Tariff Planning Checklist for US Importers After Section 122 (2026)
Short answer: As Section 122 expires July 24, 2026 and the Section 301 replacement (10–12.5%, no expiry) takes over, importers should do four things: recalculate landed cost under the new regime, check whether they're owed a refund on prior entries, watch the USMCA renegotiation for rule-of-origin changes, and set up per-HTS-code monitoring so the next change doesn't arrive as a surprise on an invoice.
1. Recalculate landed cost (this week)
- List your top HTS codes and their current Section 122 exposure.
- Re-run each under the Section 301 replacement rate + Section 232 + ADD/CVD + MFN + reciprocal + fees.
- Update your pricing/margin models with the post-cliff numbers.
2. Check refund exposure (parallel track)
- Pull entry summaries (CBP Form 7501) for the period covered by invalidated IEEPA tariffs.
- Size what you may be owed — CAPE Phase 2 opened 6/29; ~$35.46B is processing, plus interest.
- Remember: analysis and prep can be done for you, but a licensed broker files with CBP — no one else.
3. Watch USMCA (talks resume 7/20)
- Map which HTS codes claim USMCA preference.
- Monitor for rules-of-origin changes that could move those codes onto MFN or Section 301 rates.
4. Set up monitoring (ongoing)
- Track USTR, CBP, and the Federal Register filtered to your HTS codes.
- Automate landed-cost recalculation when a relevant rule changes.
Two ways we help
Refund-exposure analysis — flat fee; we prepare, a licensed broker files. Intake launching soon — join the waitlist. Or keep your numbers current with Tariff Watch — ongoing per-HTS-code monitoring + landed-cost recalculation, $199/mo (Start Tariff Watch).
Join the WaitlistSources: ttnews.com (7/2026); industrialsage.com (7/16); flexport.com (6/30); freightright.com (7/2026); autobodynews.com (7/15); cbp.gov (5/20). As of 2026-07-16. General information, not legal advice.