The US Tariff Changed Names Twice in 2026. Here Is What Importers Pay Now

From IEEPA to Section 122 to a forced-labor tariff under Section 301, and why a cost sheet built in January is now wrong in both directions.

If you import into the United States, the line on your entry that carries the extra tariff has had three different legal bases in a single year. Each change moved some products up and others down. Here is the sequence, what applies today, and how to check your own goods.

February: the Supreme Court ends the IEEPA tariffs

The reciprocal and fentanyl tariffs imposed in 2025 under the International Emergency Economic Powers Act were struck down by the Supreme Court on 20 February 2026. Collection stopped, and the duties already paid became refundable. US Customs is paying roughly $166 billion back through a tool called CAPE, in phases that depend on when each entry liquidated.

February to July: Section 122's 150 days

Four days later a flat 10% surcharge took their place under Section 122 of the Trade Act of 1974. Section 122 allows a temporary surcharge for at most 150 days, and this one ran from 24 February to 24 July 2026.

Since 24 July: the forced-labor tariff

When Section 122 expired, a new tariff under Section 301 took over, framed around forced labor in supply chains. It is not one rate:

• 12.5% on top of the regular duty for 38 economies, including China, Vietnam, Thailand, the Philippines and Türkiye.
• 10% on top of the regular duty for 17 economies, including India, Sri Lanka, Bangladesh, Malaysia and the United Kingdom. Goods from Canada and Mexico that qualify under USMCA are exempt; non-qualifying goods pay 10%.
• A floor that includes the regular duty: 10% for the EU and Taiwan, 12.5% for Japan, South Korea and Switzerland.
• Nothing for economies outside the 60 on the list.

About 860 tariff lines are exempt for every origin, among them computers and phones, semiconductors, energy products, many critical minerals and coffee. Goods that pay a Section 232 duty, such as steel and aluminum, do not pay the forced-labor tariff as well. The exceptions are drones since September and, from 4 December, solar cells and modules, where the two stack.

What it means in numbers

Take cotton T-shirts (HTS 6109.10), with a regular duty of 16.5%. From China they now pay 36.5%: the regular duty, 7.5% under China's existing Section 301 lists and the 12.5% forced-labor tariff. From Vietnam, 29%. From India, Sri Lanka or Bangladesh, 26.5%. From Italy or Portugal, 16.5%, because the regular duty already meets the EU's 10% floor.

A laptop from China, by contrast, pays no US duty at all: computers are on the exemption list, and the Section 301 duty on them is suspended.

What did not change

• China's original Section 301 lists still apply, at 7.5% to 100% depending on the product.
• Section 232 duties on steel and aluminum remain 50% for most origins.
• The $800 de minimis exemption is still suspended for every country, so every parcel pays duty.

What to do now

1. Re-price by tariff line and country of origin. The same product can be exempt from one origin and pay 12.5% from another.
2. Check the exemption list for your HTS codes before assuming the tariff applies.
3. If you paid IEEPA tariffs in 2025 or early 2026, find out which refund route your entries fall under.
4. Watch the dated changes ahead, starting with the solar tariff on 4 December.

You can check any HTS code and origin for free on Zentria Flow's forced-labor tariff checker: zentriaflow.com/forced-labor-tariff.