclamations do not state a factual test for relief. Import teams should separate proof of Canadian action from the U.S. record before repricing entries.
Read it in full: Canada Section 338 Tariffs Lack a Shared Test for a Fix.
Downstream IEEPA tariff refund claims need more than an invoice line item because the record should connect the charge to a shipment, customs entry, and CBP payment. The Nabavian dispute turns on whether the intermediary collected for the government or exercised its own pricing choice.
Read it in full: IEEPA Tariff Refund Claims Turn on a Four-Link Proof Chain.