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 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 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.

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.

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 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 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).

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 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.

March 28, 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.

March 28, 2026
Section 122
Global Tariff

New 10% Global Tariff Imposed Under Section 122 — Valid Until July 2026

After the Supreme Court struck down IEEPA tariffs, President Trump immediately invoked Section 122 of the Trade Act of 1974 to impose a new 10% global tariff on most imports. This tariff is valid for 150 days (until July 24, 2026) unless extended by Congress. Courts are currently reviewing its legality. Importers should prepare for continued tariff obligations while monitoring legal developments closely.

Why it matters: This new 10% global tariff affects most imports and is currently the primary tariff mechanism following the Supreme Court ruling. Importers must account for this cost while monitoring its legal status.

Watchouts: The tariff expires July 24, 2026 unless Congress extends it. Courts are reviewing its legality. Prepare contingency plans for both continuation and removal scenarios.

March 28, 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 28, 2026
Trade Retaliation
Global Tensions

Global Retaliation Builds as Countries Prepare Counter-Tariff Measures

As U.S. tariff policies continue to evolve, trading partners are actively preparing retaliatory measures. The UK is reportedly developing its own trade enforcement instrument modeled on the EU’s anti-coercion mechanism, while the EU has threatened to deploy €93 billion in counter-tariffs. Escalating U.S.-UK tensions — compounded by disagreements over Iran — have put existing trade deals under pressure. Importers and exporters should closely review sourcing strategies and contract terms to account for potential cross-border cost increases.

Why it matters: Retaliatory measures from major trading partners could disrupt existing supply chains and increase costs for U.S. exporters. Businesses with international operations face growing uncertainty on both import and export sides.

Watchouts: Monitor developments with the EU, UK and other key trading partners. Review export contracts for tariff escalation clauses. Diversify markets where possible to reduce dependency on any single trade relationship.

March 28, 2026
Section 301
16 Economies Targeted

New Section 301 Investigations Signal Potential Tariff Reintroductions

Following the Supreme Court’s invalidation of IEEPA tariffs, USTR initiated Section 301 investigations on March 11, 2026 into 16 economies — including China, the EU, Japan, Mexico, Vietnam, and India — over structural excess manufacturing capacity. Sectors flagged include steel, aluminum, semiconductors, batteries, and autos. Tariffs under Section 301 are more durable and not subject to time limits. New duties could be imposed as early as summer 2026 once investigations conclude.

Why it matters: Section 301 tariffs are more durable than IEEPA or Section 122 duties — no time limits apply. Businesses should prepare for potential long-term tariff increases across multiple sectors.

Watchouts: Investigations target 16 economies across steel, semiconductors, batteries and autos. New duties could arrive as early as summer 2026. Monitor USTR hearings starting May 5, 2026.