What changed The Section 122 10% global surcharge sunset at 12:01 a.m. EDT today, and USTR's replacement went live the same moment. Ambassador Jamieson Greer took final action, at President Trump's direction, under Section 301 of the Trade Act of 1974 by imposing tariffs on 60 economies for their failure to impose and effectively enforce a prohibition on the importation of goods produced with forced labor.
USTR published its final action on July 23, 2026, imposing Section 301 tariffs on 60 trading partners. CBP confirmed implementation the same day in CSMS #69326983. This is not a general tariff drop — it replaces the expiring 10% surcharge with a higher, uncapped, no-expiration duty. The new import taxes will cover over 99 percent of imports into the United States market starting Friday.
Who's affected
The new duties apply to most products classified in Chapters 1-97 of the HTSUS from the identified countries and economies.
The action includes imports from countries such as Canada, Mexico, China, India, Vietnam, the European Union, the United Kingdom, Japan, South Korea, Taiwan, and Switzerland, among others. Direct importers, FTZ operators, and e-commerce sellers sourcing from these origins are all exposed. Each country (or economy) has its own additional Harmonized Tariff Schedule (HTS) number. The tariffs apply to all goods of a country unless exempt.
Cost impact
As of 12:01 a.m. EDT on July 24, 2026, imports from 60 designated countries and economies are subject to additional duties of 10% or 12.5%, unless specifically exempted. The rate depends on origin: 10 percent applies to economies that impose a forced labor import prohibition, have committed to one through an Agreement on Reciprocal Trade, or have imposed a partial regime; 12.5 percent is the rate for all other investigated economies. These stack. The new duties are imposed on top of existing tariffs, including MFN rates, current Section 301 tariffs on China, and any other applicable trade actions. For 12.5%-tier origins, your line moves from the old 10% surcharge to 12.5% plus MFN — a net increase, not a cut. EU, Japan, Korea, Switzerland, and Taiwan get combined-rate/threshold treatment rather than a flat add-on, so verify per-HTS.
What to do 1. Re-check each entry filed on/after 12:01 a.m. EDT July 24 for the correct Chapter 99 HTS by origin — work with your broker to ensure compliance with the new Chapter 99 reporting requirements now in effect.
2. Pull the CBP HTSUS attachment in CSMS #69326983 and confirm whether your SKUs fall in an Annex A/exempt category before assuming coverage. 3. For USMCA-origin goods from Canada/Mexico, verify your origin claim is properly documented — the exemption never applies automatically. 4. Check in-transit relief: goods loaded and in transit before 12:01 a.m. July 24 and entered before 12:01 a.m. July 28 are not subject to the additional duty.
5. Re-quote landed cost on affected SKUs at 12.5% (or 10%) plus MFN plus any China Section 301, not at the old flat 10%. 6. Preserve all Feb 24–July 23 Section 122 payment records — refund eligibility remains tied to the pending Federal Circuit appeal.
Effective dates - Section 122 10% surcharge expired → 12:01 a.m. EDT July 24, 2026 - Section 301 forced-labor duties (10%/12.5%) in effect → 12:01 a.m. EDT July 24, 2026 - In-transit exception cutoff (entered) → before 12:01 a.m. July 28, 2026 - Separate Brazil 25% Section 301 in-transit cutoff → entered before July 29, 2026 (loaded before July 22) - Patented pharmaceutical articles added to Section 232 exemption via Annex I → July 31, 2026
Sources - USTR press release: https://ustr.gov/about/policy-offices/press-office/press-releases/2026/july/ustr-takes-action-forced-labor-section-301-investigations - USTR fact sheet: https://ustr.gov/about/policy-offices/press-office/fact-sheets/2026/july/fact-sheet-ustr-section-301-action-response-failure-60-economies-ban-imports-produced-forced-labor - CBP CSMS #69326983 (guidance): https://content.govdelivery.com/bulletins/gd/USDHSCBP-421d887 - Federal Register (June 5, 2026 determinations/proposed action): https://www.federalregister.gov/documents/2026/06/05/2026-11296/notice-of-determinations-and-request-for-comments-concerning-actions-in-section-301-investigations - Thompson Hine SmarTrade (Notice of Action summary): https://www.thompsonhinesmartrade.com/2026/07/ustr-to-implement-tariffs-in-section-301-forced-labor-investigations/ - Global Trade Alert (in-transit, Annex structure): https://globaltradealert.org/blog/forced-labour-section-301-final-action
---
GIL Trade & Tariff Desk — dated, plain-English alerts on the trade rules that cost you money: what changed, who's affected, what it costs, what to do. Free while we build the archive — get every alert in your inbox the day it lands.
This alert is informational only and is not legal, customs, or trade-compliance advice. Verify current rates and rules against the linked primary sources or with a licensed customs broker before acting. Corrections: errors are corrected in-place with a dated note.