§72 / US · MX · CA · CN

Cross-border trade — 10 things to know on May 31, 2026

Ten items as of May 31: US-Mexico round 1 closed May 29 with USTR joint readout — auto ROO, §232 steel/aluminum, economic security, and a new scope add (medical devices/pharma/cosmetics regulatory compatibility); Deputy USTR Jeffrey Gerrish led (not Greer); round 2 June 16-17 adds agriculture; round 3 week of July 20 slotted 4 days before §301 July 24 action; Canada track lagging — trilateral becomes de facto bilateral; §122 — CIT May 20 denied government stay but CAFC administrative stay holds; CAPE — ~1,880 refunds stuck on missing ACE ACH registration; §232 pharma 61 days; §301 54 days; CBAM Q2 36 days; Busan 163 days.

2026-05-31 · By Marcus · 6 min read

1. US-Mexico round one closed May 28-29 — USTR joint readout lands. Two days of substantive engagement. Three core agenda blocks: automotive rules of origin, §232 steel and aluminum derivatives' boundary conditions, economic security. A scope expansion worth a second look — medical devices, pharmaceuticals, and cosmetic-products regulatory compatibility now on the agenda. If concrete concessions emerge in round 2 (June 16-17 Washington), it's direct upside for Mexico's three largest pharma contract manufacturers. US-stated objectives are explicit: reduce the trade deficit with Mexico + strengthen American supply chains.

2. Deputy USTR Jeffrey Gerrish leads the US delegation (not Greer). We need to correct yesterday's piece — USTR's official statement names Jeffrey Gerrish. Greer did not personally attend. This positions round one as a technical working-group level event and saves the political signal for the formal July 1 trilateral kickoff. Mexico fielded Ebrard himself — the asymmetric seniority signals Mexico's elevated priority on these talks vs the US position. For CFOs, this is a low-noise indicator on how round 2 and 3 stance hardness may evolve.

3. Round 2 June 16-17 Washington — agriculture and "level playing field" added. USTR's announcement is explicit: the second round adds agriculture and level-playing-field topics. Mexican pork, cheese, and produce all enter the US-side push list. Ebrard's previously-prepped 5-20% retaliatory list (targeting US agricultural goods) arrives at its action timing.

4. Round 3 week of July 20 in Mexico City — placed four days before §301 July 24. Not coincidence. USTR slotted round 3 four days before the §301 16-economy investigation's affirmative action target. Mexico's core ask is avoiding being triggered on July 24 alongside China. Round 3's actual outcome decides whether Mexico is read as "ally" or "16-list co-target" on the §301 land date.

5. Canada track lags — trilateral becomes de facto bilateral. Carney's minority government hasn't yet stood up its own US track. Per Washington Trade & Tariff Letter: "USMCA review opens on the Mexico track, Canada lags." This means the US is writing the US-Mexico terms before the July 1 trilateral, then pressing Canada into a take-it-or-leave-it posture. Canadian retail and auto supply-chain planning teams face sharp incremental pressure.

6. §122 — CIT May 20 denies the government's stay motion, but CAFC's administrative stay holds. On May 20 the CIT closed off the door on a "second stay." CAFC's May 12 administrative stay keeps §122 collected for now. Bifurcated judicial state: CIT has ruled unlawful, CAFC has paused enforcement. The next gate remains CAFC's substantive appeal ruling, still landing before §301's July 24 action target.

7. CAPE refund administrative bottleneck — ~1,880 entries stuck on missing ACE registration. CBP's latest court-progress data: roughly 1,880 consolidated refunds cannot be transmitted to Treasury because the IOR has not registered ACH banking info in the ACE Portal. This is a technical bottleneck, not a policy delay — but for unregistered importers, refunds are effectively paused. Action step: check the Importer sub-account in ACE Portal for ACH details; if not registered, fix this week. CAPE issues no checks, ACH only.

8. §232 pharma 61 days from kickoff. 17 Annex III companies at 100% full value July 31. Other pharma companies September 29. Switzerland holds the 15% preferential tier. Ireland, India, China, Singapore, Belgium, Denmark, Germany, France, Italy stay default 100%. Importers exposed to these origin lines can use the Tariff Stack Calculator with the §232 pharma preset for aggregate-equivalent modeling.

9. §301 16-economy investigation 54 days to July 24 action target. Hearings closed May 8; rebuttals closed May 8. USTR is in synthesis phase. Bessent's May 19 "ceiling not floor" signal + MOFCOM's May 20 Busan-as-redline framing + the $30B reciprocal reduction framework — three vectors point to July 24 most likely being "current rates §301-codified," not a new round of increases.

10. CBAM Q2 36 days; Busan-truce 163 days. Two final H2 anchors. CBAM Q2 certificate price publishes July 6 — EU-bound exporters can run advance models on the CBAM Cost Estimator. The Busan November 10 expiry pulls everything else into its orbit — §122 judicial path, §301 action, §232 pharma steps, multi-year USMCA review — each one clock-aligning toward that date. H2 2026's actual sourcing-decision environment is now fully drawable.

Figures

Mar 2018
Original §232: 25% steel / 10% Al, metal-content basis
2019-2024
TRQ deals: JP 1.25 Mt · KR 2.63 Mt · EU quota
Feb 2025
Aluminum raised 10% → 25%
Apr 6 2026
Restructure: 50% A-I / 25% I-B / 15% transitional · full customs value
Dec 2027
Annex II 15% transitional carve-out expires
§232 STRUCTURE OVER TIME (CBP guidance · White House proclamations)
Figure 1 — §232 timeline. April 2026 marks the largest single restructure since the original 2018 proclamation.
0%25%50%75%100%🇨🇳 China§122§301§232 (50%)94%Effective ~94%🇯🇵 Japan§122§232 above-quota67%Above 1.25 Mt TRQ — in-quota = 17%🇰🇷 Korea§122§232 above-quota67%Above 2.63 Mt TRQ — in-quota = 17%🇬🇧 UK (95% melt-in-UK)§122§232 UK rate42%Special carve-out (50% ⇒ 25%)🇲🇽 Mexico§232 (full)50%USMCA exempts §122; melt-and-pour in MX/USA required
Figure 2 — Effective duty stack on HS 7208 (hot-rolled flat steel) into the US, by country of origin, post April 6 2026.
AnnexCoverageExamplesRateBasis
I-AArticles made entirely or almost entirely of steel/Al/CuBars, rods, plates, sheets, tubes, pipes, unwrought metal50%Full customs value
I-BDerivative articles with substantial metal contentBicycles, washing machines, prefab structures, wire products25%Full customs value (was: metal content)
IIMetal-intensive industrial / electrical grid equipment (transitional)Transmission towers, transformers, certain wind components15%Full customs value · expires Dec 31, 2027
IIITrade Agreement Partner-origin metal, drawback-eligibleAnnex I-B articles where metal smelted in UK/EU/JP/KR/MX/CAVariesDrawback restored
Figure 3 — §232 classification regime. Sources: April 2 2026 White House proclamation, Annexes I-A / I-B / II / III; CBP CSMS #68253075.