贸易合规 2026年3月19日 Tiago Suaid

2026年美国关税: 进口商完整指南

2026年关税格局发生了巨大变化。最高法院裁决使大部分IEEPA关税无效,最低免税额被全球取消,新的第122条关税已生效。

What Happened: The Supreme Court Ruling That Changed Everything

In February 2026, the Supreme Court ruled in Learning Resources, Inc. v. Trump that IEEPA tariffs were unconstitutional. This single decision invalidated the legal basis for most of the tariffs imposed since 2025 — an estimated $166 billion in duties collected from over 330,000 businesses.

The ruling means that importers who paid IEEPA-based tariffs may be entitled to refunds. US Customs and Border Protection is processing claims, but the process requires proper documentation and filing within statutory deadlines.

Current US Tariff Structure (March 2026)

Tariff TypeRateStatus
Section 122 Global Duty10-15%Active — expires July 24, 2026
Section 301 (China)7.5-25%Under new investigation (March 2026)
Section 232 (Steel/Aluminum)25% / 10%Active — some EU exclusions
USMCA-compliant (Mexico/Canada)0%Active — renegotiation in 2026
EU-origin goodsMFN rates (0-6%)No FTA in force
Vietnam/India/IndonesiaMFN rates + Section 122Active — under Section 301 review

The De Minimis Elimination: What It Means for Your Shipments

As of February 24, 2026, the US eliminated the $800 de minimis exemption globally. Every single import shipment — regardless of value — now requires formal customs entry with HTS classification, country of origin verification, and full duty payment.

This affects e-commerce brands, small importers, and any company that shipped individual parcels under $800 to avoid duties. The impact is massive: millions of shipments that previously cleared customs automatically now need a licensed customs broker.

Need Help Navigating 2026 Tariffs?

Our customs team provides free tariff exposure assessments. We'll analyze your HTS codes, identify savings opportunities, and handle refund claims.

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How to Claim IEEPA Tariff Refunds

  1. Gather your entry documentation: Collect all customs entry summaries (CF-7501) for shipments where IEEPA tariffs were paid. You need the entry number, date, HTS code, and duty amount for each.
  2. File a protest with CBP: Submit CBP Form 19 (Protest) within 180 days of liquidation for each entry. Include the Supreme Court ruling citation and your calculation of the refund amount.
  3. Work with your customs broker: Your customs broker or freight forwarder can file protests in bulk on your behalf. This is significantly faster and reduces the risk of errors that could delay your refund.
  4. Monitor refund processing: CBP is processing refunds in batches. Timeline varies from 30-180 days depending on volume and complexity. Your broker can track the status of each protest.

Strategies to Minimize Your Tariff Exposure in 2026

  • Proper HTS classification — Many importers overpay duties because their goods are classified under the wrong HTS code. A tariff review can often reduce rates by 5-15%.
  • Country of origin engineering — If your product has components from multiple countries, proper origin determination can qualify for preferential treatment under FTAs.
  • Foreign Trade Zones (FTZ) — Importing into an FTZ defers duties until goods enter US commerce. Goods re-exported from an FTZ pay zero duties.
  • First Sale valuation — If your supply chain has multiple sales before import (factory → trader → importer), you may use the first sale price as the customs value, reducing the dutiable amount.
  • Bonded warehousing — Store goods in a bonded warehouse and pay duties only when goods are withdrawn for domestic sale. Useful for managing cash flow.
  • USMCA and FTA utilization — Ensure you claim all available preferential tariff treatment. Many importers leave money on the table by not filing proper FTA certificates.

What's Coming Next: Section 301 Investigations in 2026

In March 2026, the US launched new Section 301 investigations targeting imports from China, Vietnam, Taiwan, Mexico, Japan, the EU, and dozens more countries. These investigations could result in new targeted tariffs within 6-12 months.

Importers should prepare by: diversifying sourcing, pre-qualifying alternative suppliers, and working with a customs broker who monitors tariff developments and can adjust classification strategies proactively.

US Tariffs 2026 FAQ

Can I get a refund for IEEPA tariffs I already paid?

Yes. The Supreme Court ruled IEEPA tariffs unconstitutional. File a CBP protest (Form 19) within 180 days of liquidation for each affected entry. Your customs broker can handle this in bulk.

What is Section 122 and how long does it last?

Section 122 of the Trade Act of 1974 allows a 150-day import duty of 10-15% on all goods. It took effect after the Supreme Court ruling and expires July 24, 2026 unless renewed or replaced.

Do USMCA goods still enter duty-free?

Yes. USMCA-compliant goods from Mexico and Canada are exempt from Section 122 duties. Proper rules of origin documentation is required.

How does de minimis elimination affect my e-commerce imports?

Every shipment now requires formal customs entry, regardless of value. You need HTS codes, country of origin verification, and a licensed customs broker. No exceptions.

Should I switch suppliers to avoid tariffs?

Possibly. A tariff engineering analysis can identify whether alternative sourcing from FTA partners, tariff-advantaged countries, or nearshoring options would reduce your total landed cost. We offer free tariff exposure assessments.

What Section 301 tariffs are still active on China?

As of March 2026, fentanyl-related tariffs on Chinese goods are at 10% (reduced from 20% under a November 2025 agreement). New Section 301 investigations launched in March 2026 could result in additional targeted tariffs.

Reduce Your Tariff Exposure Today

From HTS classification to IEEPA refund claims — our customs specialists handle it all. Get a transparent analysis within 24 hours.

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