2025 was undeniably a year of sweeping shifts in U.S. trade policy. Under the Trump Administration’s “America First” trade policy, average tariff rates climbed sharply, and new reciprocal and Section 232 tariffs were applied to a wide range of trading partners reaching levels not seen in decades.
As we look toward 2026, many are asking: Have we experienced a fundamental shift in trade policy? Will tariffs remain at the heart of U.S. trade strategy for the foreseeable future? Could we face another year of tariff turmoil in 2026? In this U.S. tariff update and trade compliance review, we’ll explore what experts think may be on the horizon.
First, A Look Back at 2025
In 2025, the Trump Administration implemented a host of new tariffs intended to protect domestic industry and address trade deficits, but they also contributed to higher import costs, global trade uncertainty, and slower economic growth projections. For businesses and consumers, this could mean higher prices on imported goods and tighter global supply chains in 2026
2025 included a sea of different tariffs, some country-specific, some commodity specific, and some even company specific.
- Commodity-specific Section 232 tariffs were put in place on aluminum, copper, steel, lumber, upholstered furniture, autos, auto parts, and more.
- Country-specific Section 301 tariffs on China remained in place, and new 301 tariffs were placed on Nicaragua. Country-specific IEEPA (International Emergency Economic Powers Act) tariffs impacted every U.S. trading partner. And some country-specific “framework agreements” were negotiated that include complex tariff calculations and tariff-exemptions.
In addition to the burden of these new, unbudgeted tariff expenses, importers struggled to navigate a host of chaotic changes, including: changing tariff rates, the implementation of new tariffs with little to no notice, complex implementation rules, enhanced customs agency enforcement, confusing and often-changing exemptions, increasing Customs entry fee costs, and broker partners making every effort to file compliant entries within 24 hours of significant policy shifts.
Will 2026 be easier to navigate? Let’s take a look at what can be expected.
Supreme Court Decision on the Lawfulness of IEEPA Tariffs
The lynchpins of the Trump tariff agenda are the IEEPA tariffs, which include reciprocal tariffs on a host of U.S. trade partners, and the so-called fentanyl tariffs on Canada (35%), Mexico (25%), and China (now 10%). The Supreme Court will soon rule in 2026 whether these tariff measures are unlawful. Prediction markets place very low odds on the chances they will be upheld.
What Happens If IEEPA Tariffs Are Struck Down or Upheld?
If the IEEPA tariffs are declared unlawful in total, expect a barrage of new measures, most commodity-specific, to come in their place. The country-specific framework agreements that have been negotiated with key U.S. trading partners have IEEPA tariffs as their basis. Expect that these agreements could quickly fall apart. The IEEPA tariff refund process is likely to be messy.
If you do not have a strong provider in place, it may be wise to engage with a trusted partner for international customs brokerage and compliance services. In addition, you should have a plan in place, and solid data around the IEEPA tariffs you’ve paid to make the potential refund process easier.
Implications of a Supreme Court ruling on trade Policy
If the IEEPA tariffs are declared lawful in total, expect decades of tariff uncertainty as any future administration will have blanket authority to implement and rescind tariffs for virtually any reason.
Some reasons previously floated could include:
- Domestic industry pressures
- Economic pressures
- Geopolitical tensions
- Environmental concerns
- Labor concerns
If the IEEPA tariffs are declared unlawful in part, expect a bit of chaos around new tariff measures, refunds, existing framework agreements, and future IEEPA tariffs. It will take the courts, the trade and government agencies some time to determine exactly how the decision will impact the trade.
Trade Negotiations and New Trade Frameworks
While the future of IEEPA tariffs is uncertain, the Administration continues to negotiate new framework agreements, a job previously in the hands of Congress. The U.S. has already negotiated agreements with some major trade partners, such as Japan, the United Kingdom, South Korea, and the European Union.
These agreements are intended to combine tariffs with market access commitments, but they are non-binding. This gives the trade community little certainty in 2026 with respect to duty rates, market access, and tariff exemptions since agreements could be rescinded at any time if either side reneges on a commitment or is unhappy with the current trade relationship.
We can expect more of these agreements in 2026. Experts report the U.S. is now close to deals with Taiwan, India, and Brazil, and more are reportedly in the works.
USMCA Review
The joint review of the United States–Mexico–Canada Agreement (USMCA) is expected in July of 2026. Comments from the U.S. Administration are already sparking concern that the agreement could be in jeopardy, with the President preferring bilateral trade deals to regional ones like USMCA. The push-back on the agreement could be a negotiating tactic but expect lots of rumors, conflict and uncertainty around its renewal in the months leading up to July.
Economic and Growth
Trade policy doesn’t happen in a vacuum — it interacts within broader economic conditions. U.S. economic growth is expected to moderate in 2026, influenced in part by trade policy uncertainty and higher import costs.
A weaker U.S. dollar, partly tied to trade and monetary factors, could benefit exporters but complicate investment and capital flows. In 2026, planning for slower demand growth, potential inflationary pressures, and continued trade policy shifts will be key.
The impact of tariff updates on the economy have also begun to drive some cracks in Congressional support for the Administration’s trade policy, with the Senate rejecting many of the President’s tariff measures. And the Administration has eased some tariffs ahead of the mid-term elections.
The final Supreme Court ruling on IEEPA tariffs and the results of the mid-term elections will partly determine the level of support for the tariffs in Congress in 2026.
Sector-Specific Shifts and Supply Chain Rebalancing
Tariff policies and trade negotiations are reshaping sectors like auto, steel, aluminum, semiconductors, and critical minerals that have been particularly impacted by tariff (Section 232) measures. Expect more commodity-specific tariff updates in 2026, and for those tariffs to include more harmonized codes in their product groups over time.
Virtually all 232 tariffs now come with multiple review periods each year that encourage domestic industry to petition for protective tariffs on more products in their market sector.
Most of these petitions are usually approved irrespective of domestic industry’s ability to meet demand or competitive price points in their sectors.
Expect commodity-specific tariffs to also come in the form of anti-dumping and countervailing duties (AD/CVD), with the number of cases exploding in recent years.
Tailored Trade Deals and Alternative Mechanisms
Expect tariff updates in the form of company-specific deals, like those we’ve seen in the pharma sector, to continue to expand, with companies negotiating specific agreements with the Administration in exchange for reduced tariffs or foreign market access.
Some negotiated deals may reduce tariffs on key exports (e.g., auto parts) in exchange for investment commitments in the U.S. market, a major shift in U.S. trade policy.
Should the IEEPA tariffs be declared unlawful, expect Section 232, Section 301 and other country- and commodity-specific tariffs to be implemented.
These options, however, do come with more guardrails than the IEEPA measures – some with time limits, some with rate limits and others with more specific guidelines or open comment periods before implementation.
How Companies are Responding
Given the shifts in tariffs, many companies are responding by diversifying their supply chains beyond China into ASEAN, Mexico, and other markets to mitigate tariff risks. As a result, 2026 could be a pivotal year for sourcing strategy. Even these moves, however, come with risk given the uncertainty surrounding U.S. trade policy we’ll see this year.
Geopolitics and Global Trade Landscape
U.S. trade policy is more closely linked to geopolitics than ever before. In 2025 we saw a host of tariff measures linked to non-trade issues and we’ll see that trend continue in 2026. We’ll likely see more trade policy actions aimed at ensuring the Administration’s overarching policy goals.
Increased Customs Enforcement Focus
The U.S. Administration continues to signal its focus on CBP trade compliance enforcement, recently launching a Trade Fraud Task Force manned with 40 attorneys focused on “aggressively pursuing enforcement actions against any parties who seek to evade tariffs and other duties, as well as smugglers who seek to import prohibited goods into the American economy.”
CBP’s newly signed contract with Exiger gives it access to a host of data points meant to help the agency better target transshipment, and false valuation, origin, classification, First Sale, and USMCA claims. A recent fraud case ended with company owners being fined $11.5 million, ordered to pay $15 million in restitution, and sentenced to 103 months in federal prison.
A Sharp Rise in Enforcement Activity
With a huge uptick in CF28’s, CF29’s, audits and fraud cases recently, CBP is doubling down on enforcement. Expect this to continue in 2026. To prepare, do your own trade compliance review and read our article on the real questions shaping trade compliance today.
The Future of the NIR Program
There are also rumors Congress may soon eliminate the non-resident importer of record (NIR) program for all countries, except Canada and Australia. NIR allows foreign companies to clear Customs in the U.S., especially for DDP and MDDP shipments. In 2026, the Administration wants to close this loophole that it believes is driving significant valuation fraud.
Export Enforcement
The new 50% rule – the one that extends the BIS’ (Bureau of Industry & Security) existing export control restrictions to any foreign entity that is 50% or more owned, directly or indirectly, individually or in the aggregate, by one or more parties on U.S. restricted lists – was delayed. But it will likely be implemented in November of 2026. Be sure you’re ready.
How U.S. Importers Can Prepare for U.S. Trade Policy in 2026
Trade policy uncertainty has become the norm rather than the exception, and that will continue in 2026. Further tariff updates, evolving enforcement priorities, geopolitical tensions, and changing trade agreements are likely to continue shaping how goods move into the United States.
While no company can control policy outcomes, preparation is a powerful risk-management tool. Here’s are 10 ways to position your company to stay competitive, compliant, and resilient in 2026:
1.) Assume Trade Volatility Is Here to Stay
One of the most important mindset shifts is recognizing that trade volatility in the U.S. is not temporary, it’s dynamic. 2026 is unlikely to bring a return to “set-it-and-forget-it” trade rules. So avoid building business models that rely on a single source of supply or static duty rates.
Expect continued tariff complexity, and the need to navigate new agreements and enforcement priorities. Plan for policy risk the same way you plan for currency or supply risk. Flexibility and supply chain agility will be a competitive advantage. Engage internal and external experts to help with analysis, strategy, and compliance.
2.) Stress-Test Your Tariff Exposure
Many importers still underestimate their true tariff exposure. Heading into 2026, it’s critical to understand where duties hit hardest and where mitigation opportunities exist. Review current HTS classifications for accuracy.
Engage experts to help model multiple duty scenarios (higher tariffs, new exclusions, loss of exclusions). Identify products with thin margins that are most sensitive to duty increases to help prioritize where to invest time and resources.
3.) Re–evaluate Country-of-Origin and Sourcing Strategies.
U.S. country-of-origin rules play a central role in tariff liability, trade remedies, and eligibility for trade agreements like USMCA. With ongoing scrutiny of transshipment and origin manipulation, importers must be confident in their sourcing claims.
Audit supplier origin documentation and component source claims. Confirm substantial transformation analyses. Explore alternative sourcing locations where feasible, including regional diversification to tariff-friendly locations for your product. Even partial diversification can reduce risk if trade tensions escalate in a region.
4.) Strengthen Customs Compliance
2026 trade policy changes will come with increased enforcement. Customs will scrutinize valuation, classification, origin, and forced-labor compliance closely this year. To prepare, conduct internal customs compliance reviews and engage outside experts to conduct a gap analysis. Ensure valuation methodologies are compliant and well-documented.
Review forced labor due diligence processes and supplier certifications. Maintain records that can withstand audit scrutiny. Strong compliance not only reduces penalties — it also prevents costly disruptions to your business. Need to bone up on trade compliance? Read our Trade Compliance 101 Guide.
5.) Build Trade Policy Monitoring into Your Operation.
Companies that rely on ad-hoc news updates are often caught off guard. By 2026, monitoring trade policy and tariff updates should be part of normal business operation and you need access to data to understand how policy changes impact your business. Assign internal ownership for trade policy updates and data collection.
Work closely with customs brokers, trade counsel, or other trusted experts who regularly monitor Executive Orders, Customs guidance, Federal Register notices, and other enforcement trends.
Having your own early warning system gives your team time for analysis to set a strategy for pricing and sourcing changes, contract review, and logistics pivots before changes take effect.
6.) Renegotiate Supplier Contracts with Trade Risk in Mind
Many purchasing contracts were written for a more stable trade environment. As 2026 approaches, contract terms should reflect today’s realities. Consider tariff-sharing or renegotiation clauses, price-adjustment mechanisms tied to duty changes, clear allocation of responsibility for compliance failures, and flexibility in sourcing or volume commitments. Contracts that account for trade risk reduce conflict and protect margins when policies shift.
7.) Use Trade Tools Strategically — Not Reactively
There are many strategies to help importers reduce import duties, but they are most effective when used proactively.
Some options include Free Trade Agreements, First Sale, Reconciliation, duty drawback, Foreign-Trade Zones (FTZs), bonded warehouses, bond optimization, compliant tariffs, and origin engineering. Importers who wait until tariffs rise often miss opportunities that require advance planning.
8.) Treat Trade Strategy as a Business Strategy
Perhaps the biggest lesson heading into 2026 is that trade is no longer just a compliance issue — it’s a core business strategy. Importers that integrate trade considerations into product design, supplier selection, pricing models, and long-term strategic planning will be better positioned to adapt quickly while competitors scramble.
9.) Think Globally and Diversify
Trade policy uncertainty could fuel market volatility, especially in manufacturing and export-dependent sectors. Be ready and consider your global exposure to tariffs and currency fluctuation.
New trade deals between countries outside the U.S. could also gradually boost export-driven growth and help stabilize prices. Be ready to take advantage of those opportunities, but move carefully. And don’t overinvest in a single market. Diversification is the best medicine for volatility.
10.) Engage Trusted Advisors
In today’s volatile trade policy environment, it’s hard to go it alone. The smart bet is to engage with trusted trade compliance advisors who have expertise in trade policy and compliance and can help you understand the big picture, assess options, and implement solutions around the globe.
While relationships with Customs brokers were often transactional in the past, it’s more important than ever to forge a strong, strategic partnership with the company filing your entries and helping you navigate trade policy.
Final Thought on Tariff Updates and Trade Compliance: Preparation Beats Prediction
No one can say with certainty exactly how U.S. trade policy will evolve in 2026, but importers don’t need perfect forecasts to succeed. They need good data for visibility across their business, access to timely updates, and operational flexibility.
By stress-testing exposure, strengthening trade compliance, diversifying supply chains, and embedding trade awareness into decision-making, U.S. importers can turn uncertainty into a manageable, and even strategic advantage.
In 2026, the most successful importers won’t be the ones who guessed right. They’ll be the ones who were ready for change. The ones who positioned themselves with the right information and the right partners to succeed in an increasingly unpredictable trade policy landscape.
Need Help with Your Global Trade Compliance Needs?
The pace and complexity of trade compliance changes are beyond the ability of most global businesses to manage the function on their own. A strategic partner like Dimerco Express Group can help by combining global shipping and logistics capabilities with an expert knowledge of customs brokerage and trade compliance. To discuss how Dimerco can help you navigate the volatile trade compliance landscape, contact us today to start a discussion.
