May 6, 2026
Trade Relations
16 Economies Targeted

Global Supply Chains Face Pressure as Retaliatory Measures Expand

Major U.S. trading partners are continuing preparations for coordinated counter-tariff actions following recent American trade policy changes. Canada, the EU, and several Asian economies are reportedly evaluating additional duties on U.S. exports while also strengthening domestic trade-protection mechanisms. Analysts warn that prolonged tensions could reshape sourcing patterns across manufacturing and retail sectors worldwide.

Why it matters: Expanding retaliatory actions increase the likelihood of prolonged trade volatility and higher operational costs for importers and exporters. Businesses dependent on cross-border manufacturing networks face mounting uncertainty.

Watchouts: Monitor retaliatory tariff announcements and bilateral trade negotiations closely. Reassess international contract terms, pricing structures, and inventory strategies to reduce disruption risk.

May 3, 2026
Global Tariffs

Courts Continue Reviewing Legality of Temporary 10% Import Tariff

Legal challenges against the administration’s temporary 10% global tariff policy continue moving through federal courts as trade groups argue the measures exceed executive authority under Section 122. Importers remain subject to the duties while litigation proceeds, creating uncertainty for manufacturers, retailers, and logistics providers planning mid-year procurement strategies.

Why it matters: Ongoing legal uncertainty surrounding the tariff policy complicates pricing, sourcing, and inventory planning for businesses dependent on imported goods. Sudden policy reversals could also disrupt customs and refund procedures.

Watchouts: Prepare contingency plans for both continuation and suspension scenarios. Track court rulings closely and maintain detailed import documentation for potential future refund claims.

April 29, 2026
Section 301
Global Tensions

USTR Expands Hearings as New Tariff Investigations Accelerate

The Office of the U.S. Trade Representative (USTR) has expanded Section 301 hearings involving imports from China, Vietnam, Mexico, India, and several EU economies. Officials are reviewing allegations of excess industrial capacity and unfair trade practices in sectors including semiconductors, batteries, electric vehicles, and steel products. Analysts expect preliminary tariff recommendations to emerge by early summer.

Why it matters: Expanded Section 301 actions could introduce long-term tariff exposure across multiple industries. Importers may face renewed duties with limited adjustment periods once investigations conclude.

Watchouts: Businesses sourcing from Asia and Europe should evaluate alternative suppliers and assess landed-cost exposure now. Monitor USTR hearing schedules and product classification lists carefully.

April 20, 2026
Supreme Court
$166B Tariff Refunds

CBP Launches $166B Tariff Refund Portal After Supreme Court Ruling

The U.S. Supreme Court ruled in February 2026 that IEEPA-based tariffs exceeded presidential authority. CBP has since launched the CAPE portal, allowing over 330,000 importers to reclaim $166B in duties paid. Refunds are expected within 60–90 days of submission. Importers should act promptly — file through CBP’s ACE portal and consult your customs broker to confirm eligibility and documentation requirements.

Why it matters: This decision creates a significant cash flow opportunity for importers who paid invalidated tariffs. However, strict deadlines apply for filing claims. Importers must act quickly to preserve refund eligibility before statute of limitations expire.

Watchouts: Refund claims must be filed with CBP within strict timeframes. Documentation requirements are extensive. Consult customs counsel immediately to assess eligibility.

April 18, 2026
EU Trade Response
Global Tariff

€93B Counter-Tariff Package Gains Momentum Across Europe

European Union officials are moving closer to approving a sweeping €93 billion retaliatory tariff package targeting key U.S. exports after recent American tariff expansions on industrial goods and metals. Several EU member states are urging accelerated implementation timelines, while business groups across Europe warn that prolonged trade escalation could weaken transatlantic supply chains. The measures are expected to affect sectors including agriculture, aerospace, machinery, and consumer products.

Why it matters: Escalating tariff retaliation from the EU could significantly increase costs for U.S. exporters and multinational manufacturers operating across Europe. Businesses with integrated supply chains face growing compliance and pricing challenges.

Watchouts: Monitor EU Commission announcements and WTO developments closely. Review supplier diversification strategies and prepare for additional customs compliance requirements on transatlantic shipments.

April 2, 2026
Section 232
50% Tariff

50% Tariffs Now Apply to Steel, Aluminum & Copper on Full Customs Value

Effective April 2, 2026, President Trump revised Section 232 tariffs so that articles made entirely or almost entirely of steel, aluminum, or copper are now subject to a flat 50% tariff on their full customs value — not just the metal content. Derivative articles with substantial metal content face 25%, while metal-intensive industrial equipment is taxed at 15% through 2027. These changes significantly impact procurement costs across manufacturing, construction, and industrial supply chains.

Why it matters: The shift to full customs value calculation significantly increases effective tariff costs for metal-intensive products. Businesses in construction, manufacturing and industrial sectors face substantially higher import costs.

Watchouts: Review all metal-containing products for Section 232 applicability. Renegotiate supplier contracts where possible. Explore domestic sourcing alternatives to reduce tariff exposure.

March 12, 2026
60 economies targeted
Section 301

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.

March 11, 2026
16 economies targeted
Section 301

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.

March 4, 2026
IEEPA refund process
CIT ruling

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.

March 4, 2026
Increase from 10% to 15% pending
Section 122

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.

February 20, 2026
Effective Feb 24, 2026 — Expires July 24, 2026 (150 days)
Section 122

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.

February 20, 2026
6-3 ruling — All IEEPA tariffs invalidated
SCOTUS

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.

February 6, 2026
Secondary tariff framework
Executive Order

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.

February 6, 2026
Effective Feb 7, 2026 — HTS Ch.99 termination
Executive Order

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.

February 2, 2026
Commerce procedures — MHDVs (Canada/Mexico)
Section 232

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).