Tariff Reset: Section 122 Expires as Section 301 Duties Expand to 60+ U.S. Trading Partners6 Min Read

What businesses should know as of July 24, 2026

The tariff landscape has shifted substantially, seemingly overnight. The expiration of the broad Section 122 surcharge may reduce costs for some imports, but new actions under Sections 301 and 338 create additional exposure based on country of origin and product classification. Businesses may have opportunities to recover eligible duties previously paid under the International Emergency Economic Powers Act (IEEPA), but refund paths look different depending on your situation.

Companies need to understand which authorities apply to each product, whether tariffs can “stack”, and how quickly those costs could affect margins, contracts, and purchasing decisions.

Starting from the most recent developments:

The Section 122 surcharge has expired

The temporary Section 122 surcharge imposed a 10% additional duty on most imports beginning February 24, 2026. With no further action by Congress, it has expired as of July 24.

Its expiration removes one broad layer of tariffs, but companies should avoid automatically reducing their landed-cost assumptions by 10%. New Section 301 tariffs take effect on the same date and may replace some or all of that reduction depending on the country, product and available exemptions.

60+ major trading partners are now subject to tariffs under Section 301

Effective July 24, USTR is imposing new Section 301 tariffs on 60 economies following investigations into their treatment of goods produced with forced labor. The covered trading partners represent 99.4% of U.S. imports.

Some imports are subject to a 10% tariff, while imports from many other economies face an additional 12.5%. Special formulas apply to products from the European Union and Taiwan, where the combined most-favored-nation and Section 301 rate is generally capped at 10%. Product exemptions and separate treatment for goods already subject to Section 232 tariffs add another layer of complexity.

Importers should identify their affected countries and Harmonized Tariff Schedule classifications before estimating the financial impact.

Brazil faces a separate 25% tariff action

A separate Section 301 action imposes an additional 25% tariff on many imports from Brazil entered on or after July 22 and not withdrawn from a warehouse for consumption by July 29. Combined with the additional 12.5%, the two Section 301 tariffs add up to a total tariff barrier of 37.5%.

The actions followed a USTR investigation involving digital trade, electronic payment services, preferential tariffs, intellectual property protections, ethanol market access, and other Brazilian policies.

The tariff applies broadly, but important exemptions include certain beef, orange juice, aircraft and aircraft parts, energy products, and other designated materials. Because Brazil is also included in the new 60-economy Section 301 action and is also subject to Section 232, companies sourcing from Brazil should review how the collection and their separate exemption lists interact.

Section 338 opens a new front for Canadian imports

The administration has also invoked Section 338 of the Tariff Act of 1930 to impose an additional 50% tariff on specified Canadian goods beginning August 19.

The three actions respond to Canadian policies involving U.S. motor vehicles, alcoholic beverages, and dairy products, but the product lists extend to other covered Canadian imports, including products ranging from wine and hockey sticks to cement. The duties generally apply regardless of whether the goods qualify as originating under the United States-Mexico-Canada Agreement. Energy, potash, goods subject to Section 232 tariffs, and certain other products are excluded.

With the August 19 effective date approaching, businesses should evaluate open purchase orders, goods currently in transit and supplier contracts that assign responsibility for tariff increases.

IEEPA refunds continue to move

Most refunds are expected to be issued within 60 to 90 days after a CAPE declaration is accepted, although claims requiring additional compliance review may take longer.

Importers should identify potentially eligible entries, confirm their electronic refund information, resolve submission errors and monitor claims through the ACE Portal. Refunds should be treated as an active recovery opportunity rather than something businesses can assume will arrive automatically.

Get the latest tariff developments on August 5

The expiration of Section 122, expansion of Section 301, new Brazil and Canada actions, and developing refund procedures can produce very different results depending on a company’s products and supply chain.

Join UHY on August 5 for a focused tariff update covering the rules currently in effect, the changes taking place next and the practical steps businesses should consider now.

Register for the August 5 tariff webinar.