The IEEPA era ended February 20 when the Supreme Court ruled 6–3 that the President cannot use IEEPA to impose tariffs. Since then, the administration has been rebuilding its tariff architecture on firmer legal ground — Section 122, Section 232, and now a wave of Section 301 investigations covering 86 countries. The comment window for those investigations closes April 15. Public hearings follow April 28 and May 5. For compliance and trade teams, that deadline is the most immediately actionable item on the calendar right now.
What Changed This Period
United States — 857 HTS changes on April 9: The April 2 Section 232 proclamation restructuring steel, aluminum, and copper tariffs — and announcing pharmaceutical duties up to 100% on patented imports — hit the USITC schedule on April 9. TradeFacts detected 857 changes, the largest single-night diff since launch. Key movements: 242 codes deleted from the 9903.80/81 series (product-specific Section 232 exemptions removed), 16 new codes added in the 9903.82 series (derivative copper and steel, Russia and UK provisions), and 599 modifications across Chapters 72–76 (iron, steel, aluminum). If your classification logic referenced any 9903.80 or 9903.81 exemption codes, those paths are now gone. The 9903.82 series defines the replacement framework.
Canada: No Customs Tariff amendments detected this period. Ottawa has signaled it is monitoring the US Section 301 filing environment and may respond to any tariff actions targeting Canadian goods through existing retaliatory mechanisms under CUSMA Article 32.10.
Mexico: No TIGIE changes detected. Mexico TIGIE data — 8,183 fracciones arancelarias including the January 2026 MFN rate increases across automotive, textiles, and steel — is now live in the TradeFacts API at Tier 2.
What to Watch
Section 301 investigations (86 countries, comments due April 15): USTR initiated 60+ investigations in March targeting structural manufacturing overcapacity and forced-labour supply chains. These are the mechanism being built to replace country-specific IEEPA tariffs with Section 301 authority — which survived the Supreme Court ruling. Tariffs resulting from these investigations will follow formal rulemaking with notice periods, unlike IEEPA's overnight proclamations, but the outcome for affected chapters could be at similar rate levels.
IEEPA refund process: CBP is building new ACE functionality to process IEEPA tariff refunds and expects it ready mid-April. Importers who paid duties on goods entered between April 2025 and February 24, 2026 should ensure they have documentation in order. The Court of International Trade's March 4 refund order is in effect; the government is expected to appeal but refunds are being processed.
Section 122 clock: The current 10% import surcharge (in force since February 24) runs for a maximum of 150 days, expiring approximately July 23. After that date, the legal authority lapses unless Congress acts or the administration uses a different tool. Build that date into your duty-cost models now.
One Practical Action
Audit your 9903.80 and 9903.81 code references before your next entry filing. If your classification logic, ERP configuration, or duty calculator has any hardcoded references to the Section 232 product-specific exemption codes in that series, they are now invalid in the HTS. The replacement framework is 9903.82. Separately, if you are not yet participating in the USTR Section 301 public comment process and your supply chain touches any of the 86 countries under investigation, consider filing or monitoring the docket — formal Section 301 proceedings provide a notice-and-comment window that IEEPA never did.
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