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Tariff Updates

Tariff rates, country designations, and trade rules are all subject to change.

3 April 2026

Recent Developments

April 2^nd, 2026: The U.S. made significant updates to Section 232 tariffs for key metals (steel, aluminum, copper, etc.) as well as new tariff measures targeting pharmaceutical imports. More information is provided below.

March 31^st, 2026: CBP provided a status update on the Consolidated Administration & Processing of Entries (CAPE) system, the newly created process for collecting IEEPA refunds. CAPE Phase 1 is still limited in scope and CBP has not clarified how it will interact with existing strategies such as filing protests.

International Emergency Economic Powers Act (IEEPA)

Supreme Court Rejects IEEPA Tariffs

Following a key Supreme Court decision that invalidated tariffs under the International Emergency Economic Powers Act (IEEPA), the Trump Administration implemented a new 10% global tariff under Section 122 of the 1974 Trade Act. This is a new tariff under a different legal authority and is not automatically affected by the Court’s ruling on IEEPA.

Other tariffs under sections 301 and 232 remain unaffected.

In-Transit Provision: U.S. Customs and Border Protection (CBP) provided guidance on its IEEPA webpage concerning the applicability of the in-transit provision. The in-transit provisions for reciprocal tariffs only apply to the vessel mode of transportation and do not apply to other modes of transportation, such as air, rail, truck, etc.

March 4^th, 2026: the U.S. Court of International Trade ordered U.S. Customs and Border Protection (CBP) to liquidate certain unliquidated entries without applying IEEPA duties and to reliquidate entries that are not yet final, potentially paving the way for refunds.

March 6^th, 2026: CBP informed the court it is not yet ready to process refunds but expects it could develop the necessary functionality in the Automated Commercial Environment (ACE) within approximately 45 days. The anticipated process may require importers to identify affected entries, after which ACE would validate them, recalculate duties without IEEPA tariffs, and aggregate potential refunds and interest before payments are issued by the U.S. Treasury.

The refund process and timeline remain uncertain, and additional court proceedings or appeals may affect implementation.

What This Means for Importers

IEEPA tariffs will no longer be collected effective February 24, 12:01 am EST.

U.S. Customs & Border Protection (CBP) has not issued instructions regarding refunds or timelines
Import entries should continue to be filed under current CBP procedures until formal guidance is issued
No immediate action is required from importers at this time
A new 10% universal tariff has been announced and is expected to take effect shortly

IEEPA Tariff Refunds: Support Available for ACH Refund

Although refund procedures have not been announced, importers should ensure their ACH refund accounts are properly configured with CBP. Having ACH refund capability in place will help prevent delays if/when refunds are authorized.

Because the refund process is still uncertain, filing a protest with U.S. Customs & Border Protection (CBP) is the best way to preserve your right to a refund. If you have not yet established or confirmed your ACH refund setup, we strongly recommend doing so as a proactive measure. Filing a protest:

Preserves your refund rights
Protects you if CBP requires protests as part of the refund process
Ensures your claim remains active while litigation continues

Failing to file a protest within 180 days of the liquidation date could jeopardize your ability to recover any paid duties. Learn more about the liquidation process here.

OIA Global can help in several ways:

Review your entry data to identify eligible IEEPA-affected shipments
Track liquidation dates to ensure deadlines are met
Prepare and file protests on your behalf
Submit protests in batches to improve efficiency
Coordinate with your legal counsel (If applicable)

Contact OIA

Section 232 Tariffs

Section 232 Metals

Key Changes (Effective April 6^th, 2026, 12:01 a.m. ET)

Tariffs will now be assessed based on the full value of imported goods—not reduced foreign pricing.

50% tariff: Articles made entirely or almost entirely of steel, aluminum, or copper (e.g., coils, sheets).
25% tariff: Derivative products substantially made of these metals.
15% tariff (through 2027): Certain metal-intensive industrial and electrical grid equipment to support U.S. industrial expansion.
10% tariff: Products manufactured abroad using entirely U.S.-origin metals.

Exemption: Goods containing 15% or less of these metals are no longer subject to Section 232 tariffs.

Pharmaceuticals

100% tariff on patented pharmaceutical products and ingredients under Section 232. Effective in 120 days (large companies) and 180 days (smaller companies).

Reduced tariffs (15%) apply for certain places: EU, Japan, Korea, Switzerland, Liechtenstein, and the United Kingdom (per recent agreement).

0% tariff available through Jan. 20^th, 2029, for companies entering Most Favored Nation (MFN) pricing agreements with the U.S. Department of Health and Human Services, and onshoring agreements with the Department of Commerce. 20% tariff applies if only onshoring agreements are executed.

De Minimus Exemption for Low-Value Parcels

July 30^th 2025, Executive Order: The U.S. suspended the duty-free de minimis classification for all countries, which applied to parcels valued <$800. The order took effect on August 29^th, 2025.

Any goods shipped through the international postal network will be subject to tariff rates based on the value of the package and its country of origin.

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Executive Orders & Regulations

On Feb. 3^rd, 2026, the U.S. and India signed a trade deal, reducing India’s tariff rate from 25% to 18%.

On October 30^th, the U.S. agreed to delay the imposition of higher tariffs against China for another year. As part of a consensus agreement, the U.S. lowered tariffs on imports from China to 10%, down from 20%. A variety of Section 301 and Section 232 tariffs remain in place, and goods from China will still face a duty burden of roughly 47%, according to U.S. Trade Representative Jamieson Greer.

As of August 7^th, 2025, the U.S. has enacted sweeping reciprocal tariffs on imports from 60+ countries, with duties ranging from 10% to over 100%, depending on origin and sector. Additions like sector-specific penalties and anti-transshipment provisions further complicate the trade landscape. The impact on landed costs, sourcing strategies, and compliance protocols will be significant.

Mexico got a reprieve and its current rates were extended for another 90 days.
The EU delayed its countermeasures by 6 months.
In an Executive Order, the U.S. imposed an additional 25% tariff on Indian products, effective on August 27, 2025.
The U.S. will apply a 50% tariff to most Brazilian goods, as part of the Executive Order: Addressing Threats to the United States by the Government of Brazil.

Summary of Effective Dates

Feb. 24, 2025—The U.S. implements a new 15% global tariff under Section 122 of the 1972 Trade Act. The tariffs can last for up to 150 days, and goods from Mexico/Canada are excluded due to previous trade agreements.

Feb. 24, 2025—IEEPA tariffs will no longer be collected as of 12:01am EST.

Nov. 1, 2025—U.S. imposes a 25% import tax on all medium- and heavy-duty trucks and a 10% levy on buses.

Oct. 14, 2025—10% tariffs on imports of softwood timber and lumber, as well as 25% levies on kitchen cabinets, vanities, and upholstered wood products.

Oct. 1, 2025—U.S. implements a 100% tariff on branded and patented pharmaceuticals entering the U.S.

Sept. 8, 2025—The U.S. set a baseline 15% ad valorem duty on nearly all imported products from Japan, which applies retroactively to goods entered for consumption or withdrawn from a warehouse for consumption on or after 12:01 a.m. EST on August 7th, 2025.

Sept. 5, 2025—President Trump modified the scope of the reciprocal tariffs, adding and removing some goods from the Annex II list.

Aug. 27, 2025—The de minimis exemption for low-value parcels is officially void. The rule allowed goods valued at $800 or less to enter the U.S. duty-free and with minimal customs oversight. Learn more here.

Aug. 27, 2025—U.S. imposes an additional 25% tariff on products imported from India.

Aug. 18, 2025—400+ new products are now subject to Section 232 steel and aluminum tariffs, impacting both raw materials and derivatives.

Aug. 11, 2025—USA and China agree to delay extra tariffs for 90 days, until November 10.

Aug. 7, 2025—U.S. imposes reciprocal tariffs on 50+ countries that did not reach a new trade deal before the Aug. 1 deadline.

Aug. 6, 2025—U.S. will apply a 50% tariff to most Brazilian goods.

Aug. 6, 2025—U.S. increases tariff on Indian products 25%; set to take effect Aug. 27.

July 30, 2025—U.S. suspends the duty-free de minimis classification for all countries.

July 30, 2025—All imports of semi-finished copper products and intensive copper derivative products will be subject to a 50% tariff, effective at 12:01 a.m. EST on Aug. 1.

July 27, 2025—The U.S. and European Union (EU) agree to a new trade deal.

July 22, 2025—U.S. reaches trade deals with Japan, Indonesia, and the Philippines.

May 12, 2025—China/USA agree to cut tariffs.

90 Day Suspension of Ad Valorem Duties on China.
Suspension of Country-Specific Ad Valorem Rate of Duty.
De Minimus tariff reduced from 120% to 54%

May 3, 2025—Auto parts (25% tariff under Section 232)

April 3, 2025—Autos (25% tariff under Section 232)

March 12, 2025—SEC 232 (Steel/Aluminum) tariff expansion

March 4, 2025—IEEPA raised to 20%

Feb. 4, 2025—IEEPA 10% tariff

Trade negotiations are evolving quickly! All parties in the supply chain industry should recognize that these widely impactful laws will change regularly and significantly. OIA Global publishes advisories, including updates about the latest tariff developments. We encourage you to bookmark some of these helpful resources for future reference.

Key Resources

Frequently Asked Questions (FAQ)

1. Do I need to act now?

Yes. Many of these tariffs are already in effect. If you import goods into the U.S., your costs and documentation requirements may have changed.

2. Can I change suppliers to avoid tariffs?

In many cases, yes. OIA can help you explore sourcing options in lower-tariff countries or regions.

3. Are there ways to recover or reduce tariffs?

Some mitigation strategies may be available, but certain tariffs—especially under IEEPA—do not allow duty refunds. Based on your products and trade lanes, we’ll help you determine what’s possible.

4. Will this affect my delivery times?

Possibly. While transportation timelines are stable, customs clearance may take longer due to more complex entry requirements and reviews.

5. Will these tariffs change again?

Yes. This is an ongoing situation. Rates and rules are subject to change with little notice.

6. Where can I get more information?

Visit https://www.oiaglobal.com/news/advisories for the latest updates. Or, contact your OIA Global representative to navigate the situation together.

How This Affects You

Cost Implications: Tariffs may significantly raise the total landed cost of your products, affecting margin and pricing models.

Supply Chain Shifts: You may need to reconsider where you source products or materials to avoid excessive tariffs.

Customs Complexity: Additional documentation, declarations, and compliance steps may be required for entry processing.

How OIA Can Help

Alternative Sourcing: Tap into our global network to explore supplier options in low- or no-tariff countries.

Compliance Support: OIA’s customs specialists can assist with classification reviews, eligibility for exclusions, and regulatory compliance.

Strategic Planning: We’ll work with you on proactive strategies to mitigate current and future tariffs’ financial and operational impact.

Consultations: We’ll help you evaluate the impact of tariffs across your supply chain and identify risk areas.

More information