If you've lost track of which tariffs actually apply to your imports, you're not alone. The last six months have seen an unprecedented amount of whiplash: the Supreme Court struck down the IEEPA tariffs in February, a temporary 10% global tariff came and went, and a new tariff regime took effect in late July. Here's where things actually stand in August 2026.
The timeline, briefly
- February 20, 2026 — The Supreme Court ruled that IEEPA does not authorize tariffs. All IEEPA-based tariffs terminated February 24, and CBP has been processing refunds on duties collected under them.
- February 24 – July 24, 2026 — A temporary 10% global tariff under Section 122 of the Trade Act filled the gap. Section 122 carries a hard 150-day statutory limit, so it expired on July 24. (Litigation over it is ongoing, but as of today it is not being collected.)
- July 24, 2026 onward — New Section 301 forced-labor tariffs took effect at 10% or 12.5%, covering roughly 60 trading partners — about 99.4% of U.S. import value.
What's actually on your invoice right now
1. Section 301 forced-labor tariffs: 10% / 12.5%
This is the new baseline for most imports. Two important carve-outs: goods that qualify under USMCA or CAFTA-DR are exempt, and merchandise already subject to Section 232 duties is capped at the MFN rate. If you import from Mexico, Canada, or Central America and you're not claiming preference, you may be paying 10% you don't owe — qualification is a paperwork exercise that pays for itself immediately.
2. Section 301 China tariffs: still 25% on most goods
The legacy China tariffs never went anywhere, and they stack on top of the new forced-labor tariff. For a typical China-origin product that means base duty + 25% + 10%. The current exclusions have been extended through November 10, 2026 — if your product has an active exclusion, make sure your broker is actually claiming it.
3. Section 232 steel and aluminum: unchanged
25% on steel, 10%+ on aluminum, applied globally with country-specific exclusions. None of this year's changes touched it.
4. De minimis is still suspended
The $800 duty-free threshold remains suspended for all countries under the February 20 executive order. Every shipment, regardless of value, requires formal customs procedures. If you're an e-commerce importer who built a model around Section 321 parcels, that model still doesn't work — and the businesses that adapted fastest consolidated parcels into formal entries months ago.
5. ADD/CVD: the quiet killer
Antidumping and countervailing duty orders — over 700 of them, at rates from 30% to over 400% — stack on top of everything above. This is where new importers get hurt worst, because ADD/CVD exposure isn't obvious from the tariff schedule. Check every new supplier and product against CBP's ADD/CVD database before you place the order.
The bottom line
For most importers, the math today is: base MFN duty + forced-labor 10%/12.5% + (China: legacy 25%) + (232 or ADD/CVD where applicable). The two biggest savings opportunities right now are claiming USMCA/CAFTA-DR preference where you qualify, and filing for refunds on IEEPA-era duties if you haven't yet.
What to do this week
- Pull your import history since February and confirm IEEPA refunds are being processed on eligible entries.
- If you source from USMCA/CAFTA-DR countries, verify preference qualification instead of paying the 10%.
- Check active Section 301 China exclusions against your HTS codes before the November 10 deadline.
- Screen any new supplier for ADD/CVD exposure before committing.
Importing? We can help.
Guy Lichtenstein CHB Corp is a licensed U.S. customs broker (filer code 9UA) clearing shipments at every U.S. port — same-day filing, ISF included with ocean entries.
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