Section 301 tariffs 2026 are not a policy discussion. They are a financial event with a hard date attached, and that date is July 24, 2026. On that day, the 10% global tariff currently running under Section 122 expires. The Trump administration has already launched the legal machinery to replace it with Section 301 tariffs across 76 countries, covering virtually every major manufacturing economy on earth. Unlike IEEPA, which the Supreme Court struck down, Section 301 tariffs carry no expiry date, no rate cap, and a legal track record that has survived more than 4,000 court challenges. If you import goods into the United States from China, India, Vietnam, Mexico, the EU, or most of Asia, the tariff structure you are operating under today will not be the one you are operating under in four months. This is what is happening, what it costs, and what you need to do before the window closes.
Why July 24, 2026 Is the Deadline Every Importer Needs to Understand
Most importers are still processing the February 20 Supreme Court ruling that struck down IEEPA tariffs. But the administration was not waiting. Within hours of that ruling, President Trump signed an executive order imposing a 10% global tariff under Section 122 of the Trade Act of 1974. Section 122 has two hard limits written into law: the rate cannot exceed 15%, and it cannot last more than 150 days. That 150-day clock started on February 24, 2026.
Do the arithmetic and you land on July 24, 2026. That is the date Section 122 expires. That is also the date USTR is targeting to have its Section 301 findings ready and new tariffs in place. The administration has been explicit: Section 122 is a bridge, not a destination. US Treasury Secretary Scott Bessent has publicly stated that tariff rates will return to their pre-SCOTUS levels within five months. Section 301 is how they get there.
For importers, this creates a 116-day window to assess exposure, restructure contracts, file IEEPA refund claims, and get their compliance architecture in order. Once Section 301 tariffs land, they do not expire. They can run for years. The businesses that treat this as a temporary disruption and wait it out are the ones that will be repricing contracts and absorbing duty increases in August.
Section 301 vs IEEPA vs Section 122: What Every Importer Needs to Know About the Switch
To understand why Section 301 tariffs 2026 are structurally different from what came before, you need to understand the three legal tools the administration has used in sequence.
IEEPA (struck down February 20, 2026): The Supreme Court ruled 6-3 that IEEPA does not give the president authority to impose tariffs. All IEEPA duties were immediately void. CBP is now processing refunds.
Section 122 (current, expires July 24, 2026): A temporary 10% global flat rate on all imports, capped at 15% and limited to 150 days by law. Cannot be extended by the president alone. Faces active legal challenges from more than 20 US states. Even if it survives legal challenge, it ends on July 24.
Section 301 (incoming, no expiry, no rate cap): Grounded in the Trade Act of 1974. Allows USTR to impose tariffs on specific countries for specific unfair trade practices. Tariff rates can be set at any level USTR recommends. No time limit. No congressional approval required. Has survived every legal challenge since 1974. The original China Section 301 tariffs from 2018 are still in effect today. This is a permanent tool, not a temporary measure.
The shift from Section 122 to Section 301 is not just a legal technicality. It means the tariff burden on your goods could increase significantly, become country-specific rather than universal, and stay in place indefinitely. That changes the economics of every import decision you make.
Which 76 Countries Are Under Section 301 Investigation in 2026
On March 11 and 12, 2026, USTR launched two separate Section 301 investigations that together cover 76 countries and economies. The full details of both investigations are published on the official USTR Section 301 investigations page. Here is exactly what each investigation targets.
Investigation 1: Industrial Overcapacity Across 16 Economies
USTR is investigating these 16 trading partners for producing more manufactured goods than their domestic markets can absorb, which the administration argues displaces US production and depresses global prices. The targeted sectors are electronics, semiconductors, batteries, EV components, steel, aluminium, chemicals, and industrial machinery. The countries under investigation are China, European Union, India, Japan, South Korea, Vietnam, Taiwan, Mexico, Indonesia, Malaysia, Cambodia, Thailand, Bangladesh, Singapore, Switzerland, and Norway.
If you source electronics, IT hardware, industrial equipment, or metal components from any of these countries, this investigation directly targets your supply base.
Investigation 2: Forced Labour Import Enforcement Across 60 Economies
The second investigation is broader and blunter. USTR is examining whether 60 countries have failed to ban imports of goods made with forced labour. The 60 countries represent 99% of all goods imported into the United States by value. China, the EU, India, Mexico, the UK, Japan, South Korea, Brazil, Vietnam, and most major exporting economies are all included.
An affirmative finding in either investigation gives the president authority to impose tariffs, import restrictions, or fees on services. There is no statutory cap on the rate. There is no automatic sunset date. If USTR finds against a country, tariffs can be set at whatever level the administration determines is proportionate to the harm caused to US commerce.
What Section 301 Tariffs 2026 Will Actually Cost: Real Numbers Every Importer Should Model Now
The current Section 122 rate is a flat 10% on all goods from all countries. This is simple to model. Section 301 is not simple. It is country-specific, product-specific, and determined by the findings of each investigation. Historical Section 301 tariff rates give you a realistic range to plan against.
When USTR imposed the original China Section 301 tariffs in 2018, rates ranged from 7.5% to 25% across thousands of product categories. After the 2024 Biden-era review, those rates were significantly increased on strategic sectors: semiconductors moved to 50%, electric vehicles to 100%, solar cells to 50%, permanent magnets to 25%, and medical gloves to 50%. These are not theoretical worst-case numbers. These are rates currently in force on China-origin goods.
To understand what this means in real money, consider a standard IT hardware shipment. A consignment of servers and networking equipment valued at $500,000, imported from Vietnam under the current 10% Section 122 rate, carries a duty bill of $50,000. If Section 301 findings place Vietnamese electronics at 25%, that same shipment costs $125,000 in duties. At 50%, it reaches $250,000. The difference between those scenarios is not a rounding error. It is the difference between a profitable contract and a loss-making one.
Businesses using DDP (Delivered Duty Paid) terms need to pay particular attention here. Under DDP, the party responsible for delivery takes on all duties and taxes at the destination. If your DDP contracts were priced against the current 10% Section 122 rate and Section 301 lands at 25% or above, the duty burden increase falls directly on whoever accepted DDP responsibility. Review every active DDP contract before July 24. Our Trade Compliance team can run a full duty exposure analysis across your active trade corridors.
The Section 301 Exclusion Process: The Tool Most Importers Are Not Using
Here is something that almost nobody covering the 2026 tariff situation is explaining clearly: you can apply for exclusions from Section 301 tariffs. The process is not automatic and it is not guaranteed, but it is real, it has worked for thousands of product categories in the past, and the comment window for the current investigations closes April 15, 2026.
During the original China Section 301 proceedings, USTR accepted public comments from importers, manufacturers, and industry associations explaining why specific product categories should be excluded from tariffs. Importers that submitted well-structured comments, backed by evidence that the tariff would cause economic harm without meaningfully affecting the trade practice being targeted, achieved product-specific exclusions that saved them millions in duty costs.
The 2026 investigations are running on an accelerated timeline, but the comment mechanism is the same. If your goods fall within a product category targeted by either investigation, submitting detailed public comments before April 15, 2026 is one of the highest-leverage actions you can take right now. Your comments need to address the specific acts, policies, and practices of the country being investigated and explain with evidence how the tariff would burden US commerce rather than correct it. This is not a process to wing. Get your trade compliance team or legal counsel working on this immediately.
How to Claim Your IEEPA Tariff Refund Before the 180-Day Window Closes
While the Section 301 process unfolds, a separate and equally time-sensitive process is running for IEEPA duty refunds. The Court of International Trade directed CBP to re-liquidate entries affected by IEEPA duties. CBP has published guidance on the refund process and protest filing on the CBP Section 301 Trade Remedies FAQ page. The refund mechanism works differently depending on the status of your entries.
For unliquidated entries, CBP will re-liquidate automatically without IEEPA duties. You do not need to take action. The refund flows through the standard liquidation process once CBP’s automated CAPE system is operational, expected around April 20, 2026.
For already-liquidated entries, the situation is different. You have a 180-day window from the date of liquidation to file a customs protest. That window is running right now on every entry that was liquidated in the months before the February 20 ruling. If the 180 days expire on a specific entry without a protest being filed, that refund opportunity is gone. Check the liquidation dates on every entry that carried IEEPA duties. Your IOR provider or freight forwarder should have the liquidation dates on file. Act on these now, not in summer.
We covered the full background on the SCOTUS ruling in our earlier post on what SCOTUS striking down IEEPA tariffs means for importers.
What Happens to Importers Who Do Nothing Before July 24
This section is not on most tariff guides. It should be.
If you import goods from any of the 76 countries currently under Section 301 investigation and you take no action before July 24, here is what happens. Your shipments continue to move. Customs continues to clear them. But on July 24 or shortly after, the duty rate on your goods changes. CBP applies the new Section 301 rate at the point of import entry. If you have not updated your landed cost calculations, DDP contract pricing, or duty provision budgets, the first shipment cleared after that date produces a duty bill your commercial model was not built to absorb.
Businesses that ship high volumes will feel this immediately. A container of electronics that cost $50,000 in duties last week could cost $125,000 in duties the week after July 24. That delta does not appear in your contracts, your customer pricing, or your margins. It appears as an unplanned cost that falls on whoever is legally responsible for customs entry at the destination. That is your Importer of Record. If your IOR is you, the liability lands on your balance sheet. If your IOR is a third-party provider operating under a contract priced at today’s rates, you need to understand what your contract says about duty rate changes before you find out the hard way.
At Carra Globe, every IOR engagement is structured with full duty transparency. Before we accept IOR responsibility on a shipment, we run a landed cost analysis that accounts for current rates, pending investigations, and likely rate scenarios. That protects both us and you from being caught by a rate change that was entirely predictable.
Six Actions Every Importer Must Take Before the Section 301 Tariff Deadline
1. Map Every Import Corridor Against the Investigation Lists
List every country you source from. Check it against the 16-country overcapacity investigation list and the 60-country forced labour list. Most major manufacturing economies are on at least one list. Countries that appear on both lists, including China, Vietnam, India, Mexico, and the EU, carry the highest tariff risk because two separate investigations could produce two separate tariff actions. Prioritise your high-volume corridors first.
2. Run Three-Scenario Landed Cost Models
For each active import corridor, model three scenarios: Section 122 expires with no replacement (unlikely), Section 301 tariffs land at 15-25%, and Section 301 tariffs land at 25-50% on targeted product categories. The DDP pricing and customer contracts you have in place today were built against scenario one. They need stress-testing against scenarios two and three before July 24, not after.
3. Check Your HS Code Classification Immediately
Section 301 tariffs are applied at the HS code level. The same physical product can carry radically different tariff rates depending on how it is classified. Getting HS codes wrong has always been costly under standard customs rules. Under Section 301, a misclassification in a targeted product category could mean you are paying a 25% tariff when the correct classification attracts 7.5%, or not paying when you should be. Both scenarios create exposure. The customs compliance fundamentals that drive clean entry start with accurate classification. Check every active product code against the categories named in the investigation notices.
4. File for Section 301 Exclusions Before April 15
If your goods fall within a targeted product category, the USTR public comment window closes April 15, 2026. Public hearings begin April 28 for forced labour and May 5 for overcapacity. Submitting well-evidenced comments arguing for product exclusions is a legitimate and historically effective path to reducing Section 301 exposure. This window will not reopen after April 15. Use it.
5. File IEEPA Protest Claims on Liquidated Entries Now
Every entry that was liquidated with IEEPA duties has a 180-day protest window running from its liquidation date. Pull the liquidation dates for every entry that carried IEEPA duties between April 2025 and February 2026. File protests before each entry’s 180-day window expires. CBP’s automated refund system goes live around April 20, 2026. Entries that reach their 180-day anniversary without a protest filed are permanently ineligible for refund. This is not a drill. Check your entry records this week.
6. Review and Renegotiate DDP Contracts Before June
Any DDP contracts currently in force and running past July 24 need reviewing before June. The party accepting DDP responsibility accepted the duty burden at today’s rate. If that rate changes materially after July 24, the contract needs to reflect who absorbs the difference. Silence in a DDP contract on the question of duty rate changes is not neutral. It is a liability. Our Trade Compliance team works through active DDP contracts with clients regularly. The time to do this is now, while Section 301 rates are still unknown and both parties have room to negotiate.
How Carra Globe Supports Importers Through Section 301 Tariff Changes
We have managed import programmes through multiple tariff cycles across 175+ countries. The pattern is always the same. The businesses that come out ahead are the ones that treated tariff change as an operational event to plan for, not a policy story to monitor from a distance. The businesses that struggled are the ones that waited to see what the final rates were before starting to act.
Section 301 tariffs 2026 are moving on a defined timeline with defined decision points. The comment deadline, the hearing dates, the July 24 expiry, the April 20 CAPE launch. Every one of these is a date you can build a plan around. Our full range of services is available to support importers at every stage of that plan:
- Importer of Record (IOR): We act as the legal importer on your US and global shipments, absorbing customs liability and ensuring correct duty application as rates change across 175+ countries.
- Exporter of Record (EOR): We manage export documentation, licensing, and compliance from the origin side of your shipment, including export controls that interact with US trade investigations.
- Delivered Duty Paid (DDP): We price and manage end-to-end delivery with full duty cost visibility, structured to account for pending rate changes before they happen.
- Freight Forwarding: We manage ocean, air, and multimodal freight globally, including route and origin optimisation when tariff changes make existing corridors commercially unviable.
- White Glove Delivery: Specialist handling, installation, and last-mile logistics for high-value goods where duty cost changes have the most impact on total landed cost.
- Global Warehouse Logistics: Bonded warehouse solutions across key trade hubs that let you manage the timing of duty payment as Section 301 rates take effect.
- Global Trade Compliance: HS code classification, duty exposure analysis, DDP contract review, and customs audit support across all active import corridors.
If you are importing goods from any of the 76 countries currently under Section 301 investigation and you do not have a plan for July 24, speak to our team now. The window to get ahead of this is open. It will not stay open.
Frequently Asked Questions About Section 301 Tariffs 2026
What exactly are Section 301 tariffs and why are they harder to challenge than IEEPA?
Section 301 of the Trade Act of 1974 gives USTR the authority to impose tariffs on countries that engage in unfair trade practices. Unlike IEEPA, which the Supreme Court struck down because it was not designed to authorise tariffs, Section 301 is an explicit statutory grant of tariff authority. It has been used by Republican and Democratic administrations for decades. The original China Section 301 tariffs from 2018 have survived more than 4,000 legal challenges and remain in force today. They carry no expiry date, no rate cap, and no congressional approval requirement for initial imposition. They are the most legally durable tariff tool in US trade law.
My goods come from Vietnam, not China. Am I still affected by Section 301 tariffs 2026?
Yes. Vietnam is specifically named in the industrial overcapacity investigation targeting 16 economies. Vietnam’s electronics, garment, footwear, and machinery sectors are all cited in the overcapacity context. If USTR finds against Vietnam, Section 301 tariffs could apply to Vietnamese-origin goods at rates determined by the investigation findings. Many businesses shifted sourcing from China to Vietnam after the original 2018 Section 301 tariffs. The 2026 investigations directly target that shift. Diversifying away from China alone is no longer a sufficient Section 301 risk mitigation strategy.
Can I get my goods excluded from Section 301 tariffs?
Yes, in principle. USTR accepts public comments on its Section 301 investigations, and businesses can submit arguments for product-specific exclusions. The comment window for both current investigations closes April 15, 2026. To have a realistic chance of achieving an exclusion, your submission needs to demonstrate that the tariff would impose costs on US commerce without effectively addressing the underlying unfair trade practice. This process requires specific documentation and a strong factual case. It is not a guarantee, but for businesses with significant exposure in targeted product categories it is worth pursuing. Contact our trade compliance team to discuss whether your products qualify for exclusion arguments.
How do Section 301 tariffs interact with existing China tariffs?
China is already subject to Section 301 tariffs from the 2018 investigations, with rates between 7.5% and 100% depending on the product category. The new 2026 investigation into China targets additional sectors under the overcapacity and forced labour frameworks. If USTR finds actionable practices, it could expand the product coverage of existing Section 301 tariffs on China or impose new tariff layers on top of existing ones. For China-origin goods already carrying Section 301 tariffs, the practical question is whether new investigation findings could result in rate increases on currently covered categories or tariff imposition on currently uncovered ones. Both are possible under the statute.
I am not based in the US. Do Section 301 tariffs affect my business?
Yes, directly. Section 301 tariffs are paid by the US Importer of Record on goods entering the United States. If you are a non-US manufacturer or distributor selling goods into the US market, the duty cost lands on your buyer or on the entity acting as IOR on your shipments. If that entity passes duty costs back to you under the terms of your commercial contract, you absorb them indirectly. If you are acting as your own IOR in the US, you pay them directly. Either way, a significant Section 301 tariff increase on your product category changes the economics of selling into the US market. Understanding your IOR structure and who bears tariff liability under your commercial terms is essential before July 24. Read our guide on how Importer of Record services work to understand your current exposure.
Will Section 301 tariffs definitely replace Section 122 on July 24?
USTR’s stated intention is to complete investigations and be ready to impose tariffs by approximately July 24, 2026. The administration has also signalled that Section 232 investigations into pharmaceuticals, aircraft, semiconductors, and other sectors are running in parallel and could produce additional tariff actions before or alongside the Section 301 findings. The scenario where Section 122 simply expires on July 24 with no replacement is considered unlikely by most trade analysts. The more realistic scenarios are Section 301 tariffs taking effect on or around July 24 at country-specific rates, or Section 232 tariffs covering additional product categories arriving at a similar time. Plan for tariff continuity at potentially higher rates, not for a tariff-free window after July 24.