Five Things Business Owners Can Do after Latest Tariff Updates

After the U.S. Supreme Court struck down IEEPA and reciprocal tariffs, the existing tariffs were replaced almost immediately with Section 122 duties, applying a uniform 10% rate globally from February 24 through July 24, 2026.

The administration has indicated it desires a 15% rate, though that has not yet been confirmed.

Section 232 and Section 301 tariffs were not affected by the ruling and remain in place, creating overlapping layers of duties under different authorities.

For business owners, the question is how to respond to this development in a way that protects margins, preserves flexibility, and avoids costly mistakes. Here are five practical steps you can take now.

A realistic tariff action plan

1. Audit tariff exposure and recover overpayments

Conduct a comprehensive review of all 2025 imports at the HTS-code level to identify tariff exposure and refund opportunities. This includes:

• Organizing all 2025 entry summaries and payment records and pursuing Post-Summary Corrections or Protests where eligible, especially for IEEPA-related tariffs.
• Monitoring liquidation dates for all 2025 customs entries. Liquidation typically occurs 314 days after entry, but in some cases it can be earlier. Protests can only be filed up to 180 days after the liquidation date.

2. Optimize product classification, valuation, and design to reduce duty liability

Legally restructure how products are classified, valued or finished. This includes HTS reclassification (tariff engineering) importing products unassembled where feasible and applying First Sale valuation when purchasing through intermediaries.

3. Leverage trade programs and duty-reduction mechanisms

Use U.S. Customs programs that defer, reduce or eliminate tariffs, including Foreign Trade Zones, bonded warehouses, preferential trade agreements, or exclusions and duty drawback (Section 122 tariffs are eligible for duty drawback, whereas IEEPA tariffs were not).

4. Rebuild landed cost models and pricing strategy

Recalculate landed costs using updated tariff rates and stress-test margins under multiple scenarios (10%, 15%, 25%). Implement flexible pricing responses, such as temporary tariff surcharges or adjusted product mix (shift sales towards lower-cost/lower-tariff products), instead of permanent price increases. Consider updating sales contracts to include “Tariff Escalation” clauses, allowing for price adjustments within 30 days of a government policy change.

5. Strengthen sourcing strategy and compliance infrastructure

Evaluate alternative sourcing or production options (nearshoring, dual sourcing, partial assembly) while ensuring origin documentation is airtight, update internal SOPs for customs entry, valuation and recordkeeping, and train procurement and logistics teams on new tariff rules to withstand increased customs scrutiny in a volatile tariff environment.

Section 122 grants the President temporary authority to impose tariffs to address trade imbalances, limited to 150 days unless extended by Congress. This window may be extended or used to further leverage other authorities, including Sections 232 and 301.

It is more critical than ever to know your options and remain flexible.

Take control of your tariff exposure

If we’ve seen anything it is that the tariff landscape can change in an instant. Understand your exposure and your mitigation options. Factor tariff volatility into your planning as a business risk.

If you are unsure how Section 122 or other tariffs affect your business, our tariff specialists can help you take the next step.

Assess My Tariff Mitigation Options