45Z tallow needs USITC injury support, while WTO reform does not preserve refunds
The USITC record and CBP procedural deadlines are where real money is won or lost right now. Neither front waits for a policy theory to mature.
Importers seeking tariff refunds cannot wait on WTO reform. Preserving recovery rights still turns on CBP liquidation status, protest deadlines, and the appropriate U.S. court path, and those clocks run independently of whatever dispute-settlement overhaul emerges in Geneva.
Section 45Z may be tightening North American tallow markets, but that theory has not yet been built on the USITC injury record in the fatty acids investigations. Respondents cannot assume the argument carries itself. If they want 45Z-related tallow cost pressure to factor into any non-subject cause analysis, they need evidence before the Commission, not just a plausible policy narrative. Leaving the record bare on this point is a concrete litigation risk.
Read the full analysis: The 45Z Tallow Theory Still Needs a Case Record.
WTO reform may reshape dispute leverage, but it does not rewrite U.S. refund mechanics. CBP liquidation status and protest deadlines still govern whether refund rights are preserved, and U.S. court options remain the operative path for contested recovery. Importers with live exposure should be tracking liquidation windows and litigation options now, not waiting for a multilateral outcome.
Read the full analysis: WTO Reform Leaves Tariff Refunds in U.S. Court.