US tariff changes in force

Proclamation 11012 ran the surcharge through 12:01 a.m. eastern daylight time on 24 July 2026, unless suspended earlier or extended by an Act of Congress. As of 5 November 2026 we found no such Act and no extending proclamation or notice in the Federal Register, so we treat it as lapsed at that moment. We also found no CBP message announcing the end. In Slip Op. 26-47 the trade court gave relief only to the State of Washington and two importers, and the government appealed on 8 May 2026. Refunds of the surcharge for anyone else aren't settled, so ask your broker or counsel whether to protest.

From 12:01 a.m. eastern time on 24 July 2026, goods of 60 economies pay an extra duty, on the stated ground that those economies don't enforce a ban on forced-labour imports. Each origin has its own heading or pair of headings from 9903.05.20 to 9903.05.84.

Four exemptions decide most real cases:

• USMCA goods. Products of Canada and Mexico entered free under USMCA are exempt, through headings 9903.05.93 and 9903.05.94.
• Goods already under Section 232. Heading 9903.05.90 takes out listed steel, aluminium and copper articles, vehicles and parts, wood products and semiconductors, so these goods don't pay both.
• Product lists. Annexes exempt things like civil aircraft parts, articles for pharmaceutical use and listed raw materials, and some lists apply only to certain origins.
• Chapter 98. Goods entered under chapter 98 are generally exempt. Under 9802.00.40, 9802.00.50, 9802.00.60 and 9802.00.80 the duty still applies to the value of the repair, processing or foreign assembly.

An FTA claim doesn't remove the duty by itself, as US note 52 applies it even to goods eligible for special tariff treatment. USMCA is the main exception, and CAFTA-DR textile and apparel goods entered free are another. Goods admitted to a foreign-trade zone must take privileged foreign status unless they qualify for domestic status.

Brazil sits in the 12.5% group as well as under its own 25% action. Note 52 says these duties also apply on top of other duties in the same subchapter unless it excludes them, and we found no carve-out for the Brazil duty, so check both exemption lists for your line. USTR's list of investigations also shows structural excess capacity, opened 11 March 2026; Vietnam's intellectual property practices, opened 29 May 2026; and German pharmaceutical pricing, opened 18 June 2026. We found no action notice for those as of 5 November 2026.

The 2018 actions didn't lapse in July and August 2026: USTR confirmed continuation on 7 October 2026, with a second four-year review to follow. The September 2024 modification took some lines as high as 100%, such as electric vehicles. These duties sit in a different subheading and stack with the 12.5% unless a note excludes them.

These apply by what the goods are, whatever the country, with rates varying by agreement. The table isn't exhaustive, and every line has annexes and exceptions. Rates are as of 5 November 2026, and the polysilicon row isn't in force until 4 December 2026.

Before 4 December 2026, a BIS rule in force from 22 September to 3 December 2026 can bar polysilicon importers it finds stockpiling and limits weekly volumes for importers who registered on or after 6 August 2026.

For commercial aircraft, wind turbines, and robotics and industrial machinery, the proclamations published in July, October and November 2026 direct negotiations and impose no new tariff yet. On metals, BIS proposed in August 2026 adding 14 more derivative articles, among them fire extinguishers, floor safes, trailers and brass-wind instruments, generally at 25%. It isn't law. Comments closed on 27 August 2026, and we found no final notice as of 5 November 2026.

In July 2026 the US imposed 50% duties on listed goods of Canada, citing Canadian treatment of US alcohol, dairy and vehicles. The start date moved to 22 August 2026. Lists changed on 15 September 2026 and again on 30 October 2026, when 22 lines came off and 100 went on under heading 9903.03.14. From 29 September 2026 some Canadian goods have been banned outright.

Since 15 September 2026 the alcohol and vehicle lists (headings 9903.03.12 and 9903.03.14) have applied in addition to Section 232. Only the dairy list (9903.03.13) keeps the Section 232 carve-out. CBP's current list shows that carve-out and one for civil aircraft, but no general USMCA exemption, and its chapter 98 exception leaves out USMCA subchapter XXIII. So don't assume a USMCA claim clears these lines. Read the list for your heading with your broker.

The USMCA itself wasn't renewed at the 1 July 2026 joint review. It stays in force, and Article 34.7 now calls for a joint review every year.

Executive Order 14436 of 16 October 2026 sets a 500% increase on goods from Russia under the Graham Act, plus 100% on some other countries, and waives all of those duties in the same order. The waiver can be lifted without a new tariff action, so keep it on your list if you buy Russia-linked goods. Separately, a four-year Section 201 safeguard on quartz surface products started on 15 August 2026, as a tariff-rate quota that excludes many FTA partners and developing countries.

This is an illustration, not a quote. Take $10,000 of cotton tote bags with an assumed 6% general rate, none of them on an exempt list. Look up the real rate for your subheading. The figures below show how much origin now matters.

Fees come on top, as set out on landed cost. Outside USMCA, an FTA claim can take the general rate to 0%, but the Section 301 duty generally stays, subject to the exceptions above.

Importers who paid IEEPA duties can claim through CBP's CAPE process, which launched in ACE on 20 April 2026 after the trade court's orders in Atmus Filtration and Euro-Notions. On CBP's refund page, last modified 2 November 2026:

• Who files. Only the importer of record, or the licensed broker who filed those entries, through the ACE Portal. An attorney can't.
• What's covered. Phase 1 covers certain unliquidated entries and certain entries within 80 days of liquidation. Since 29 June 2026, phase 2 adds entries flagged for reconciliation where the reconciliation entry isn't yet on file, on the same timing.
• What isn't yet. CBP is still evaluating reconciliation entries already on file, drawback, warehouse entries, entries under open protest, some AD/CVD entries, entries not filed in ACE, and entries whose liquidation is final.
• How you're paid. By ACH, with interest, into the bank details on your ACE account. CBP says to expect valid refunds generally within 60 to 90 days of acceptance, later for suspended, extended or warehouse entries.
• If you disagree. You can protest the refund amount within 180 days of liquidation or reliquidation. CBP says it can also bill you if the entry was underpaid in other ways.

CBP says you don't need a court case for phase 1 entries, and gives no guidance on whether you need one for any others. If that's you, take legal advice now. CBP only refunds the importer of record or its designated notify party, not consumers. So if a courier or a seller was the importer on your parcel, the claim starts with them.

For parcels, see US low-value shipments. For the importer question, see DDP and DAP. This page is guidance, not legal advice.