U.S. Tariff Actions Timeline (2025–2026)

Informational only — not legal advice.

Between early 2025 and June 2026, at least five different tariff programs were collecting duties at the same time - each under a different legal authority, each with different refund implications. The Supreme Court struck down IEEPA tariffs in February 2026. CBP then implemented Section 122 one minute later, and the CIT invalidated that Section 122 proclamation on May 7, 2026 with relief limited to importer plaintiffs. The government appealed, the Federal Circuit entered an administrative stay on May 12, and the CIT denied the government's separate stay request on May 20. Through this June 8 review, no new substantive Section 122 merits or refund order changed that posture. Section 232, Section 301, Section 201, USMCA, customs enforcement, and the de minimis suspension remain separate. If you are trying to figure out what you paid and whether any of it is refundable, the first step is separating which authority applies to each line on your entry.

What changed (and what did not)

If you are trying to reconcile “tariff” charges (or evaluate refund exposure), the first step is to separate which legal authority caused the duty change. In 2025–2026, multiple authorities were in play at the same time.

High-signal takeaway: the Supreme Court decision was about IEEPA tariff authority. It did not repeal other trade regimes (like Section 232 or Section 301).

What changed in 2025–2026 (the lanes)

• IEEPA import duties (2025–Feb 2026): multiple duty programs were imposed under the International Emergency Economic Powers Act (IEEPA), including “reciprocal” rates and fentanyl/border-related duties. The Supreme Court held IEEPA does not authorize tariffs on imports, and CBP stopped collecting IEEPA duties.
  • Supreme Court opinion PDF: https://www.supremecourt.gov/opinions/25pdf/24-1287_4gcj.pdf
  • CBP CSMS (ending collection): https://content.govdelivery.com/accounts/USDHSCBP/bulletins/40b11c9
• Section 122 temporary surcharge (starting Feb 24, 2026): CBP began collecting a separate temporary import surcharge under Section 122 (a different legal authority) immediately after ending IEEPA collection.
  • CBP CSMS (Section 122 implementation): https://content.govdelivery.com/accounts/USDHSCBP/bulletins/40b3b7b
  • White House proclamation: https://www.whitehouse.gov/presidential-actions/2026/02/imposing-a-temporary-import-surcharge-to-address-fundamental-international-payments-problems/
• De minimis: CBP states duty-free de minimis treatment remains suspended (this affects how many shipments enter “formally” and pay duties).
  • CBP CSMS: https://content.govdelivery.com/accounts/USDHSCBP/bulletins/40b3d6e
• Section 232 national-security tariffs: remained in effect; additional 2025–2026 proclamations adjusted coverage for certain sectors/products, including June 8 metals implementation under 9903.82.20-.26.
• Section 301 trade remedies: remained in effect; USTR periodically updates exclusions and related mechanics, including June 2026 proposed forced-labor and Brazil tariff actions, the Vietnam IP investigation, and China Board of Trade comments.

For a deeper, IEEPA-only “history book” with more litigation detail, see: /learn/ieepa-tariffs-timeline.

What stuck vs what did not (high-signal)

As of June 8, 2026 (based on the sources linked in this page):

• IEEPA tariffs: held invalid by the Supreme Court; CBP ended collection; CBP launched CAPE Phase 1 for eligible IEEPA refunds in ACE beginning April 20, 2026; refunds remain procedural and entry-specific, not automatic. CAPE acceptance is not the same thing as payment; monitor ACE reports, Entry Summary Query code 36 / CAPE, ACH/Form 4811 status, netting, offsets, and returned payments.
• Section 122 surcharge: Proclamation No. 11012 declared invalid by CIT Slip Op. 26-47 on May 7, 2026; permanent injunction and refund relief are specific to The State of Washington, Burlap and Barrel, and Basic Fun; no universal injunction. The government appealed, the Federal Circuit entered an administrative stay on May 12, and the CIT denied the government's separate stay request on May 20.
• Section 232: not affected by the IEEPA decision; April 2026 proclamations raised metals rates, added pharma tariffs, and May/June 2026 Federal Register/HTS updates added implementation detail for pharma onshoring procedures, medium/heavy-duty vehicle parts offsets, Taiwan-specific auto-part, wood-product, and civil-aircraft-component treatment, and June 8 metals headings 9903.82.20-.26.
• Section 301: not affected by the IEEPA decision; USTR proposed forced-labor duties for 60 economies, proposed Brazil tariffs, opened a Vietnam IP investigation, and requested comments on a China Board of Trade mechanism. Those June items are proposed or investigative tracks unless and until USTR publishes final HTS implementation language.
• De minimis: still suspended; the IEEPA-based suspension is being challenged separately at the CIT (Detroit Tractor Parts Co. v. United States).
• USMCA review: formal U.S.–Mexico and U.S.–Canada bilateral review tracks launched March 2026; USTR announced a May/June/July U.S.-Mexico negotiating-round sequence on May 27, 2026; Article 34.7 joint review deadline is July 1, 2026.

Authority map (how to categorize what you see on a 7501 / ACE export)

Not every “tariff” charge on your entry is an IEEPA duty — and only IEEPA duties are covered by the Supreme Court ruling. Before assuming “refund,” identify the authority behind each Chapter 99 line:

Timeline (2025-2026)

This is a “highest-signal” timeline: executive actions → CBP cutovers → court milestones → early refund mechanics.

Refund implications

Two things can be true at the same time:

1. A program can be held unlawful on the merits (IEEPA tariffs), and
2. Refunds can still require entry-by-entry procedure (and can be affected by liquidation status and who the entry shows as the Importer of Record).

1) Do not treat every “tariff charge” as IEEPA

Before you assume “refund,” separate the duty types:

• IEEPA duties (refundable target): struck down on the merits, but refunds are still procedural. CAPE acceptance, liquidation/reliquidation, Entry Summary Query code 36 / CAPE, ACH/Form 4811, netting, debt offset, and returned ACH status can all affect when cash arrives.
• Section 122 duties: a different surcharge program; not part of the IEEPA merits ruling or CAPE. The May 7 CIT judgment gives relief to the importer plaintiffs, the May 20 CIT order denied the government's stay request, and the Federal Circuit administrative stay leaves operational treatment dependent on later appellate guidance or orders.
• Section 232 / 301 / AD/CVD: unaffected by the IEEPA ruling and generally not “IEEPA refund exposure.”

2) Start with documents (because headlines do not substitute for entry records)

You usually need, at minimum, an entry list:

• entry number
• entry date/port
• what special duty lines were reported (Chapter 99 and/or duty types)
• IOR identity
• liquidation status/date (to understand deadlines)

Practical starting point: /learn/customs-documents-field-guide.

3) “Automatic refund” is not guaranteed by the merits decision

The Supreme Court decided the legal authority question. It did not publish an operational refund “one-click” workflow. Refund paths still run through customs procedure and timing rules.

If you want the operational “what to do now” version, start here:

• /learn/ieepa-refunds-start-here
• /learn/cape-refund-not-received-troubleshooting
• /learn/deadlines-liquidation-180-day-clock

4) Importer-of-record mechanics can control refund flow

Even if you paid the money economically, refunds (if and when processed) typically flow through the customs entry account to the party shown as the Importer of Record on the entry.

If you are not sure who the IOR was, or if a broker/carrier advanced duties and billed them back, treat “refund flow” as a live issue to confirm with records rather than an assumption.

If you are trying to identify what you paid

Many importers start with a “customs invoice” (carrier duty/tax invoice or broker statement). That can be a useful lead document, but the cleanest analysis usually comes from:

• Form 7501 PDFs (with continuation sheets), and/or
• ACE entry summary exports (CSV/Excel), and/or
• a broker export that includes Chapter 99 lines and duty detail.

RefundArrow note: upload what you have — including customs invoices and packets — but expect the cleanest results once you can obtain Form 7501s and/or ACE exports.

Start here: /learn/customs-documents-field-guide.

Frequently Asked Questions

What tariff programs were active in 2025–2026?

Multiple programs ran simultaneously: IEEPA duties (struck down by the Supreme Court), Section 122 temporary surcharge (began Feb 24, 2026), Section 232 national-security tariffs, Section 301 trade remedies, and suspended de minimis treatment.

Are IEEPA tariffs being collected now?

No. The Supreme Court held IEEPA does not authorize tariffs on imports, and CBP ended IEEPA duty collection on February 24, 2026. CBP announced CAPE (Consolidated Administration and Processing of Entries) Phase 1 for eligible IEEPA refunds in ACE beginning April 20, 2026. Refunds remain procedural and entry-specific — not automatic.

What replaced IEEPA tariffs?

CBP began collecting a Section 122 temporary import surcharge one minute after ending IEEPA collection on February 24, 2026. On May 7, 2026, the CIT declared Proclamation No. 11012 invalid and entered importer-plaintiff-specific injunctive and refund relief; the government appealed, and the Federal Circuit entered an administrative stay on May 12.