Two tariff clocks ran out this week, and a third started ticking. On April 20, U.S. Customs and Border Protection opened the CAPE refund portal for an estimated $127 billion in IEEPA duties the Supreme Court struck down in February — the first recovery channel available to importers who paid tariffs now deemed unlawful. On April 15, the USTR comment docket for two Section 301 investigations closed, locking in the input window for what will become the permanent replacement regime. And between April 17 and April 18, Iran reopened the Strait of Hormuz, then reversed course, sending Brent crude on a three-day round trip from $100 to below $90 to back above $95. For procurement teams managing active RFQs, every quote now carries three overlapping tariff histories, and the oil basis under petroleum-derived inputs shifted four times in one week.
$127 Billion IEEPA Refund Window Opens — Phase 1 Prioritizes Speed Over Completeness
At 8 a.m. EDT on April 20, CBP launched Phase 1 of the Consolidated Administration and Processing of Entries (CAPE) system inside the ACE portal, beginning the electronic refund process for an estimated $127 billion in IEEPA duties. The Supreme Court struck down the tariffs in February, and the government owes roughly $166 billion total — the vast majority of which is eligible for electronic refunds because most importers already receive ACH payments from CBP.
Phase 1 has two hard eligibility limits. Only importers of record or the licensed customs broker who filed the entry may submit a claim, and only entries that are either unliquidated or liquidated within the preceding 80 days qualify at launch. Importers file a CAPE Declaration — a CSV upload listing entry numbers — through a new tab in the ACE portal. CBP then validates the entries, removes the IEEPA tariff provisions, recalculates duties, and issues a consolidated ACH refund to the importer of record. Refunds are projected to take 60–90 days from acceptance.
| Element | Phase 1 Detail |
|---|---|
| Launch | April 20, 2026, 8:00 a.m. EDT |
| Eligible population | $127B of ~$166B total IEEPA duties owed |
| Entry eligibility | Unliquidated + liquidated within past 80 days |
| Filer | Importer of record or licensed broker who filed entry |
| Filing mechanism | CSV upload in CAPE tab of ACE portal |
| Processing time | 60–90 days post-acceptance |
| Payment method | ACH to importer of record |
Key takeaway: For procurement teams that managed imports under IEEPA rates, the refund is real but narrowly scoped in Phase 1. Entries liquidated more than 80 days ago are not eligible at launch — a critical exclusion for long-cycle capital project procurement, where customs entries often liquidate well before equipment reaches commissioning. Finance and trade compliance teams should immediately inventory eligible entries, coordinate with brokers on CSV preparation, and stage claims against liquidation risk. The organizations that move first will also establish the cleanest paper trail for Phase 2, when CBP extends eligibility to finally liquidated entries. Refunds recovered on capital project components materially improve landed cost reconciliation on bids that were evaluated under a tariff basis that no longer applies.
Hormuz Reopens, Then Shuts — Brent Round-Trips $100 to $90 to $95 in 72 Hours
On April 17, Iran’s foreign minister announced the Strait of Hormuz was open to all commercial shipping for the duration of the Lebanon ceasefire. Brent crude fell roughly 11% in the immediate aftermath, briefly trading below $90 per barrel on April 18 — the lowest level in five weeks. Within hours, the reopening narrative unraveled. Commercial ships reported having to coordinate with Iranian forces for transit approval, and some turned away.
On April 18, Iran reversed course entirely, declaring the strait had “returned to its previous state” and restoring transit restrictions pending a full U.S. lift of the naval blockade on Iranian ports. By Monday, April 20, Brent had climbed back above $95 per barrel, up more than 5% intraday after President Trump said the U.S. Navy had fired on and seized an Iranian-flagged cargo vessel in the Gulf of Oman. The IEA now estimates more than 12 million barrels have already been lost since the conflict began, with April disruptions projected to hit Europe harder.
Physical tanker throughput remains severely degraded. Crude, NGL, and refined product loadings through Hormuz have averaged approximately 3.8 million barrels per day in early April, compared with more than 20 million bpd in February before the crisis. As covered in last week’s brief, the physical oil market remains in structural deficit with 13 million bpd of production shut in and a months-long ramp even when transit normalizes. Aluminum futures tracked the whiplash in real time — briefly falling to $3,550/tonne on April 16 from a three-year high of $3,670 on the reopening signal before climbing again as restoration failed.
Key takeaway: The three-day price round trip is the signal, not the noise. Quote validity windows on energy-intensive equipment and petroleum-derived materials need to accommodate multi-directional moves, not just escalation. A vendor that submitted a quote on April 15 against $100 Brent, resubmitted on April 18 against $88, and is now defending against $95 is caught flat-footed if the procurement team cannot rapidly normalize the three submissions against a common energy-basis anchor. Teams running active RFQs on petrochemical feedstocks, coatings, resins, insulation, aluminum, and steel should build symmetric revalidation into RFQ cycles — tracking both downward and upward deltas across submissions, not just the direction tariffs and energy costs are expected to move.
Section 301 Comment Docket Closes — The Permanent Regime Begins Its Construction
The April 15 deadline for written comments on the USTR’s parallel Section 301 investigations — targeting structural excess capacity in 16 economies and forced labor enforcement across 60 trading partners — passed at 11:59 p.m. EST. As covered in our March 30 and April 13 briefs, this was the last input window procurement organizations would have before the USTR begins constructing tariff determinations.
Attention now shifts to the hearing calendar, where public testimony becomes the remaining mechanism for shaping outcomes:
- April 28–May 1: Public hearings on forced labor enforcement track
- May 5–8: Public hearings on industrial excess capacity track
- Within 7 days post-hearing: Rebuttal comments due for each track
- Mid-to-late 2026: Tariff determinations expected, potentially aligning with July expiration of temporary Section 122 tariffs and the USMCA review
The investigations cover steel, aluminum, chemicals, plastics, machinery, batteries, semiconductors, and construction materials — the core input categories for EPC, LNG, T&D, and manufacturing procurement. Unlike the struck-down IEEPA tariffs that CAPE now refunds, Section 301 tariffs carry no statutory cap or expiration. Rates set through this process become the durable tariff floor.
Key takeaway: The window to influence Section 301 outcomes through writing is closed; the window to influence them through testimony is open for the next three weeks. Procurement organizations whose capital project cost structures depend on imports from the 16 targeted economies should inventory their company-specific data — landed cost deltas, domestic sourcing constraints, project timeline exposure — and coordinate with trade counsel on whether hearing testimony is warranted. Organizations that filed comments before the deadline now have standing to submit rebuttal comments after hearings close, which is the most tactical remaining leverage point in the process.
NextDecade Awards Rio Grande LNG Trains 4–5 to Honeywell and Bechtel
NextDecade’s Rio Grande LNG LLC awarded Honeywell a contract on April 14 to supply liquefaction process technology and equipment for Trains 4 and 5 at the 30 million tpy Brownsville, Texas facility. The award flows through existing EPC contractor Bechtel Energy and extends the Honeywell C3MR process and high-efficiency coil-wound heat exchanger technology used on the first three trains. Trains 4 and 5 will lift the plant’s total capacity from 18 million tpy to 30 million tpy, with all five trains targeted for operation by mid-2031.
The award lands in the same week that Saipem secured two offshore contracts worth approximately $400 million under its long-term Aramco agreement — EPCI work on water injection facilities at the Safaniya field. Together, the two awards signal that large-scale EPC capex in oil, gas, and LNG is not cooling despite the tariff overhang. It is compressing into established contractor-supplier pairings with mature technology packages.
Key takeaway: For LNG and EPC procurement teams, the Rio Grande award is a reference point for how capacity expansions are now being procured: repeat-technology licensing, incumbent EPC, and long-cycle equipment locked in six to seven years ahead of commissioning. The implication for sub-tier sourcing is material. Trains 4 and 5 will trigger downstream RFQs for compressors, heat exchangers, cryogenic piping, and instrumentation that must be evaluated against a tariff regime that is itself still in motion — with Section 232 metals rules restructured April 6, Section 301 determinations pending, and IEEPA refunds now filable. Sub-tier suppliers bidding into the Rio Grande expansion will carry different landed cost trajectories depending on sourcing region, metal content, and whether their customers can file for IEEPA refunds on prior component entries.
What to Watch
- CAPE Phase 2 timing. CBP has not published a date for Phase 2, which is expected to extend refund eligibility to finally liquidated entries beyond the 80-day Phase 1 window. For capital project procurement organizations with long-cycle import entries that liquidated months ago, Phase 2 is the decisive milestone. Monitor CBP trade remedies guidance and the CBP IEEPA duty refunds page for announcement.
- Section 301 hearing testimony (April 28 and May 5). The first wave of hearings begins next week. Which industries testify, what data they present, and whether any sector secures a carve-out signal will shape the contour of the eventual tariff determinations. Watch in particular for testimony from steel, chemicals, and machinery sectors — the input categories most exposed in EPC and manufacturing supply chains.
- Hormuz status as ceasefire window narrows. The 14-day ceasefire window that accompanied the April 17 reopening is already fracturing. If Iran formalizes the closure or the U.S. expands naval interdiction, the petroleum-derived input basis will continue resetting weekly. Dated Brent remains the leading indicator; watch for sustained moves above $100 or below $85 as signals that the next phase — escalation or de-escalation — is crystallizing.
- USMCA review track. Formal USMCA review proceedings continue bilaterally between the U.S. and Mexico, with the July 1, 2026 extension decision approaching. Removal of existing carve-outs could add meaningful additional tariff exposure to components sourced through Mexico — relevant for manufacturing BOMs and T&D equipment assembled across the North American corridor.