Trade Compliance March 19, 2026 Tiago Suaid

US Tariffs 2026: The Complete Importer's Guide

The tariff landscape changed dramatically in 2026. A Supreme Court ruling invalidated most IEEPA tariffs, de minimis was eliminated globally, and a new Section 122 duty is in effect. Here's what every importer needs to know.

What Happened: The Supreme Court Ruling That Changed Everything

In February 2026, the Supreme Court ruled in Learning Resources, Inc. v. Trump that IEEPA tariffs were unconstitutional. This single decision invalidated the legal basis for most of the tariffs imposed since 2025 — an estimated $166 billion in duties collected from over 330,000 businesses.

The ruling means that importers who paid IEEPA-based tariffs may be entitled to refunds. US Customs and Border Protection is processing claims, but the process requires proper documentation and filing within statutory deadlines.

Current US Tariff Structure (March 2026)

Tariff TypeRateStatus
Section 122 Global Duty10-15%Active — expires July 24, 2026
Section 301 (China)7.5-25%Under new investigation (March 2026)
Section 232 (Steel/Aluminum)25% / 10%Active — some EU exclusions
USMCA-compliant (Mexico/Canada)0%Active — renegotiation in 2026
EU-origin goodsMFN rates (0-6%)No FTA in force
Vietnam/India/IndonesiaMFN rates + Section 122Active — under Section 301 review

The De Minimis Elimination: What It Means for Your Shipments

As of February 24, 2026, the US eliminated the $800 de minimis exemption globally. Every single import shipment — regardless of value — now requires formal customs entry with HTS classification, country of origin verification, and full duty payment.

This affects e-commerce brands, small importers, and any company that shipped individual parcels under $800 to avoid duties. The impact is massive: millions of shipments that previously cleared customs automatically now need a licensed customs broker.

Need Help Navigating 2026 Tariffs?

Our customs team provides free tariff exposure assessments. We'll analyze your HTS codes, identify savings opportunities, and handle refund claims.

How to Claim IEEPA Tariff Refunds

  1. Gather your entry documentation: Collect all customs entry summaries (CF-7501) for shipments where IEEPA tariffs were paid. You need the entry number, date, HTS code, and duty amount for each.
  2. File a protest with CBP: Submit CBP Form 19 (Protest) within 180 days of liquidation for each entry. Include the Supreme Court ruling citation and your calculation of the refund amount.
  3. Work with your customs broker: Your customs broker or freight forwarder can file protests in bulk on your behalf. This is significantly faster and reduces the risk of errors that could delay your refund.
  4. Monitor refund processing: CBP is processing refunds in batches. Timeline varies from 30-180 days depending on volume and complexity. Your broker can track the status of each protest.

Strategies to Minimize Your Tariff Exposure in 2026

  • Proper HTS classification — Many importers overpay duties because their goods are classified under the wrong HTS code. A tariff review can often reduce rates by 5-15%.
  • Country of origin engineering — If your product has components from multiple countries, proper origin determination can qualify for preferential treatment under FTAs.
  • Foreign Trade Zones (FTZ) — Importing into an FTZ defers duties until goods enter US commerce. Goods re-exported from an FTZ pay zero duties.
  • First Sale valuation — If your supply chain has multiple sales before import (factory → trader → importer), you may use the first sale price as the customs value, reducing the dutiable amount.
  • Bonded warehousing — Store goods in a bonded warehouse and pay duties only when goods are withdrawn for domestic sale. Useful for managing cash flow.
  • USMCA and FTA utilization — Ensure you claim all available preferential tariff treatment. Many importers leave money on the table by not filing proper FTA certificates.

What's Coming Next: Section 301 Investigations in 2026

In March 2026, the US launched new Section 301 investigations targeting imports from China, Vietnam, Taiwan, Mexico, Japan, the EU, and dozens more countries. These investigations could result in new targeted tariffs within 6-12 months.

Importers should prepare by: diversifying sourcing, pre-qualifying alternative suppliers, and working with a customs broker who monitors tariff developments and can adjust classification strategies proactively.

US Tariffs 2026 FAQ

Can I get a refund for IEEPA tariffs I already paid?

Yes. The Supreme Court ruled IEEPA tariffs unconstitutional. File a CBP protest (Form 19) within 180 days of liquidation for each affected entry. Your customs broker can handle this in bulk.

What is Section 122 and how long does it last?

Section 122 of the Trade Act of 1974 allows a 150-day import duty of 10-15% on all goods. It took effect after the Supreme Court ruling and expires July 24, 2026 unless renewed or replaced.

Do USMCA goods still enter duty-free?

Yes. USMCA-compliant goods from Mexico and Canada are exempt from Section 122 duties. Proper rules of origin documentation is required.

How does de minimis elimination affect my e-commerce imports?

Every shipment now requires formal customs entry, regardless of value. You need HTS codes, country of origin verification, and a licensed customs broker. No exceptions.

Should I switch suppliers to avoid tariffs?

Possibly. A tariff engineering analysis can identify whether alternative sourcing from FTA partners, tariff-advantaged countries, or nearshoring options would reduce your total landed cost. We offer free tariff exposure assessments.

What Section 301 tariffs are still active on China?

As of March 2026, fentanyl-related tariffs on Chinese goods are at 10% (reduced from 20% under a November 2025 agreement). New Section 301 investigations launched in March 2026 could result in additional targeted tariffs.

What are the current US import tariffs in 2026?

US import tariffs in 2026 are governed by a combination of MFN base rates from the HTSUS (Harmonized Tariff Schedule of the United States), Section 301 China tariffs (originally imposed 2018, modified through 2026), Section 232 steel and aluminum tariffs (25% on most steel, 10% on aluminum), reciprocal tariffs introduced in April 2025 (15-50% on imports from countries with US trade deficits), and new IEEPA-based tariffs on Mexico, Canada, and China imposed February 2025 (10-25%). The combined effect: many imports now face 35-60% total duty when accounting for stacked Section 301 + reciprocal + base MFN rates. The 90-day reciprocal tariff pause announced April 2025 has been partially extended for some countries through 2026 but is subject to ongoing trade negotiations. Verify current rates at the time of booking as the regulatory environment is unusually volatile.

How do Section 301 China tariffs work in 2026?

Section 301 tariffs were originally imposed by the Trump administration in 2018-2019 in four lists (List 1: 25% on $34B in goods, List 2: 25% on $16B, List 3: 25% on $200B initially at 10%, List 4A: 7.5% on $120B). The Biden administration maintained most of these rates and added new tariffs on Chinese EVs (100%), batteries (25-100%), semiconductors (50%), solar cells (50%), and steel (25%) in 2024. The 2025 Trump administration added additional 10-20% on top of existing rates. In 2026, total Section 301 duty for many Chinese goods exceeds 50%. Our partner network helps importers explore mitigation strategies: tariff engineering (modifying products to qualify for lower HTS codes), first sale valuation (reducing the dutiable value), foreign trade zone (FTZ) routing, and substantial transformation in third countries (Mexico, Vietnam, Thailand) to legally avoid Section 301.

Which countries are affected by US reciprocal tariffs in 2026?

The April 2025 reciprocal tariff order targets countries based on their bilateral trade deficit with the United States. Affected countries include: China (additional 34% on top of existing tariffs, totaling 54%+ in many categories), EU (20% additional), Vietnam (46%), Taiwan (32%), Japan (24%), India (26%), South Korea (25%), Thailand (36%), Switzerland (31%), Indonesia (32%), Malaysia (24%), Cambodia (49%), Bangladesh (37%). Mexico and Canada have separate IEEPA-based 25% tariffs (with USMCA exemptions for compliant goods). The UK got a baseline 10%. The 90-day pause announced April 9, 2025 reduced most reciprocal tariffs to a 10% baseline for negotiating countries while maintaining 145% on China (later modified). The situation continues to evolve — check status before each shipment.

How can importers reduce US tariff exposure in 2026?

Several strategies can legally reduce US tariff exposure: **Tariff engineering** — modifying product specifications to qualify for lower HTS codes (e.g., adding components, changing assembly steps). **First sale rule** — using the manufacturer-to-middleman price as the dutiable value instead of the middleman-to-importer price, often reducing dutiable value by 20-35%. **Foreign Trade Zones (FTZ)** — bringing goods into US-designated FTZs without immediate duty payment, only paying when goods leave the zone for US consumption (avoiding duty on re-exports and inverse-flow operations). **Substantial transformation in third countries** — moving final manufacturing to Mexico, Vietnam, Thailand, or Cambodia where Section 301 doesn't apply (must demonstrate genuine substantial transformation, not just trans-shipment). **USMCA qualification** — ensuring Mexican-made goods meet USMCA rules of origin for duty-free treatment. **Duty drawback** — recovering up to 99% of duties on re-exported goods. Our supply chain advisory partners model the cost impact of each strategy for your specific HTS codes and supply chain footprint.

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