Trump Ends IEEPA Tariffs, Imposes New Trade Act Tariffs
Summary
President Trump ended tariffs imposed under IEEPA and initiated new tariffs under Section 122 of the Trade Act of 1974, set at 15% and lasting 150 days. The USTR also announced new Section 301 investigations targeting major trading partners. These changes took effect February 20, 2026.
What changed
Following a Supreme Court ruling invalidating the use of the International Emergency Economic Powers Act (IEEPA) for tariff imposition, President Trump issued an Executive Order on February 20, 2026, terminating all IEEPA-based tariffs. Concurrently, a proclamation invoked authority under Section 122 of the Trade Act of 1974 to impose new tariffs, initially at 10% and increased to 15%, aimed at correcting the U.S. balance-of-payments deficit. These new tariffs apply broadly to imports, with specific exclusions for goods under Section 232, USMCA-compliant Canadian and Mexican goods, certain CAFTA-DR textiles, and critical U.S. economic inputs. The new Section 122 tariffs are scheduled to take effect on February 24, 2026, and will remain in place for 150 days.
In parallel, the U.S. Trade Representative announced new investigations under Section 301 of the Trade Act of 1974, targeting major trading partners on issues such as pharmaceutical pricing, industrial overcapacity, forced labor, and discrimination against U.S. technology companies. Customs and Border Protection is reviewing the collection of previously imposed IEEPA tariffs and will provide guidance to importers. Regulated entities, particularly importers and exporters, should review the specific exclusions and the new tariff rates to assess their impact on supply chains and costs. The effective date for the new Section 122 tariffs is February 24, 2026, with a duration of 150 days, requiring immediate attention to compliance and potential adjustments to import strategies.
What to do next
- Review the list of exclusions for the new Section 122 tariffs to determine applicability.
- Assess the impact of the 15% tariff on imported goods and adjust pricing or sourcing strategies as needed.
- Monitor USTR announcements regarding new Section 301 investigations for potential future trade actions.
Source document (simplified)
March 2, 2026
Trump Tariff Tracker – New Tariff Update -February 23, 2026
Matthew West Baker Botts L.L.P. + Follow Contact LinkedIn Facebook X Send Embed
In response to the Supreme Court invalidating the use of IEEPA to impose tariffs, President Trump issued an Executive Order on February 20, ending the IEEPA based tariffs imposed by Executive Orders. This included the reciprocal tariffs; fentanyl-related tariffs on China, Canada and Mexico; and the tariffs directed against dealings with Brazil, Cuba, Iran, Russia and Venezuela.
At the same time, President Trump issued a proclamation invoking his authority under section 122 of the Trade Act of 1974 to impose tariffs to correct the U.S.’s balance-of-payments deficit. The new tariffs were originally set at 10 percent, but are being increased to 15 percent according to President Trump. These tariffs will apply broadly to imports to the U.S., with some notable exceptions, including:
- all goods and parts of goods that currently are or later become subject to Section 232 tariffs;
- USMCA compliant goods of Canada and Mexico;
- textiles and apparel goods that enter duty-free under the Dominican Republic-Central America Free Trade Agreement; and
- specified goods needed for the U.S. economy, including certain critical minerals, fertilizers, agricultural products, electronics, passenger vehicles, pharmaceuticals, aerospace products and informational materials and accompanied baggage. These Section 122 tariffs are scheduled to take effect on February 24, and will last for a period of 150 days.
Also in response to the Supreme Court striking down the IEEPA-based tariffs, U.S. Trade Representative Greer announced Friday that the USTR will begin several new investigations under Section 301 of the Trade Act of 1974. He noted that these new Section 301 investigations will target most major U.S. trading partners and address key trade concerns, including pharmaceutical product pricing, industrial overcapacity, forced labor practices, and alleged discrimination against American technology companies and digital goods. The Trump Administration has already used Section 301 investigations to target Chinese electronics and shipping interests, and Nicaragua.
Customs and Border Protection (“CBP”) has issued a notice to importers in the Cargo Systems Messaging Service that as a result of the Supreme Court Ruling it is reviewing the collection of the IEEPA tariffs and will provide additional information and technical guidance for import filers as soon as it becomes available. CBP has made no reference to a process for refunds of collected IEEPA tariffs.
Keeping track of all the tariffs that have been promulgated or proposed during the Trump Administration continues to be a head-spinning task. To help follow the proliferation of tariffs in the Trump Administration, I have put together the following list of each of the tariff measures that have been implemented, pending, or proposed since January 20, 2025.
Here is the developing landscape of U.S. tariffs as of February 23, 2026:
| | U.S. Tariff Measure | Status |
| Global | 15% ad valorem duty on imports into the U.S. pursuant to Sec. 122 of the Trade Act of 1974.
Imports of certain specified items excluded
Imports of USMCA-qualifying products of Canada and Mexico excluded | **Implemented: 2/20/2026
Proclamation Imposing Sec. 122 Tariffs |
| Global | Semiconductors – 25% ad valorem duty on imports of specified semiconductors and derivative products | **Implemented: 1/14/2026
DOC Initiation and Request for Public Comments
Proclamation on Sec. 232 Duties |
| Global | Critical Minerals – trade negotiations directed regarding imports of processed critical minerals and derivative products | **Implemented: 1/14/2026
DOC Initiation and Request for Public Comments
Proclamation on Section 232 Action |
| Nicaragua | Section 301: Acts, Policies, and Practices Related to Labor Rights, Human Rights and Fundamental Freedoms, and the Rule of Law
January 1, 2026 - 0% ad valorem duty on all products of Nicaragua not under CAFTA-DR
January 1, 2027 – 10% ad valorem duty on all products of Nicaragua not under CAFTA-DR
January 1, 2028 – 15% ad valorem duty on all products of Nicaragua not under CAFTA-DR | Implemented: **** 12/12/2025 (effective 1/1/2026)
USTR Fed Reg Notice of Action |
| Global | Medium & Heavy Duty Trucks – 25% ad valorem duty on imports of medium-duty trucks, heavy-duty trucks, and medium- and heavy-duty truck parts
10% ad valorem duty on imports of buses and motor coaches | Implemented **** 10/17/2025
DOC Initiation and Request for Public Comments
Proclamation on Sec. 232 Duties |
| China | Section 301: Cranes/Cargo Handling Equipment – 100% ad valorem duty on imports of STS cranes and other cargo handling equipment | Implemented **** 10/16/2025 (effective 11/9/2025) Suspended 11/10/2025
USTR Fed. Reg. Notice of Proposed Suspension |
| Global | Lumber – 10% ad valorem duty on imports of softwood timber and lumber
25% ad valorem duty on imports of certain upholstered wooden products
25% ad valorem duty on imports of kitchen cabinets and vanities
Reduced tariffs on subject imports from U.K., the E.U., and Japan | Implemented **** 9/29/2025
Executive Order Initiating Sec. 232 Investigation
DOC Request for Public Comments
Proclamation on Sec. 232 Duties
Proclamation Delaying Duty Increase |
| Global | Copper – 50% ad valorem duty on imports of semi-finished copper products and intensive copper derivative products | Implemented: 7/30/2025
Executive Order Initiating Investigation
DOC Request for Public Comments
Proclamation on Sec. 232 Duties |
| Global | Steel – 50% ad valorem duty on imports of steel articles and derivative products with no exemptions or exclusions
25% ad valorem duty on imports of steel articles and derivative products from the United Kingdom.
Certain aerospace products from the United Kingdom exempt. | Revised 6/4/2025
Implemented: 3/12/2025
Proclamation on Sec. 232 Duties
Executive Order Removing “Stacking” of Tariff Programs
Proclamation Increasing Tariff Rate
Executive Order Implementing US-UK Trade Deal
Commerce Fed Reg Notice Adding Derivative Products
CBP Guidance on Additional Steel Derivative Products
Commerce Notice of Inclusion of Additional Products |
| Global | Aluminum – 50% ad valorem duty on imports of aluminum articles and derivative products with no exemptions or exclusions
25% ad valorem duty on imports of aluminum articles and derivative products from the United Kingdom.
Certain aerospace products from the United Kingdom exempt. | Revised 6/4/2025
Implemented: 3/12/2025
Proclamation on Sec. 232 Duties
Executive Order Removing “Stacking” of Tariff Programs
Proclamation Increasing Tariff Rate
Executive Order Implementing US-UK Trade Deal
Commerce Notice of Inclusion of Additional Products |
| China | Section 301: Chinese Vessels – Port Entry Fees on Chinese owned or built vessels, and foreign-built car carriers. | Implemented: 4/17/2025 Suspended 11/10/2025
USTR Notice of Action/Proposed Action, Request for Comments, and Notice of Public Hearing
USTR Request for Comments on Proposed Modification
USTR Fed. Reg. Notice of Proposed Suspension |
| Global | Automobiles – 25% ad valorem duty on imports of automobiles (with certain allowances for USMCA-qualifying autos) and certain automobile parts (with limited tariff offsets).
Import quota and reduced tariffs for automobiles and automobile parts from the United Kingdom. | Implemented 4/3/2025 (effective 5/3/2025 for automobile parts)
Proclamation on Sec. 232 Duties
Proclamation with HTS Amendments
Proclamation Establishing Tariff Offsets on Parts
Executive Order Removing “Stacking” of Tariff Programs
Executive Order Implementing US-UK Trade Deal |
| Global | Personal Protective and Medical Equipment – potential tariffs on imports of personal protective equipment, medical consumables, and medical equipment, including devices | Pending: Section 232 Investigation
DOC Initiation and Request for Public Comments |
| Global | Robotics and Industrial Machinery – potential tariffs on imports of robotics and industrial machinery | Pending: Section 232 Investigation
DOC Initiation and Request for Public Comments |
| Global | Wind Turbines – potential tariffs on imports of wind turbines and their parts and components | Pending: Section 232 Investigation
DOC Initiation and Request for Public Comments |
| Brazil | Section 301: Brazil's Acts, Policies, and Practices Related to Digital Trade and Electronic Payment Services; Unfair, Preferential Tariffs; Anti-Corruption Enforcement; Intellectual Property Protection; Ethanol Market Access; and Illegal Deforestation | Pending: Section 301 Investigation
Public Hearing Transcript |
| Global | Unmanned Aircraft Systems – potential tariffs on imports of unmanned aircraft systems (UAS) and their parts and components | Pending: Section 232 Investigation
DOC Initiation and Request for Public Comments |
| Global | Polysilicon – potential tariffs on imports of polysilicon and its derivatives | Pending: Section 232 Investigation
DOC Initiation and Request for Public Comments |
| Global | Aircraft and Engines – potential tariffs on imports of commercial aircraft and jet engines, and aircraft/engine parts | Pending: Section 232 Investigation
DOC Initiation and Request for Public Comments |
| Global | Pharmaceuticals– potential tariffs on imports of pharmaceuticals, pharmaceutical ingredients, and derivative products | Pending: Section 232 Investigation
DOC Initiation and Request for Public Comments |
| Global
[Canada & Mexico Exempt] | Reciprocal tariffs – 10% ad valorem duty
Country specific duty rates of 15% to 50% ad valorem
Certain goods excluded | STRUCK DOWN: 2/20/2026
Revised 11/20/2025
Implemented **** 4/2/2025
Executive Order Establishing Tariffs
Executive Order Revising Tariffs
CBP Bulletin on Excluded Electronics
Executive Order Reducing China Tariff Rates
Fed. Circuit Administrative Stay
Fed. Circuit Order Granting Motion to Stay
Executive Order Implementing US-UK Trade Deal
Executive Order Extending Effective Date of Country-Specific Tariffs
Executive Order Suspending Duty-Free de minimis Treatment
Executive Order on Brazil Tariffs
Executive Order Modifying Reciprocal Tariffs
Executive Order on India Tariffs
Executive Order Extending China Tariff Rates
Executive Order Implementing US-Japan Trade Deal
Executive Order Modifying Reciprocal Tariff Coverage
Implementing Elements of EU Framework Agreement
Executive Order Modifying Reciprocal Tariff Rates for China
Executive Order Modifying Reciprocal Tariff Rates on Certain Agriculture
Executive Order Modifying the Scope of Tariffs on Brazil
Executive Order Modifying Tariffs on India
Executive Order Ending Tariffs |
| Canada | 10% ad valorem duty on non-USMCA-qualifying energy and potash
25% ad valorem duty on all other non-USMCA-qualifying products of Canada | STRUCK DOWN: 2/20/2026
Implemented: 3/4/2025;
4/2/2025 (updated)
Fed. Circuit Administrative Stay
Fed. Circuit Order Granting Motion to Stay
Executive Order Ending Tariffs |
| Mexico | 25% ad valorem duty on all non-USMCA-qualifying products of Mexico | STRUCK DOWN: 2/20/2026
Implemented: 3/4/2025;
4/2/2025 (updated)
Fed. Circuit Administrative Stay
Fed. Circuit Order Granting Motion to Stay
Executive Order Ending Tariffs |
| China | 10% ad valorem duty on all products of China (reduced from original rate of 20%) | STRUCK DOWN: 2/20/2026
Implemented : 3/4/2025
CBP Fed Reg Notice
Fed. Circuit Administrative Stay
Fed. Circuit Order Granting Motion to Stay
Executive Order Reducing Tariff Rate
Executive Order Ending Tariffs |
| Global | All goods imported from a country determined to be directly or indirectly purchasing, importing, or otherwise acquiring any goods or services from Iran, since February 7, 2026 – discretionary variable rate ad valorem duty may be imposed | STRUCK DOWN: 2/20/2026
Implemented: 2/6/2026
Executive Order Ending Tariffs |
| Global | All goods imported from a country determined to have sold/provided oil to Cuba since January 30, 2026 – discretionary variable rate ad valorem duty may be imposed | STRUCK DOWN: 2/20/2026
Implemented: 1/29/2026
Executive Order Ending Tariffs |
| Global | All goods imported from any country that imports Venezuelan oil – discretionary 25% ad valorem duty may be imposed | STRUCK DOWN: 2/20/2026
Implemented **** 4/2/2025
Executive Order Ending Tariffs |
| Canada | Aircraft – potential 50% ad valorem duty on imports from Canada | Proposed: 1/29/2026, announced by President Trump on Truth Social |
| Denmark
Finland
France
Germany
Netherlands
Norway, Sweden
U.K. | 10% ad valorem duty on imports from designated countries relating to Greenland, to be effective Feb. 1, 2026 with increase to 25% on June 1, 2026 | Proposed: 1/17/2026, announced by President Trump on Truth Social, walked back on 1/21/2026 |
| Global | 100% tariff on movies produced outside of the United States | Proposed: 5/4/2025 and 9/29/2025, announced by President Trump on Truth Social |
| Global | 100% ad valorem duty as “secondary tariffs” on countries that do business with Russia. | Proposed: 7 /14/2025, announced by President Trump |
| Global | 200% ad valorem duty on imports of pharmaceuticals (currently subject to Sec. 232 investigation) | Proposed: 7 /8/2025, announced by President Trump at cabinet meeting |
| E.U. | 25% ad valorem duty on all products of the E.U. | Proposed: 2/26/2025, superseded by Reciprocal Tariffs |
This list will be updated weekly as new tariffs are implemented and new targets for tariffs are identified by President Trump and the administration.
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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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