If keeping up with U.S. customs requirements has become more challenging in recent years, 2026 has taken that complexity to another level. Tariffs have been introduced, modified, and removed, while Section 301, Section 232, de minimis, International Emergency Economic Powers Act (IEEPA) refunds, and new electronic filing requirements continue to reshape the import landscape.
For importers, staying current is essential because tariff treatment can change even when the product, supplier, and Harmonized Tariff Schedule (HTS) classification remain the same.
One of the most significant developments this year involves IEEPA tariffs. Following the Supreme Court’s February 2026 decision that IEEPA did not authorize the tariffs imposed by the administration, collection of those duties stopped. The United States Customs and Border Protection (CBP) subsequently established the Consolidated Administration and Processing of Entries (CAPE) system to process refunds for duties that had already been paid. Importers should review affected entries, liquidation status, protests, amounts paid, and refund activity, while maintaining detailed records of IEEPA-affected entries.
The temporary 10% Section 122 import surcharge also expired on July 24, 2026. Importers should therefore verify effective dates carefully and avoid carrying expired Chapter 99 provisions into current entry calculations.
New Section 301 duties also took effect July 24, 2026, affecting goods from 60 trading partners based on findings concerning forced-labor import prohibitions. The additional duties generally range from 10% to 12.5%, depending on the country and applicable provisions. Determining the correct treatment requires review of the country of origin, HTS classification, Chapter 99 requirements, and applicable exclusions.
Importers should also remember that paying a tariff does not make merchandise automatically admissible. Uyghur Forced Labor Prevention Act (UFLPA) enforcement remains a separate concern, making supply-chain documentation increasingly important. Importers should be able to identify their manufacturers, suppliers, raw materials, components, and countries of origin.
Brazil is another area requiring careful review. Many Brazilian products are subject to a new 25% Section 301 tariff, subject to exemptions and special provisions. Depending on the merchandise, additional Section 301 duties, ADD/CVD, and normal customs duties may also apply. Canadian products are likewise subject to new Section 338 tariff actions, with certain products facing additional duties while others receive different treatment or exclusions. In both cases, the HTS classification and applicable Chapter 99 provisions must be reviewed rather than relying on a country-wide tariff assumption.
Section 232 continues to be a major compliance issue. Steel, aluminum, copper, and derivative products remain subject to evolving requirements, including changes affecting certain industrial equipment and country-specific provisions. The applicable duty depends on the product, HTS classification, derivative status, metal content, Chapter 99 provision, exemptions, and interaction with other tariffs. Simply determining that a product contains steel or aluminum is not enough to establish Section 232 liability.
Consumer Product Safety Commission (CPSC) electronic filing is another significant development. Mandatory CPSC e-filing for covered consumer products began July 8, 2026, through the CBP ACE/PGA process. Applicable information may include product identification, certification, manufacturing and testing information, and recordkeeping details. For qualifying FTZ withdrawals, the requirements are scheduled to expand beginning January 8, 2027.
Looking ahead, importers should also monitor the upcoming Section 232 action involving polysilicon and certain derivative products, expected to take effect December 4, 2026. Sugar importers should prepare for the FY2027 sugar TRQ year beginning October 1, 2026, including the WTO raw cane sugar allocation of 1,117,195 metric tons, raw value.
Beyond individual tariff programs, CBP’s increasing focus on supply-chain transparency is an important trend. Importers should maintain accurate information regarding manufacturers, factories, suppliers, raw materials, components, valuation, transportation, and country of origin. Transshipment, duty evasion, forced labor, valuation, and origin accuracy remain areas of significant customs enforcement attention.
The key takeaway for 2026 is straightforward: yesterday’s tariff treatment cannot be assumed to apply today. A shipment may involve multiple tariff programs, while another shipment of a similar product may receive different treatment based on origin, HTS classification, product composition, exclusions, trade agreements, or effective dates.
For importers, Chapter 99 provisions are now an essential part of entry review alongside the underlying HTS classification. In today’s customs environment, accurate classification is only the starting point; understanding the current tariff programs, effective dates, exclusions, and admissibility requirements is equally important.
In 2026 and beyond, being proactive is an essential part of effective customs compliance.
