The U.S. tariff landscape has changed significantly over the past year. For importers, manufacturers, and businesses involved in global trade, staying informed about these changes is more important than ever.
In February 2026, the U.S. Supreme Court struck down the use of the International Emergency Economic Powers Act (IEEPA) as a legal basis for broad tariffs. While this marked a major shift in trade policy, it did not eliminate the government’s ability to impose tariffs. Instead, attention has shifted to several other trade laws that continue to shape U.S. import regulations.
Understanding which tariff authorities remain in effect and how they differ can help businesses make informed decisions, prepare for future changes, and maintain compliance.
Why the End of IEEPA Matters
For much of 2025, IEEPA served as the legal foundation for broad tariffs imposed on imports from numerous trading partners. It became one of the most significant trade compliance issues for importers, affecting sourcing decisions, landed costs, and supply chain planning.
On February 20, 2026, the Supreme Court ruled that the administration’s use of IEEPA to impose tariffs exceeded presidential authority. As a result, U.S. Customs and Border Protection stopped collecting IEEPA tariffs shortly after the ruling.
While this removed one major tariff authority, it did not end tariff activity. Instead, businesses must now navigate several other legal authorities that remain active or are currently under review.
Section 122: A Temporary Measure with an Uncertain Future
Immediately following the Supreme Court’s decision, the administration implemented a temporary 10 percent tariff on most imports under Section 122 of the Trade Act of 1974.
Unlike IEEPA, Section 122 is much more limited.
Key characteristics include:
- Tariffs are capped at 15 percent.
- They may only remain in effect for 150 days unless Congress approves an extension.
- The authority is intended to address large and serious balance of payments issues.
The temporary Section 122 tariffs became effective on February 24, 2026, and are currently scheduled to expire on July 24, 2026, unless extended or modified.
However, Section 122 is also facing ongoing legal challenges. Multiple lawsuits argue that the administration exceeded its authority by using Section 122 to impose broad tariffs. While the litigation continues, the tariffs remain in effect following a stay issued by the U.S. Court of Appeals.
For importers, this means continued uncertainty. Businesses should closely monitor developments as both the legal proceedings and the statutory expiration date could affect future duty obligations.
Section 301 Continues to Expand
While some tariff authorities have faced legal challenges, Section 301 of the Trade Act of 1974 remains one of the most established and durable tools available to the U.S. government.
Section 301 allows the Office of the U.S. Trade Representative to investigate and respond to unfair foreign trade practices, including:
- Intellectual property violations
- Forced technology transfer
- Unfair market access restrictions
- Other discriminatory trade practices
Unlike IEEPA, Section 301 follows a structured investigation process that includes opportunities for public comments and hearings before tariffs are implemented.
Today, Section 301 investigations continue across numerous countries and industries, making this authority an ongoing compliance consideration for importers.
Businesses with international supply chains should expect Section 301 to remain an important part of the U.S. trade landscape for the foreseeable future.
Section 232 Remains a Major Consideration
Another significant tariff authority is Section 232 of the Trade Expansion Act of 1962.
Rather than focusing on specific countries, Section 232 addresses imports that may threaten U.S. national security.
Current Section 232 tariffs affect products such as:
- Steel
- Aluminum
- Copper
In recent years, the scope of Section 232 has expanded to include many downstream products containing these materials, including industrial equipment, machinery, automotive components, and other manufactured goods.
For many importers, compliance with Section 232 involves more than simply paying additional duties.
Businesses must carefully determine:
- Product composition
- Applicable tariff classifications
- Country of origin
- Product exclusions, if available
Because Section 232 continues to evolve, companies importing products that contain steel, aluminum, or copper should regularly review whether their products fall within the latest tariff requirements.
Could Section 338 Be Used?
Although it has never been used, another trade authority has attracted increased attention.
Section 338 of the Tariff Act of 1930 allows the president to impose tariffs of up to 50 percent on countries that discriminate against U.S. commerce.
While Section 338 has remained dormant for decades, trade professionals are watching it more closely because recent administrations have demonstrated a willingness to explore a wide range of available tariff authorities.
At this point, Section 338 remains theoretical rather than active, but businesses should remain aware of its existence as part of the broader trade policy landscape.
Why Tariff Authority Matters
Many importers focus primarily on tariff rates, but understanding the legal authority behind a tariff is equally important.
The legal authority determines:
- How tariffs are implemented
- Whether public comments are permitted
- The likelihood of legal challenges
- How long tariffs may remain in effect
- Whether future modifications are likely
Knowing the source of a tariff helps businesses better evaluate long-term risk and prepare for potential changes.
What This Means for Importers
The current tariff environment is more fragmented than it has been in years.
Instead of one broad tariff authority, businesses must now monitor several different legal frameworks simultaneously.
This creates additional complexity for companies that import products from multiple countries or source from diverse global suppliers.
Importers should consider:
- Reviewing current sourcing strategies
- Monitoring active trade investigations
- Evaluating tariff exposure across product lines
- Staying informed about regulatory updates
- Working closely with customs professionals
Proactive planning can help reduce unexpected costs and minimize supply chain disruptions.
The Importance of Strong Customs Compliance
As tariff rules become more complex, customs compliance becomes even more critical.
Accurate documentation, product classification, customs valuation, and country of origin reporting all play an important role in ensuring compliance with current tariff requirements.
Errors can result in:
- Additional duties
- Customs delays
- Penalties
- Increased audits
- Supply chain disruptions
Businesses that maintain organized import records and regularly review their compliance procedures are generally better positioned to respond as regulations evolve.
Staying Prepared for Future Changes
Trade policy continues to evolve quickly, and additional investigations under Sections 301 and 232 may lead to new tariff actions in the coming months.
Because many of these authorities involve formal investigation processes, businesses often have opportunities to monitor developments before new tariffs take effect.
Remaining informed allows importers to make strategic decisions about purchasing, inventory planning, and sourcing before regulatory changes impact costs.
Final Thoughts
The end of IEEPA tariffs marked an important turning point in U.S. trade policy, but it did not eliminate tariff uncertainty. Instead, businesses must now navigate a landscape shaped by multiple legal authorities, each with its own rules, procedures, and compliance obligations.
Understanding the differences between Section 122, Section 301, Section 232, and other potential tariff authorities can help businesses better manage risk and make more informed importing decisions.
As trade regulations continue to change, staying proactive is essential for maintaining an efficient and compliant supply chain. Although “uncertainty” has become a word used all too often in our industry, there is some certainty on the horizon. On July 24th, there WILL be CHANGE. As the Section 122 tariffs expire, there will certainly be CHANGE.
Krenz & Hannan International Can Help
Navigating today’s tariff environment requires more than simply tracking duty rates. It requires understanding how changing regulations affect your imports, your compliance obligations, and your overall supply chain strategy.
At Krenz & Hannan International, our experienced team helps importers stay informed about evolving trade policies, customs regulations, tariff changes, and import compliance requirements. Whether you need assistance with customs clearance, product classification, tariff planning, or import documentation, we are here to help.
If you have questions about how recent tariff developments may affect your business, contact Krenz & Hannan International today. We are committed to helping you navigate today’s changing trade environment with confidence.