The U.S. tariff system just went through one of its most significant legal and policy resets in decades — and the dust is far from settled. If your sourcing strategy is based on assumptions from even six months ago, it may already be outdated.
Here’s what changed, what it means for manufacturers and importers, and what the next 90 days are likely to bring.
The IEEPA Ruling Changed Everything
On February 20, 2026, the U.S. Supreme Court struck down the International Emergency Economic Powers Act (IEEPA) as a valid basis for imposing tariffs. The ruling invalidated all IEEPA-based tariffs that the Trump administration had put in place since January 2025 — a sweeping set of duties that had been reshaping global supply chains for over a year.
Four days after the ruling, the administration responded by invoking Section 122 of the Trade Act of 1974, implementing a new 10% global tariff on all imports from all countries. The rate can be increased up to 15% — but Section 122 has a hard 150-day clock. Without Congressional approval, it expires on July 24, 2026.
The administration was direct about its intent: use the 150-day window to build the legal architecture for longer-term tariffs under Section 301.
New Section 301 Investigations — Launched This Week
On March 11, 2026 — this week — the Office of the U.S. Trade Representative (USTR) launched two sets of Section 301 investigations:
- Overcapacity investigations targeting 16 countries including China, the EU, Vietnam, Bangladesh, India, Mexico, Japan, South Korea, Taiwan, Indonesia, Malaysia, Cambodia, Thailand, Singapore, Switzerland, and Norway — covering sectors such as steel, aluminum, textiles, electronics, chemicals, and machinery.
- Forced labor investigations targeting 60 countries for alleged failures to prohibit the importation of goods produced with forced labor.
Written comments for both investigations are due April 15, 2026. Public hearings begin April 28. For manufacturers with supply chains touching any of these countries — which is most of them — this is a meaningful window to submit input.
Section 301 tariffs on China from 2018 remain fully in force and are unaffected by the IEEPA ruling. Section 232 national security tariffs also remain active. These two authorities now form the core of the administration’s trade enforcement toolkit.
What This Means for Manufacturers Right Now
The practical implications are immediate:
- IEEPA tariff refunds are likely available for duties paid since January 2025 — but the refund process is still being determined by the Court of International Trade. Manufacturers who paid these duties should be tracking this actively.
- The 10% Section 122 global tariff is active now. It applies broadly and stacks on top of existing Section 232 and 301 duties in many categories.
- Supply chain diversification decisions made under IEEPA assumptions may need to be re-evaluated. Countries like Vietnam, Bangladesh, and India are now under Section 301 investigation — which changes the risk calculus for sourcing shifts.
- Nearly one-third of manufacturers plan to pass tariff cost increases directly to customers. Almost half are splitting costs between price increases and margin absorption. Neither is a sustainable long-term strategy.
- Reshoring interest is rising, but execution is slow. Many companies are instead accelerating supplier diversification in lower-tariff regions as an interim response.
The Next 90 Days Are Critical
Between now and late July 2026, three things will happen that will shape the tariff environment for the next several years: the Section 122 clock runs down, the new Section 301 investigations move through hearings, and the CUSMA joint review begins in July.
Companies that treat this as a waiting period will find themselves reacting to outcomes they could have shaped. The public comment process for the Section 301 investigations is open until April 15 — manufacturers with specific supply chain exposure have a real opportunity to put industry data in front of the USTR before tariff levels are set.
The manufacturers who come out of 2026 in the strongest position will be the ones who mapped their exposure early, engaged where they could, and built supply chains flexible enough to absorb multiple outcomes.
Looking to connect with verified manufacturers across the regions reshaping global supply chains? Explore the global supplier network on Manufacturer.com — where sourcing decisions are built on real supplier relationships, not assumptions.
