The U.S. Tariff Landscape Just Changed Overnight — What Importers and Exporters Need to Know

Published: February 23, 2026

The last week of February 2026 brought one of the most significant shifts in U.S. trade policy in decades — not through a new negotiation or a trade deal, but through a Supreme Court ruling that invalidated the legal foundation of nearly two years of tariff policy. Within hours, the administration responded with a new framework. If you're moving goods to or from the United States, your cost structure may look different today than it did last week.

Here's what happened, what it means in practice, and what you should be doing right now.

How Did We Get Here?

When President Trump returned to office in January 2025, trade policy moved fast. Using the International Emergency Economic Powers Act (IEEPA) — a law originally designed for sanctions, not tariffs — the administration declared trade deficits a national emergency and imposed sweeping duties across virtually all U.S. trading partners. At its peak, the average effective U.S. tariff rate reached 7.7%, the highest level since 1947.

The tariffs were broad: country-specific reciprocal rates ranging from 10% to over 100% on Chinese goods, plus separate "fentanyl" tariffs on China, Canada, and Mexico. Alongside these, Section 232 tariffs on steel, aluminum, automobiles, and semiconductors — which had a different legal basis — remained in place and were expanded.

Throughout 2025, the legal challenges mounted. The Court of International Trade ruled against the IEEPA tariffs in May 2025. The Federal Circuit upheld that ruling. And on February 20, 2026, the U.S. Supreme Court confirmed in a 6-3 decision: IEEPA does not authorize the president to impose tariffs.

By the following day, the administration had signed an executive order terminating IEEPA tariffs and issued a new proclamation imposing a 15% global tariff under Section 122 of the Trade Act of 1974 — a different legal authority with a 150-day statutory limit.

What the New Tariff Structure Actually Looks Like

The transition from IEEPA to Section 122 isn't a clean swap. Here's a practical breakdown of what's in effect as of late February 2026:

The 15% global tariff (Section 122) applies to imports from virtually all countries of origin, effective February 24, 2026, through July 23, 2026. This is the new baseline.

What's excluded from the 15% tariff: USMCA-compliant goods from Canada and Mexico, CAFTA-DR countries, critical minerals, most energy products, and certain agricultural commodities. Full exclusion lists are published in Annexes I and II of the proclamation — worth reviewing carefully if your product category sits near the boundary.

Section 232 tariffs remain fully in place. Steel, aluminum, automobiles, lumber, and semiconductors were never tied to IEEPA and are unaffected by the Supreme Court ruling. If your goods fall under these categories, those duties continue unchanged.

China-origin goods still face elevated rates. IEEPA-specific duties are being wound down, but Section 301 tariffs (25%+) and Section 232 duties remain stacked on top of the new baseline. The effective rate on many Chinese product categories remains well above 15%.

De minimis restrictions continue. The suspension of duty-free de minimis treatment for postal shipments is maintained under a separate executive order. Postal entries are subject to the 10% global tariff rate — a significant reduction from previous rates, but the exemption itself remains suspended.

What Shippers & Consignees Should Be Watching

Your In-Transit Shipments

There is a narrow but important exception built into the Section 122 proclamation: goods that were loaded onto a vessel and in transit before 12:01 a.m. ET on February 24, 2026, and that enter or are withdrawn for consumption before February 28, 2026, are exempt from the new tariff. If you have shipments currently mid-ocean, check your bill of lading dates carefully. This four-day window matters.

CBP Is Still Catching Up

The Supreme Court ruling is final, but customs clearance systems don't update overnight. CBP (U.S. Customs and Border Protection) has not yet fully reprogrammed its Automated Commercial Environment (ACE) system to reflect the termination of IEEPA tariffs. In practical terms: shipments currently clearing customs may still be assessed at old IEEPA rates while the system update is pending. This isn't an error — it's a timing gap. Your freight forwarder or customs broker should be monitoring this closely.

Recalculate Your Landed Costs

If you priced a purchase order or sales quote last month, your cost basis may no longer be accurate. The shift from IEEPA-era rates to the new 15% global tariff — combined with the exclusion lists and the continued Section 232/301 stack — means landed cost calculations need to be revisited before new orders are confirmed.

Know Your Protest Deadlines

For importers who paid IEEPA duties that have now been struck down, refunds are not automatic. The Department of Justice stated during litigation that the government would issue refunds if tariffs were held unlawful — but the Supreme Court provided no direction on the refund process itself, and CBP has not yet announced a mechanism. What you can do now: identify entries that are approaching the protest deadline (180 days from the liquidation date) and file protests where that window is closing. Once an entry is past protest eligibility, your options narrow significantly.

The 150-Day Clock Is Running

Section 122 is a temporary authority — the statute limits its use to 150 days. That means the current tariff framework is set to expire on or around July 23, 2026. The administration has signaled it will use Section 301 and Section 232 investigations to build a longer-term tariff architecture before that window closes. Expect more policy announcements in the months ahead — and build that uncertainty into your mid-year planning.

What Could Come Next?

The 150-day expiry is the most immediate horizon. If Congress doesn't act and the administration doesn't find a new legal vehicle, the 15% global tariff lapses in July. But that's the least likely outcome — the administration has been explicit that it intends to maintain tariff pressure through other statutory tools.

More probable scenarios for the second half of 2026:

New Section 301 investigations targeting specific countries or sectors, which could produce higher, targeted rates to replace the blanket IEEPA structure. Section 301 investigations typically take 12 months but can be accelerated.

Expanded Section 232 coverage, potentially into pharmaceuticals, shipbuilding, or electronics — categories the administration has flagged as strategic priorities.

Bilateral trade deals negotiated under the threat of tariff reinstatement — similar to the framework agreements reached with the EU, UK, Japan, and South Korea in 2025. Some of those agreements are now in a grey area legally and may be renegotiated.

For importers and exporters planning through the rest of 2026, the practical takeaway is this: the specific rates will keep moving, but the direction of U.S. trade policy is not reversing. Cost modeling that assumes a return to pre-2025 tariff levels is not a sound planning assumption.

How Movargo Can Help

Navigating a tariff environment that changes week to week requires more than just tracking the news. It requires understanding how each policy shift translates into your specific shipment, your specific product codes, and your specific trade lanes.

At Movargo, we work with importers, exporters, and supply chain teams to make sure these developments don't catch you off guard:

• Landed cost reviews as the tariff landscape shifts — so your quotes and purchase orders reflect current reality

• In-transit shipment monitoring to capture time-sensitive exemptions and avoid unnecessary duty payments

• Routing and timing guidance tailored to the current regulatory environment

• Coordination with customs brokers on protest filings and duty documentation for entries that may be eligible for refunds

  
  

If you have shipments moving to or from the U.S. right now, or if you're pricing orders for Q2 and Q3, this is a good moment to pressure-test your assumptions.

Get in touch with the Movargo team — we're tracking these developments daily and can help you translate the policy changes into decisions that make sense for your freight.