For the past two years, importers have learned one important lesson: expect the unexpected.
Between the court decisions surrounding IEEPA tariffs, the implementation of temporary Section 122 tariffs, expanding Section 232 actions, and new Section 301 investigations, U.S. trade policy has become increasingly dynamic. As we approach August 2026, many companies are asking the same question:
What will the U.S. tariff landscape actually look like next month?
While no one can predict the final outcome with certainty, several trends are becoming increasingly clear.
The Temporary Section 122 Tariffs Will Likely Be Gone
Section 122 of the Trade Act only authorizes temporary tariffs for up to 150 days unless Congress acts to extend them. That means the current global 10% tariff was always intended to be a bridge—not a permanent solution.
Trade policy experts are now focused on what will replace those tariffs rather than whether they were designed to last indefinitely.
Since the Section 122 tariffs expire without congressional action, importers will likely see the temporary across-the-board tariff disappear on July 24th.
But that doesn’t necessarily mean tariffs are going away.
Tariffs Are Unlikely to Become Less Complicated
If there is one consistent theme throughout the current Administration’s trade strategy, it is that tariffs remain a central policy tool. Rather than relying on a universal tariff, we will likely see a shift toward more targeted tariffs, including:
- Country and commodity-specific (and sometimes company specific) expanded Section 301 tariffs following the conclusion of many ongoing investigations
- Additional Section 232 national security tariffs covering new industries
In other words, the conversation may move away from “one tariff for everyone” toward a more customized—and more complicated—tariff environment.
Section 232 Tariffs Could Continue to Grow
Section 232 has become one of the Administration’s preferred legal authorities because it is not subject to the same time limitations as Section 122.
We’ve already seen Section 232 expand beyond its traditional focus on steel and aluminum into additional industrial sectors like copper, and more investigations are possible.
Most recently, while the Administration chose not to implement Section 232 tariffs on commercial aircraft, jet engines, and aircraft parts immediately, it maintained the authority to impose tariffs within 180 days if agreements with certain countries on aerospace products cannot be reached.
This signals that Section 232 remains an active policy tool and that additional industry-specific actions remain possible.
Businesses importing products with significant metal content, manufactured components, or strategic materials should continue monitoring developments closely.
Section 301 May Become the Long-Term Replacement for Section 122
Another likely development is increased reliance on Section 301 tariffs which are country and commodity specific.
Unlike Section 122, Section 301 investigations require a formal process but can ultimately produce long-term tariff programs targeted at specific countries for unfair trade practices.
Recent actions and commentary by the Administration suggest new Section 301 investigations will be used to expand tariffs, providing a stronger legal foundation for its trade policy agenda.
USTR Proposes New Section 301 Tariffs on 60 Countries
On June 2nd, the USTR announced its findings in its Forced Labor Section 301 case on 60 countries around the globe. As a result of the findings the USTR is proposing additional duties on all products of these countries except for products listed in its Annex A (reach out to Dimerco for a copy of this Annex).
The USTR concluded that these countries failed to impose and effectively enforce prohibitions on imports made with forced labor.
Countries Facing a Proposed 12.5% Tariff
The USTR proposes a 12.5% Section 301 tariff on imports from the following countries:
Algeria; Angola; Australia; the Bahamas; Bahrain; Brazil; Chile; China, People’s Republic of; Colombia; Costa Rica; Dominican Republic; Egypt; Guyana; Honduras; Hong Kong, China; India; Iraq; Israel; Japan; Jordan; Kazakhstan; Kuwait; Libya; Morocco; New Zealand; Nicaragua; Nigeria; Norway; Oman; Peru; the Philippines; Qatar; Russia; Saudi Arabia; Singapore; South Africa; South Korea; Sri Lanka; Switzerland; Thailand; Trinidad and Tobago; Türkiye; United Arab Emirates; Uruguay; Venezuela; and Vietnam.
Countries Facing a Proposed 10% Tariff
The USTR also proposes a 10% Section 301 tariff on countries that have already implemented measures to combat forced labor under their respective trade agreements.
These countries include: Canada; Ecuador; the European Union; Indonesia; Mexico; and Pakistan; Argentina, Bangladesh, Cambodia, Ecuador, El Salvador, Guatemala, Indonesia, Malaysia, and Taiwan; and the United Kingdom.
How the Proposed Tariffs Would Apply
If implemented, these new Section 301 tariffs would:
- Apply to all products from the affected countries unless specifically exempted in Annex A.
- Stack on top of the existing China Section 301 tariffs (7.5% or 25%), where applicable.
- Not stack on top of existing Section 232 tariffs.
- Not apply to USMCA-qualifying goods.
- Include a proposed textile mechanism that would allow certain apparel and textile imports from eligible countries to enter the U.S. under a reduced Section 301 tariff.
Importers should carefully review product classifications and confirm whether their imports qualify for any exemptions.
Timeline and Next Steps
The USTR received public comments on the proposed action and held public hearings. Industry experts believe the agency intends for these new tariffs to take effect when the temporary Section 122 tariffs expire on July 24.
Section 301 Tariffs on Brazil
As part of the Administration’s increased reliance on Section 301 tariffs, the U.S. recently announced a new 25% Section 301 tariff on goods from Brazil, effective on or after 12:01 a.m. EST on July 22, 2026. Goods loaded onto a vessel before July 22 and entered prior to July 29 are exempt.
The new tariff does not stack on top of existing Section 232 tariffs, and the order also includes an expanded list of exempted products. This latest action reinforces the Administration’s strategy of using targeted Section 301 measures as a long-term replacement for broader temporary tariff programs.
Additional Section 301 Investigations Underway
In addition to the forced labor investigation, the Administration has several other Section 301 cases in progress. These include investigations involving the European Union, Japan, China, Singapore, Switzerland, Norway, Indonesia, Malaysia, Cambodia, Thailand, South Korea, Vietnam, Taiwan, Bangladesh, Mexico, and India.
If additional Section 301 actions are implemented, they could stack on top of the proposed forced labor tariffs outlined above, creating further duty exposure for importers.
Importers Shouldn’t Wait for Final Answers
One of the biggest mistakes companies can make is delaying planning until the government announces its final tariff decisions.
With the U.S. tariff landscape continuing to evolve, successful importers are already evaluating ways to reduce duty exposure and strengthen their supply chains. That includes reviewing:
- Section 301 exclusion opportunities
- Country of origin and sourcing strategies
- First-sale opportunities
- Free Trade Agreement eligibility
- USMCA qualification
- Customs valuation strategy
- Product classification / tariff engineering options
- Duty drawback opportunities
- Foreign Trade Zone and bonded warehouse utilization
- Supplier and sourcing diversification
Companies that wait until new tariffs take effect often have fewer options than those that prepare in advance.
Compliance Will Matter More Than Ever
As the U.S. tariff landscape becomes more complex, customs compliance will become even more important.
A single classification error, incorrect country of origin determination, or unsupported duty preference claim can significantly increase landed costs, delay shipments, or create audit exposure.
Importers should review their customs documentation and internal compliance processes to ensure they can support:
- HTS classifications
- Country of origin determinations
- Customs valuation
- Free Trade Agreement claims
- Section 301 exclusion claims
- Recordkeeping requirements
As tariff enforcement expands, strong compliance practices will be just as important as sourcing and tariff mitigation strategies.
What Should Importers Expect?
August may mark the end of one tariff program, but it is unlikely to mark the end of an aggressive U.S. trade policy on tariffs.
The temporary Section 122 tariffs are expected to expire on July 24. However, importers should expect the Administration to continue using other trade authorities, including Sections 232 and 301, to pursue many of the same policy objectives.
The legal authority may change, but tariffs are likely to remain a significant part of the U.S. tariff landscape.
Don’t Wait to Prepare
Dimerco continues to monitor tariff developments, Customs rulings, and trade policy announcements so our clients can make informed decisions before changes affect their supply chains.
Whether you are evaluating sourcing strategies, reviewing customs classifications, identifying duty mitigation opportunities, or strengthening your trade compliance program. Our experts can help you prepare for changes in the U.S. tariff landscape and develop practical, long-term strategies for managing tariff risk.
