Trump Tariff Tracker: Section 122 Tariffs and Section 301 Investigations
Summary
This update tracks the Reclaim Trade Powers Act, challenges to Section 122 tariffs, and new Section 301 investigations by the USTR into excess manufacturing capacity and forced labor. Public comments are invited for these investigations.
What changed
This update details legislative efforts to repeal Section 122 of the Trade Act of 1974, which President Trump used for global tariffs, and ongoing legal challenges to these tariffs in the Court of International Trade. It also highlights new Section 301 investigations initiated by the USTR into structural excess capacity in 16 economies and into countries failing to enforce bans on goods produced with forced labor, potentially leading to new import bans.
Regulated entities, particularly importers and exporters, should be aware of these developments. The USTR is accepting public comments on the Section 301 investigations until April 15, 2026, with hearings starting May 5, 2026. The potential expiration of Section 122 tariffs on July 24, 2026, and the possibility of new import bans require close monitoring for compliance and strategic planning.
What to do next
- Monitor legal challenges to Section 122 tariffs.
- Submit public comments on Section 301 investigations by April 15, 2026.
- Prepare for potential import bans related to forced labor investigations.
Source document (simplified)
March 13, 2026
Trump Tariff Tracker – March 12, 2026
Matthew West Baker Botts L.L.P. + Follow Contact LinkedIn Facebook X Send Embed
President Trump’s use of Section 122 of the Trade Act of 1974 to impose global tariffs continues to be challenged. Senators Kaine and Warnock have introduced The Reclaim Trade Powers Act, which would repeal Section 122, the legal basis President Trump used to justify the global 10% tariff. This section was originally designed to address balance-of-payments deficits or significant currency depreciation at a time the U.S. dollar was tied to gold and subject to rapid depletion through foreign central bank actions. Proponents of the legislation believe that with the shift to a floating exchange‑rate system more than 50 years ago, Section 122 has become functionally obsolete and is being applied incorrectly by President Trump.
In a follow-up action in the Court of International Trade case brought by 24 states against the Section 122 tariffs, the plaintiff states in that case will be requesting the CIT issue an injunction to block President Trump’s 10% global tariffs while the case is under consideration. The court has scheduled a three-judge panel to meet on April 10 to hear the state officials’ challenge to the Section 122 tariffs President Trump imposed. This will be heard in tandem with another challenge brough by an importer against the Section 122 tariffs. The CIT could issue its decision on the legality of the Section 122 tariffs by the end of April.
The United States Trade Representative has initiated new Section 301 investigations into acts, policies, and practices of 16 economies relating to structural excess capacity and production in manufacturing sectors. According to the USTR, these investigations will focus on “economies that appear to exhibit structural excess capacity and production in various manufacturing sectors, which can manifest as large or persistent trade surpluses or underutilized or unused capacity.” The economies in question include China, the European Union, Singapore, Switzerland, Norway, Indonesia, Malaysia, Cambodia, Thailand, Korea, Vietnam, Taiwan, Bangladesh, Mexico, Japan, and India. The USTR is inviting public comments on these investigations until April 15, and will hold a public hearing covering each investigated economy starting on May 5.
USTR Greer has also announced that he will soon initiate another Section 301 investigation into countries that do not enforce bans on goods produced with forced labor. This investigation will cover imports from more than 60 countries, and could result in new bans on imports into the U.S. of goods produced with forced labor. These bans may be similar to the existing bans on imports of solar panels and other goods from China's Xinjiang region under the Uyghur Forced Labor Prevention Act. USTR Greer said that he hoped to conclude both sets of Section 301 investigations, including proposed remedies, before the Section 122 tariffs imposed by President Trump expire on July 24, 2026.
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 March 12, 2026:
| | U.S. Tariff Measure | Status |
| Global | 10% 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 |
| Bangladesh
Cambodia
China
EU
India
Indonesia
Japan
Malaysia
Mexico
Norway
Singapore
South Korea
Switzerland
Taiwan
Thailand
Vietnam | Section 301: Acts, Policies, and Practices of Certain Economies Relating to Structural Excess Capacity and Production in Manufacturing Sectors | Pending: Section 301 Investigation
USTR Fed. Reg. Notice |
| 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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