2026 US Import Tariff Report:
Section 301, 232, IEEPA & USMCA

1 US Import Tariff Landscape Overview (May 2026)

The current US tariff structure is not a single number — it's a stack of up to five overlapping duties that apply simultaneously depending on the product and origin country. The 2026 tariff landscape is the most complex in modern history.

2 Section 301 Tariffs — Current Status

Section 301 of the Trade Act of 1974 is the primary authority for US tariffs on Chinese goods and targeted third-country goods. These tariffs were initiated in 2018, expanded through 2024, and escalated to 84% additional duties on all remaining Chinese goods in April 2025.

2A. Timeline of Section 301 Tariffs on China

2B. Current Section 301 Rates by Product Category (China)

3 Section 232 Tariffs — Steel, Aluminum & Derivatives

Section 232 tariffs on steel were increased from 25% to 50% effective April 7, 2026. USMCA-compliant goods from Canada and Mexico remain at 0% — creating a significant cost advantage for importers who can document North American origin.

3A. Current Steel Tariffs

3B. Current Aluminum Tariffs

4 Section 122 Tariffs — Invalidated May 7, 2026

On April 2, 2025 ("Liberation Day"), President Trump imposed a 10% baseline tariff on all imports under IEEPA authority. On May 7, 2026, the Court of International Trade (CIT) ruled that this exceeded presidential authority and invalidated Section 122 tariffs, ordering CBP to process refunds.

How to File for Section 122 Refunds

1. 1 Access the CAPE portal at cbp.gov/cape (requires ACE account)
2. 2 Identify entries with Section 122 duties paid (10% baseline IEEPA tariff)
3. 3 File a CAPE declaration with your refund claim and supporting documentation
4. 4 For complex entries, consult a licensed customs broker
5. 5 Monitor for appeal status — the ruling may be challenged by DOJ

5 Reciprocal & Retaliatory Tariffs

Reciprocal tariff rates vary significantly by economy. Most countries are in active negotiations with reduced or paused rates. China faces the highest rates — 84% reciprocal on top of existing Section 301 duties.

5A. Current Reciprocal Tariff Rates by Economy

6 De Minimis Threshold Changes

The $800 de minimis exemption — previously one of the highest in the world — has been dramatically curtailed. Chinese goods no longer qualify, and the threshold for all other countries was reduced from $800 to $50.

7 IEEPA Refund Programs — $166B+ Available

Importers who paid Section 232 and Section 301 duties may be eligible for refund via the CAPE portal for entries paid under IEEPA authority. The CIT's May 7, 2026 ruling on Section 122 significantly expanded the pool of eligible refund claims.

How to File via CAPE Portal

1. 1 Register for the ACE portal at cbp.gov/ace
2. 2 Identify eligible entries — look for IEEPA-authority duty payments in your entry history
3. 3 Obtain customs broker assistance for complex entries with multiple duty layers
4. 4 File CAPE declaration — Phase I covers straightforward entries now
5. 5 Track refund status via ACE portal; Phase II launch date TBD

8 USMCA Review — July 1, 2026

USMCA-compliant goods from Canada and Mexico receive preferential duty treatment. Rules of origin require minimum 70%–75% regional value content (RVC). The joint USMCA review is scheduled for July 1, 2026 — the first formal review since the agreement entered force in 2020.

What Importers Should Do Before July 1, 2026

1. 1 Audit current sourcing — identify which imports from Canada and Mexico qualify for USMCA
2. 2 Update supplier documentation — ensure certificates of origin are current and accurately reflect RVC
3. 3 Calculate RVC for affected products — minimum 70%–75% regional value content required
4. 4 Review supply chain routing — ensure goods aren't transshipped through non-USMCA countries

9 Section 301 Remedy Determinations — July 24, 2026

July 24, 2026 is the statutory deadline for the Trump administration to announce Section 301 remedy determinations for investigations covering 16+ economies. This is the most consequential tariff date of 2026.

Action Items Before July 24

1. 1 Classify all products — ensure HTS codes are accurate for all imported goods
2. 2 Check current tariff exposure — identify which economies and products are under active investigation
3. 3 Identify product substitutions — assess lower-tariff origin alternatives for high-risk SKUs
4. 4 Pre-position inventory — consider 60–90 day safety stock for products likely to face new tariffs
5. 5 Review supplier contracts — add tariff pass-through provisions before determinations are announced

10 Forced Labor Enforcement — 60+ Economies

US CBP continues to enforce Withhold Release Orders (WROs) and findings under the Uyghur Forced Labor Prevention Act (UFLPA). The UFLPA creates a rebuttable presumption that goods produced wholly or in part in Xinjiang are made with forced labor.

Major enforcement categories include electronics, solar panels, textiles, polysilicon, and agricultural products. Importers must maintain complete supply chain documentation and be prepared to demonstrate UFLPA compliance at the port of entry.

11 Total Landed Cost Examples — Tariff Stacking

These examples illustrate the full tariff stack and total landed cost for common import scenarios. All examples assume $100 FOB value.

12 HTS Code Classification

Every tariff analysis starts with correct HTS classification. Misclassification is the leading cause of CBP penalty cases — resulting in either underpayment (penalties, interest, retroactive assessment) or overpayment (unnecessary cost).

How to Find Your HTS Code

1. 1 Use the USTradeStack HTS Classifier — free AI-powered classification with CBP references
2. 2 Cross-reference with USITC DataWeb (dataweb.usitc.gov)
3. 3 Work with a licensed customs broker for complex multi-component products
4. 4 Request a CBP binding ruling for certainty on high-value products

13 Savings Opportunities by Product Category

Sourcing shifts from China to alternative origins can yield significant duty reductions. These estimates reflect 2026 effective rates and assume comparable product quality and logistics costs.

14 Recommendations for US Importers — Action Plan 2026

Immediate Actions (Now)

1. 1 Audit all active import lines for Section 301 and Section 232 exposure
2. 2 Check HTS codes — are all products correctly classified?
3. 3 Identify USMCA-compliant sourcing from Canada and Mexico for steel, aluminum, and auto parts
4. 4 File IEEPA refund claims via CAPE portal for Section 122 overpayments

By July 1, 2026 (USMCA Review)

1. 5 Obtain USMCA certificates of origin from all Canadian and Mexican suppliers
2. 6 Calculate regional value content (RVC) for all products claiming USMCA preference
3. 7 Audit supply chain routing for USMCA eligibility

By July 24, 2026 (Section 301 Determinations)

1. 8 Identify at-risk product categories under active Section 301 investigation
2. 9 Pre-position inventory — consider 60–90 day safety stock for high-risk SKUs
3. 10 Review supplier contracts for tariff pass-through provisions

Ongoing

1. 11 Monitor tariff negotiations — rates for EU, Japan, India, Vietnam are in active flux
2. 12 Track IEEPA refund window — Phase II CAPE launch date TBD
3. 13 Review forced labor compliance for all Xinjiang-adjacent supply chains

A Appendix A: Key Dates 2026

B Appendix B: Key Resources