Tariff News & Section 301 Updates
Stay current on U.S. China tariffs, Section 301 actions, and global trade policy shifts that impact your supply chain.
March 11, 2026 · 16 economies targeted
March 12, 2026 · 60 economies targeted
March 4, 2026 · Increase from 10% to 15% pending
March 4, 2026 · IEEPA refund process
February 20, 2026 · 6-3 ruling — All IEEPA tariffs invalidated
February 20, 2026 · Effective Feb 24, 2026 — Expires July 24, 2026 (150 days)
February 2, 2026 · Commerce procedures — MHDVs (Canada/Mexico)
February 6, 2026 · Effective Feb 7, 2026 — HTS Ch.99 termination
February 6, 2026 · Secondary tariff framework
Recent Tariff Updates. What They Mean for You
Informational summaries only. Confirm specifics with your customs broker or trade counsel before acting.
USTR Initiates Section 301 Investigations Into Structural Excess Manufacturing Capacity Across 16 Economies
USTR launched Section 301 investigations into China, the EU, Japan, Mexico, Vietnam, India, Korea, Taiwan, Singapore, Switzerland, Norway, Indonesia, Malaysia, Cambodia, Thailand, and Bangladesh over structural excess capacity in manufacturing sectors including steel, aluminum, autos, batteries, semiconductors, chemicals, and electronics.
Why it matters: These investigations are widely viewed as the legal pathway to reimpose tariffs at or near pre-SCOTUS levels once the temporary Section 122 surcharge expires on July 24. Section 301 tariffs have no rate cap and no built-in expiration.
Watchouts: Public comments due Apr 15, 2026. Hearings scheduled May 5–8, 2026. New tariffs could land by late summer 2026.
USTR Initiates 60 Section 301 Investigations Into Failures to Ban Forced-Labor Imports
USTR launched a separate wave of Section 301 investigations into 60 economies (including Canada, the UK, Australia, Brazil, and major Asian and Middle Eastern trading partners) for failing to impose and effectively enforce bans on importing goods produced with forced labor.
Why it matters: This creates a second, parallel track for potential new tariffs covering a much broader set of countries. Even allies and partners with existing trade deals are included, which could add duty layers to supply chains previously considered low-risk.
Watchouts: Public comments due Apr 15, 2026. Hearings begin Apr 28, 2026. Audit forced-labor compliance in your supply chain now.
Treasury Secretary Confirms Section 122 Tariff Increase to 15% Expected This Month
Treasury Secretary Bessent confirmed the Section 122 global surcharge will increase from 10% to 15% (the statutory maximum). The President announced the increase on Feb 21 via social media, but as of this update no formal implementing order has been issued. Bessent also stated tariff rates would return to pre-SCOTUS levels within five months using other authorities.
Why it matters: A 15% floor raises landed costs across nearly all non-exempt imports. Importers quoting prices or planning inventory should model both the 10% and 15% scenarios until the formal order is published. The surcharge still expires July 24 unless Congress extends it.
Watchouts: No formal order issued yet; monitor Federal Register. USMCA-qualifying goods and Section 232 products remain exempt. 24 states have filed suit to block Section 122 tariffs.
Court of International Trade Orders Government to Begin Refunding IEEPA Tariffs
Judge Eaton of the Court of International Trade ruled that all importers of record whose entries were subject to IEEPA tariffs are entitled to refunds. CBP has stated that its systems cannot process refunds at this scale immediately and has requested approximately 45 days to build the necessary functionality in ACE. All refunds will be issued electronically via ACH.
Why it matters: Roughly $168 billion in IEEPA duties may be eligible for return. This is a significant potential cash recovery for importers, but the government is expected to appeal, and the timeline and mechanics remain uncertain.
Watchouts: Confirm your ACH info is current in ACE. Track liquidation dates on all IEEPA entries. Government appeal expected; refund timeline may shift.
Supreme Court Rules IEEPA Cannot Be Used to Impose Tariffs (Learning Resources v. Trump)
The Supreme Court held 6-3 that the International Emergency Economic Powers Act does not authorize the President to impose tariffs. All IEEPA-based tariffs, including reciprocal, fentanyl, and universal baseline duties, were struck down. CBP stopped collecting IEEPA tariffs effective 12:00 a.m. ET on Feb 24.
Why it matters: This eliminated the primary tariff authority used throughout 2025 and early 2026. The effective tariff rate dropped from roughly 14.3% to 7.3% immediately after the ruling, before the Section 122 replacement was imposed. Tariffs under Section 232, Section 301, and AD/CVD orders remain unaffected.
Watchouts: Refund eligibility depends on entry liquidation timing. De minimis duty-free treatment remains suspended. Section 232, 301, and AD/CVD tariffs still in effect.
10% Global Tariff Imposed Under Section 122 of the Trade Act of 1974
Hours after the SCOTUS ruling, the President issued a proclamation imposing a flat 10% surcharge on most U.S. imports under Section 122, citing balance-of-payments deficits. The tariff applies uniformly to all countries (no country-specific rates) and took effect Feb 24 at 12:01 a.m. ET. It is limited to 150 days unless Congress extends it.
Why it matters: Unlike the old IEEPA regime, Section 122 applies a single flat rate across all trading partners. Countries that previously faced high IEEPA rates (e.g., China, India, Vietnam) now see lower duties, while countries with low or negotiated rates may face higher ones. The 150-day clock creates a hard deadline for the Administration to establish replacement authorities.
Watchouts: USMCA-qualifying goods exempt. Section 232 products excluded (no stacking). Critical minerals, energy, pharma, electronics also exempt. In-transit exemption for goods loaded before Feb 24, entered before Feb 28.
USMCA MHDVs: Process to Apply 232 Tariff Only on Non-U.S. Content
Commerce published submission procedures for importers of USMCA-qualifying medium/heavy-duty vehicles (MHDVs) to document U.S. content so the 25% Section 232 tariff can apply exclusively to the non-U.S. content value.
Why it matters: This can materially reduce duty exposure for compliant USMCA MHDVs by shrinking the dutiable base, but it is documentation-heavy and requires consistent valuation and certification.
Watchouts: Submissions open Feb 2, 2026. CFO/GC-level certification required. Retroactive treatment possible to Nov 1, 2025 (discretionary).
Additional 25% Duty on Products of India Terminated
An Executive Order eliminated the additional 25% ad valorem duty previously imposed on imports of articles of India; specified Chapter 99 headings were terminated effective 12:01 a.m. EST on Feb 7, 2026.
Why it matters: Immediate landed-cost relief for Indian-origin imports previously paying the extra layer; also raises refund/entry-correction considerations depending on entry timing.
Watchouts: Confirm entry date/time vs. Feb 7 cutover. Refunds per CBP standard procedures. Tariff could be reimposed if conditions change.
New Tariff System Targeting Countries That Acquire Goods/Services from Iran
The Administration established a process to impose additional tariffs on imports from countries that directly or indirectly purchase, import, or otherwise acquire goods or services from Iran.
Why it matters: This expands "secondary tariff" risk: even if your supply chain avoids Iran-origin goods, your product's country of origin could become subject to added duties based on that country's Iran-related trade.
Watchouts: Framework in place — watch for country targets and rates. Update risk register for supplier countries. Bake tariff-change triggers into contracts.
Section 301 Tariffs & What They Mean Today
The Section 301 tariffs on China impact billions in imports, adding extra costs on top of the baseline 10% and reciprocal duties. For U.S. companies sourcing electronics, plastics, metals, or textiles, this means higher landed costs and shrinking margins. No surprise many search for Section 301 tariffs on China; the rules are complex, and mistakes get expensive.
At Importivity, we help you identify tariff exposure, check for possible exclusions, and apply proven strategies like tariff engineering, FTZ planning, and nearshoring to Mexico or Vietnam. Staying ahead of Section 301 changes isn’t optional; it’s how smart importers protect profits.
Key Trump-Era Tariff Changes Impacting Businesses
Date |
Policy Change |
Details |
Impact on Businesses |
February 11, 2026 |
India secondary tariff modified/terminated (Russia-related duty layer) |
Executive Order modifies duties imposed to address Russia-related threats and terminates India-related Chapter 99 tariff headings (removing the additional 25% layer on products of India). (Federal Register) |
Immediate landed-cost relief for importers sourcing from India; companies should review entries around the effective date and pursue refunds via PSC (unliquidated) or protest (liquidated) where eligible. |
February 2, 2026 |
USMCA medium/heavy-duty vehicle U.S. content submission procedures published |
Commerce published official submission procedures for importers of USMCA-qualifying medium/heavy-duty vehicles (MHDVs) to document U.S. content under the Section 232 vehicle framework. (Federal Register) |
Fleet operators and OEM importers must implement documentation workflows to preserve preferential treatment; missing submissions may result in higher effective duty exposure. |
January 20, 2026 |
Section 232 semiconductor & SME tariffs announced (derivative products included) |
Proclamation (Section 232) addresses imports of semiconductors, semiconductor manufacturing equipment (SME), and derivative products; CBP/HTS implementation guidance published for covered categories. (Federal Register) |
Major compliance and pricing impact for chip-related supply chains; importers must update HTS/Chapter 99 reporting and reassess contracts, landed-cost models, and alternative sourcing options. |
January 9, 2026 |
Section 232 timber/lumber/furniture tariff increases delayed |
Proclamation amends the Section 232 timber, lumber, and derivative products action, delaying scheduled tariff rate increases originally planned for January 2026. (Federal Register) |
Provides short-term cost relief for furniture retailers and construction supply chains; importers should adjust shipment timing plans and reassess sourcing from capped-rate partner countries. |
December 29, 2025 |
Nicaragua Section 301 implementation (Chapter 99 + FTZ privileged foreign status rule) |
USTR implementation notice updates HTS Chapter 99 for Nicaragua Section 301 action and establishes FTZ admission rules requiring covered goods admitted on/after the effective date to generally enter as privileged foreign status. (Federal Register) |
Importers using Nicaragua sourcing or FTZ strategies must coordinate with brokers on Chapter 99 reporting, review FTZ procedures, and assess refund/correction options for impacted entries. |
December 12, 2025 |
Section 301 action finalized on Nicaragua (labor/human rights/rule of law) |
USTR issued a formal Section 301 Notice of Action targeting Nicaragua’s policies and practices related to labor rights, human rights, and governance, authorizing trade remedies and phased implementation. (Federal Register) |
Companies with Nicaragua exposure should validate CAFTA-DR origin claims, review supplier documentation, and develop contingency sourcing plans ahead of phased duty risk. |
December 29, 2025 |
China semiconductors: Section 301 dominance investigation action published |
USTR published a Section 301 Notice of Action related to China’s semiconductor targeting policies, establishing a basis for future tariff actions and HTS implementation steps. (Federal Register) |
Semiconductor and electronics importers should reassess tariff exposure and classification strategy, monitor for follow-on implementation notices, and consider diversifying away from China for covered product categories. |
|
November 13, 2025 |
Agricultural products exempt from reciprocal tariffs |
Executive Order exempts 237 HTS classifications covering coffee, tea, tropical fruits, cocoa, spices, bananas, oranges, tomatoes, and beef from reciprocal tariffs; Brazil ag products also exempt from 40% additional duty. (White House) |
Immediate cost relief for food importers; file Post Summary Correction (unliquidated) or protest (liquidated) for refunds; update HTS codes to 9903.01.32 for exempt products. |
|
November 10, 2025 |
US-China trade deal & Section 301 maritime suspension |
Fentanyl tariff cut from 20% to 10%; reciprocal tariff suspension extended to Nov 2026; Section 301 maritime fees and STS crane tariffs suspended one year; China suspends rare earth controls. (White House) |
Lower Chinese import costs; maritime fee relief for shippers/ports; plan for Nov 2026 expiration; monitor Section 301 exclusions now extended to Nov 10, 2026. |
|
November 5, 2025 |
Supreme Court hears IEEPA tariff challenges |
3-hour oral arguments in Learning Resources v. Trump and Trump v. V.O.S. Selections; majority of justices appeared skeptical of IEEPA tariff authority; decision expected by year-end. (SCOTUSblog) |
Monitor liquidation dates and file protests within 180 days to preserve refund rights; prepare for potential tariff invalidation or alternative statutory reimposition. |
|
November 1, 2025 |
Medium/heavy-duty vehicle Section 232 tariffs effective |
25% on Class 3-8 vehicles and parts; 10% on buses; USMCA-qualified MHDVPs exempt; US manufacturers get 3.75% offset through 2030; EU/UK/Japan caps apply. (Federal Register) |
Fleet operators face higher costs; evaluate USMCA compliance; domestic assemblers should register for offset program; document US content for preferential treatment. |
|
October 30, 2025 |
US-China summit tariff reduction |
Trump and Xi meet in South Korea; US cuts fentanyl tariff from 20% to 10% in exchange for farm purchases and rare earth access; one-year agreement. (White House) |
De-escalates October 10 crisis; Chinese import costs reduced; companies should monitor one-year timeline and renewal negotiations. |
|
October 17, 2025 |
Section 232 medium/heavy-duty vehicle proclamation |
Proclamation imposing 25% on MHDVs (Class 3-8), parts, engines, transmissions, tires; 10% on buses; effective Nov 1; offset program for US manufacturers through 2030. (Federal Register) |
Fleet operators plan for Nov 1 cost increases; manufacturers evaluate offset eligibility; USMCA compliance critical for exemptions. |
|
October 15, 2025 |
Section 301 ship-to-shore crane tariffs finalized |
100% tariffs on Chinese STS cranes, intermodal chassis, chassis parts effective Nov 9 (later suspended Nov 10); containers removed from tariff list; cranes contracted before April 17, 2025 exempt if entering by April 18, 2027. (USTR Federal Register) |
Port authorities and shipping companies assess procurement contracts; container exemption provides relief; monitor Nov 10 suspension terms. |
|
October 14, 2025 |
Section 232 timber, lumber, furniture tariffs |
10% on softwood timber/lumber; 25% on upholstered furniture and cabinets; rates increase Jan 1, 2026 to 30% and 50%; UK capped at 10%, EU/Japan at 15%. (CBP Guidance) |
Homebuilders and furniture retailers accelerate imports before Jan 1 increases; evaluate sourcing from UK/EU/Japan for capped rates. |
|
October 10, 2025 |
Additional 100% tariff on China announced (later resolved) |
Additional 100% on Chinese goods announced in response to rare earth controls; effective Nov 1; would stack on existing tariffs; resolved at Oct 30 summit. (White House) |
Created extreme volatility; ultimately de-escalated; demonstrates need for diversified supply chains and contingency plans. |
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Actionable Steps For Businesses
To navigate the shifting tariff landscape, businesses should begin by reviewing their supply chains to identify exposure to affected imports and explore opportunities for diversification. At the same time, it’s crucial to adjust financial planning to account for increased costs, both in sourcing and pricing, ensuring that budgets and profit margins remain sustainable in the face of rising import duties.
- Apply for Tariff Exclusions: Check eligibility for product-specific exclusions through USTR or CBP.
- Diversify Supply Chains: Engage alternative suppliers from unaffected regions or countries with lower tariffs.
- Cost Mitigation: Renegotiate supplier agreements or adjust pricing strategies to minimize tariff impacts.
- Review Relief Programs: Explore eligibility for reimbursement programs related to automotive tariffs and steel/aluminum tariff relief efforts.
Diversifying Supply Chains With a Vietnam Backup Mold
Explore a recent (2025) case study where Importivity helped businesses recieve tariff relief.
Plan B Mold Strategy: China for Scale, Vietnam for Tariff Relief
How a consumer goods brand neutralized 25% Section 301 exposure by building a backup mold in Vietnam — unlocking six-figure annual savings and real negotiating power.
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01
The Challenge A U.S. consumer brand relied on one Chinese supplier — and one mold — for a top-selling product. When China Section 301 duties rose to 25%, margins collapsed and disruption risk spiked with no alternative in place.→1Factory & mold25%Tariff exposureHighDisruption riskTopRevenue critical SKU
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02
The Solution A duplicate mold and tooling built at a long-standing partner factory in Vietnam — enabling instant production switching if China tariffs spike or supply disruptions hit.→Lane A — China Primary line for volume, rapid scheduling, and established manufacturing workflows.Lane B — Vietnam Backup and parallel line for tariff-protected production runs and surge capacity.
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03
Results & Impact Moving 30% of volume to Vietnam eliminated the tariff burden on that portion of production — delivering measurable annual savings, stronger supplier leverage, and zero single points of failure.→$480kAnnual tariff savings30%Volume shiftedDualSourcing capability↑China negotiating power
Avoided duty =
25% × Shifted Volume
Savings $480k → Volume shifted ≈$1,920,000
30% of output → Total production ≈$6,400,000 -
04
Why It Works Importivity builds proactive redundancy — duplicate molds, sister factories across countries, and parallel logistics lanes — so clients stay a step ahead of policy shifts, protecting margins and continuity long-term.→
Tariff Engineering
Tariff engineering involves designing or classifying products in a way that legitimately lowers their tariff rate. From adjusting materials to altering assembly processes, we help companies avoid unnecessary duties without compromising quality or compliance.
1
Foreign Trade Zones (FTZ)
By routing imports through an FTZ, businesses can delay or even eliminate certain tariffs. This approach is especially powerful for high-volume importers or companies handling complex, multi-country supply chains.
2
Duty Drawback Programs
If your imports are later exported or destroyed, you may qualify for a refund of the duties you initially paid. We help clients navigate the paperwork and timelines to reclaim significant sums that would otherwise be lost.
3
First Sale for Export
The First Sale rule allows duties to be calculated on the manufacturer-to-middleman price instead of the final sale price. This simple change in documentation can reduce tariff costs by double digits.
4
Supply Chain Diversification
Incorrect HTS codes are one of the most common causes of inflated duties. Our compliance team reviews your classifications to ensure every SKU is coded accurately, saving thousands in unnecessary fees.
5
Frequently Asked Questions
If you need further assistance, feel free to reach out to our team!
What are tariff mitigation strategies?
Tariff mitigation strategies are proactive steps businesses take to reduce the financial impact of duties, like Section 301 tariffs on China. These strategies include tariff engineering, using Foreign Trade Zones (FTZs), claiming duty drawback, leveraging First Sale pricing, and diversifying supply chains into countries like Mexico or Vietnam.
How can tariff engineering lower my costs?
Tariff engineering involves adjusting the product’s design or classification so it falls into a more favorable HTS category. Done correctly, it can reduce your duty rate legally while maintaining compliance with U.S. Customs. Importivity guides businesses through this process to ensure savings without risk.
What is a Foreign Trade Zone (FTZ), and how does it work?
An FTZ is a designated area within the United States where imported goods can be stored, processed, or assembled without immediately paying duties. Tariffs are deferred until products leave the FTZ, and in some cases eliminated altogether. This is a powerful tool for high-volume importers facing ongoing tariff news changes.
Can I get a refund on tariffs I’ve already paid?
Yes. Through duty drawback programs, businesses can recover duties on goods that are exported, re-exported, or destroyed. While the process is paperwork-intensive, Importivity helps companies file correctly and reclaim thousands in tariff refunds.
What is the First Sale rule and why does it matter?
The First Sale for Export rule allows companies to calculate tariffs based on the price paid to the first seller (the manufacturer), not the final sale price to the importer. This can significantly lower the duty value and reduce costs on every shipment.
How does supply chain diversification protect against tariffs?
Relying solely on China means being vulnerable to Section 301 tariffs and trade policy shifts. By diversifying production into Vietnam, Mexico, or other countries, businesses can reduce tariff exposure, gain leverage with suppliers, and keep their supply chains resilient.
Are tariff mitigation strategies legal?
Yes, every strategy Importivity uses, from FTZs to First Sale and tariff engineering, is fully compliant with U.S. Customs and Border Protection. The key is having expert guidance to avoid missteps that could trigger penalties.
How do I know which tariff mitigation strategy is right for my business?
The right approach depends on your product mix, import volumes, and markets. For example, FTZs work best for large-volume importers, while smaller brands may benefit more from First Sale or supply chain diversification. Importivity provides tailored tariff consulting so you can choose the most effective path.
Can Importivity help me with Section 301 tariffs on China specifically?
Absolutely. Many of our clients come to us searching for Section 301 tariffs China help. We analyze your product codes, explore exclusion opportunities, and design contingency plans, like moving production to Mexico or Vietnam, to protect your margins.
How often do tariff rules change, and how can I keep up?
Tariff news shifts frequently, sometimes monthly. Exclusions expire, reciprocal tariffs change, and new Executive Orders reshape trade rules overnight. That’s why Importivity maintains a live tariff tracker and updates clients regularly so they’re never caught off guard.
Still have questions?
Our team is happy to help! Visit our Help Center or contact us directly.