Your tariff stack changed again. Here's how to find your real number.

The current position

What changed, in plain terms.

• February 2026. The Supreme Court held in Learning Resources v. United States (20 February 2026) that tariffs imposed under IEEPA were unlawful. The IEEPA layer — including the surcharge that had been applied to Chinese-origin goods — came off. Refunds are being processed in phases through CBP’s refund programme, though the Court of International Trade’s nationwide refund order is under appeal, so timing is not settled. If you paid IEEPA duties, talk to your broker about your entries rather than waiting.
• February to July 2026. A 10% Section 122 balance-of-payments surcharge replaced it, applied to most imports regardless of origin. Section 122 carries a hard 150-day statutory ceiling and cannot be extended by the president alone.
• 24 July 2026. That 150 days ran out. The surcharge lapsed by operation of law at 12:01 a.m. Eastern, at the end of its statutory limit. Congress did not extend it.
• What did not change. Section 301 duties on Chinese-origin goods continue at their existing rates — a different legal authority, with no expiry date attached. Section 232 duties on steel, aluminium, copper and lumber continue, with further 232 actions under way in other categories. The de minimis exemption for low-value shipments remains closed for China and Hong Kong — every shipment pays the full stack regardless of value.
• What replaced it. Effective the same day, a new Section 301 action applies additional duties of 10% or 12.5% to imports from around sixty trading partners, subject to product and country exceptions. Unlike Section 122, Section 301 has no statutory rate cap and no expiry date. Treat it as the durable baseline rather than another temporary measure.

Why most numbers are wrong

Three places importers get the arithmetic wrong.

They model duty on the wrong value. Duty applies to the customs value, not the invoice you happen to be looking at. Assists, tooling amortisation and certain payments to third parties can be dutiable. Getting this wrong in either direction is expensive.

They forget the layers don't behave the same way. Some layers stack, some are mutually exclusive, and product-specific measures override country averages. A country-level headline percentage is a directional number, not your number.

They compare ex-works to ex-works. A factory-direct quote and an all-in delivered cost are not the same object. Add QC, consolidation, documentation, prep, and the cost of the problem nobody priced in — the one that shows up as a rejected shipment.

Levers

Five that are real, and two that aren't.

The five that are real

Classification review. Products are routinely entered under a code that is defensible but not optimal. This is the cheapest lever and the first one to pull. It requires your broker, not us — we'll flag candidates.

Consolidation. Four suppliers, four part-empty shipments, four sets of documentation. One consolidated container out of our warehouse cuts per-unit freight materially — typically the largest single saving available to a multi-supplier buyer.

Prep and labelling in China. Doing FBA prep, kitting or retail-ready packaging here rather than after arrival removes a domestic handling leg entirely, at Chinese labour rates.

Second-sourcing within China. Prices vary widely between factories for identical spec. Aggregated volume across our client base gets minimums and pricing a single buyer won't be quoted.

Dual-sourcing outside China. For some categories this is genuinely correct. We'll tell you when — including when it means less work for us.

Worked example

What we actually look at.

We are not going to publish a worked example built on invented numbers — that is precisely what makes most tariff pages worth ignoring. A real, anonymised client example is being prepared with that client's permission and will replace this section. Until it does, here is the shape of what comes back to you.

1. The scope. Product category and HS code, annual units, and how many suppliers currently ship them.
2. Before. Ex-works price, freight, duty and domestic prep, and the all-in landed cost per unit those four add up to.
3. After. The same four lines re-priced — ex-works at a second source, consolidated freight, duty at the reviewed classification, prep done in China — and the new landed cost per unit.
4. The change. The difference per unit, and as a percentage, with the assumptions written down next to it.
5. Where it came from. How much of the saving is consolidation, how much is China prep, how much is the supplier change, and how much is classification — so you can see which levers are yours to pull and which are ours.

Engagement model

How this is priced.

• Landed-cost review Part of a sourcing or procurement engagement — not sold as a standalone product.
• Second-source project Quoted per project.
• Ongoing procurement Monthly retainer based on order volume and supplier count.

WHERE THESE FACTS COME FROM

Every dated claim on this page, and how to check it.

We would rather you verified this than trusted us. Each item below is checkable at source, and we re-read them on the monthly review.

• Section 122 surcharge ended 24 July 2026. It lapsed by operation of law at the end of its 150-day statutory limit, with no extension by Act of Congress. Check the proclamation and CBP’s implementing notice.
• IEEPA tariffs held unlawful. Learning Resources v. United States, decided 20 February 2026. Refund handling runs through CBP; the Court of International Trade’s nationwide refund order is on appeal.
• Section 301 continues. A separate legal authority with no expiry date, unaffected by the IEEPA decision. A further Section 301 action took effect 24 July 2026 — check the current USTR notice for scope and rates before you model them.
• Your own numbers. Rates change; your HS codes, incoterms and supplier mix are what actually decide your landed cost. Nothing here replaces a classification from your customs broker.