reference·22 min read

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

Timeline of major U.S. tariff actions (IEEPA, Section 122, Section 232, Section 301) with refund implications and practical notes for importers.

By Jayson M.··Updated May 8, 2026

Informational only — not legal advice.

Between early 2025 and May 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. Section 232, Section 301, 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)

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 May 8, 2026 (based on the sources linked in this page):

  • IEEPA tariffs: held invalid by the Supreme Court; CBP ended collection; CBP announced CAPE Phase 1 for eligible IEEPA refunds in ACE beginning April 20, 2026; refunds remain procedural and entry-specific, not automatic.
  • 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.
  • Section 232: not affected by the IEEPA decision; new proclamations effective April 6, 2026 raised metals rates to 50% and added new pharma tariffs.
  • Section 301: not affected by the IEEPA decision; two new investigation packages opened March 2026 (60-economy forced labor + 16-economy excess capacity); hearings scheduled April–May 2026; no HTS code assignments yet.
  • 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; 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:

AuthorityWhat it is (plain English)Status as of May 8, 2026Where it usually shows up in documents
IEEPA (50 U.S.C. § 1701 et seq.)Emergency statute used as the basis for 2025–2026 import duties (reciprocal + fentanyl/border and related orders)Supreme Court held IEEPA does not authorize tariffs; CBP ended collectionOften visible as Chapter 99 lines on Form 7501 / ACE entry summary data (plus carrier/broker “tariff” invoicing)
Section 122 (19 U.S.C. § 2132)Temporary import surcharge tied to balance-of-payments statuteBegan Feb 24, 2026; Proclamation No. 11012 declared invalid by CIT on May 7, 2026; injunction/refund relief limited to importer plaintiffs unless later guidance or orders broaden operational treatmentCBP guidance uses the 9903.03.* Chapter 99 family
De minimis (19 U.S.C. § 1321)Duty-free treatment for low-value shipments (a process, not a “rate line”)Suspended; IEEPA-based suspension challenged at CIT (Detroit Tractor Parts)Often changes the entry workflow/type more than “a single Chapter 99 line”
Section 232National-security tariffs (sector-specific; longstanding)Still in effect; new proclamations effective April 6, 2026 raised metals to 50% and added pharma tariffsOften visible as Chapter 99 lines (varies by action/sector)
Section 301USTR trade-remedy tariffs (China-focused regime; longstanding)Still in effectOften visible as Chapter 99 lines (commonly in the 9903.88 series for China remedies)
AD/CVDAntidumping/countervailing duties (case-based)Still in effectOften appears as AD/CVD duty types with case identifiers; sometimes easiest to see in ACE/broker exports

Timeline (2025-2026)

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

DateWhat happenedAuthority laneWhy it mattered (practical)
Feb 1, 2025First IEEPA duty orders (Canada / Mexico / China). (Canada, Mexico, China)IEEPALaunch of a new duty regime that later became the refund target.
Mar 24, 2025“Venezuelan oil” tariff action. (White House action)IEEPA (tariff action)Example of how IEEPA was used for tariff measures beyond a single “reciprocal” headline.
Apr 2, 2025Reciprocal tariff program announced. (White House action)IEEPACreated the “baseline + country-specific” structure importers later had to unwind entry-by-entry.
Apr 9, 2025Reciprocal program modified. (White House action)IEEPARate mechanics became dynamic (suspensions/retaliation framing), increasing the need for document-based confirmation.
Apr 29, 2025Amendments to automobile / auto parts tariff action. (White House action)Section 232Illustrates: other tariff authorities continued on separate tracks.
May 28, 2025Trial court decision holding IEEPA tariffs unlawful. (CIT Slip Op. 25-66)IEEPA litigationThe issue shifted from “can this be done” to appellate posture and refund mechanics.
May 31, 2025USTR action extending certain Section 301 exclusions. (USTR press release)Section 301Section 301 remained a live, separate duty ecosystem (not impacted by the IEEPA merits decision).
Jul 30, 2025Copper tariff action. (White House proclamation)Section 232Another major non-IEEPA duty lane during the same period.
Jul 30, 2025Duty-free de minimis treatment suspended. (White House action)De minimisIncreased the number of shipments hitting formal entry/duty workflows.
Aug 29, 2025Appellate decision (en banc) affirming IEEPA tariffs unlawful. (CAFC opinion PDF)IEEPA litigationSet up Supreme Court review and the ultimate “IEEPA is not tariff authority” holding.
Jan 14, 2026Semiconductors tariff action. (White House proclamation)Section 232Reinforces: “tariff headlines” include multiple authorities and sectors.
Feb 20, 2026Supreme Court merits decision: IEEPA does not authorize tariffs on imports. (Opinion PDF)IEEPA litigationThe legal basis for IEEPA import duties collapsed; refund mechanics became the live question.
Feb 24, 2026 (12:00 a.m. ET)CBP ended IEEPA duty collection and inactivated related IEEPA HTS numbers in ACE. (CBP CSMS)IEEPA (operations)Operational cutover date/time matters for entry analysis and “what duty type was charged.”
Feb 24, 2026 (12:01 a.m. ET)CBP began collecting a Section 122 temporary surcharge (with exemptions). (CBP CSMS, White House proclamation)Section 122A new duty regime began immediately; not the same thing as “IEEPA refunds.”
Feb 24, 2026CBP stated de minimis duty-free treatment remains suspended. (CBP CSMS)De minimisClarified that the IEEPA merits ruling did not automatically restore de minimis processes.
Mar 2, 2026Appellate procedural order directing mandate to issue forthwith. (CAFC order PDF)IEEPA refund mechanicsCleared a procedural gate for post-decision proceedings to move forward.
Mar 4, 2026CIT order emphasizing importer-of-record mechanics in liquidation/reliquidation. (CIT order PDF)IEEPA refund mechanicsReinforced that “who gets the refund” can turn on entry record roles (IOR) and procedure.
Mar 5, 2026Multistate Section 122 challenge filed at the CIT. (Complaint PDF)Section 122 litigationSection 122 is being litigated on its own authority/constraints (separate from IEEPA).
Mar 6, 2026CBP tells the CIT it is developing ACE functionality to streamline and consolidate IEEPA refunds and interest payments on an importer basis, with all possible efforts aimed at readiness in 45 days. (CBP declaration PDF)IEEPA refund mechanicsIndicates CBP is planning a centralized importer-basis refund workflow rather than only entry-by-entry processing.
Mar 6, 2026CIT orders a short progress report on the IEEPA refund-process buildout by 2:00 p.m. EDT on Mar. 12, 2026. (Order PDF)IEEPA refund mechanicsShows the court is actively supervising refund-process development after the Mar. 4 order.
Mar 6, 2026Nintendo of America files a direct CIT refund complaint seeking prompt repayment of IEEPA duties with interest. (Complaint PDF)IEEPA refund mechanicsShows new importer-plaintiff refund suits are still being filed even after the Supreme Court merits decision.
Mar 9, 2026Private-plaintiff Section 122 challenge filed by Burlap and Barrel and Basic Fun. (Complaint PDF)Section 122 litigationConfirms Section 122 is being challenged by both state plaintiffs and private importers.
Mar 12, 2026CBP identifies the ACE-based refund workflow as CAPE and reports component completion estimates of 70% (Claim Portal), 40% (Mass Processing), 80% (Review and Liquidation/Reliquidation), and 60% (Refund). (CBP declaration PDF)IEEPA refund mechanicsGives importers a named workflow and concrete build-status numbers rather than only a generic 45-day target.
Mar 12, 2026CIT continues the suspension of immediate compliance and orders another short progress report by 2:00 p.m. EDT on Mar. 19, 2026. (Order PDF)IEEPA refund mechanicsShows the court is still overseeing the refund rollout week by week.
Mar 11, 2026USTR initiates Section 301 investigations into structural excess capacity and production across 16 economies. (USTR press release, fact sheet)Section 301Confirms the administration is opening a new trade-remedy lane separate from the IEEPA/Section 122 litigation.
Mar 12, 2026USTR states it launched 60 additional Section 301 investigations focused on failures to prohibit and enforce against forced-labor imports. (Fact sheet)Section 301Adds another current policy lane importers need to separate from the IEEPA refund story.
Mar 12, 2026CIT revives Detroit Tractor Parts Co. v. United States — a previously dormant lawsuit challenging the IEEPA-based de minimis suspension. (WWD/Sourcing Journal)De minimis litigationSignals the court may separately scrutinize whether revoking de minimis treatment is distinguishable from "imposing tariffs" under IEEPA — a legal theory separate from the Section 122 merits.
Mar 13, 2026State coalition (24 states) files cross-motions for summary judgment and a preliminary injunction seeking to stop collection of Section 122 duties. Private-plaintiff importers (Burlap & Barrel / Basic Fun) file parallel summary-judgment cross-motions. CIT assigns an expedited briefing schedule. (Oregon DOJ press release)Section 122 litigationBoth state and private plaintiffs are now pursuing interim injunctive relief alongside merits rulings on parallel tracks.
Mar 16–18, 2026USTR Ambassador Greer and Mexican Economy Secretary Ebrard formally launch bilateral U.S.–Mexico USMCA review discussions; a separate U.S.–Canada bilateral track opened in parallel. (USTR press release)USMCAArticle 34.7 of USMCA requires a joint review by July 1, 2026. Ambassador Greer told Congress he was "not prepared to recommend renewal without changes," signaling substantive renegotiation is likely.
Mar 17, 2026Both new Section 301 investigation packages published in the Federal Register, formally opening public comment periods: 60-economy forced-labor investigations (FR Doc 2026-05151) and 16-economy structural excess capacity investigations (FR Doc 2026-05214). Comment deadline: April 15, 2026. Hearings: April 28-29 (forced labor) and May 5-8 (excess capacity).Section 301No HTS code families or proposed tariff rates published yet in the May 8 reviewed USTR/Federal Register source set. Section 301 remains the likely replacement-authority track after the Section 122 ruling.
Mar 19, 2026CBP files second CAPE progress declaration: completion updated to 73% (Claim Portal), 45% (Mass Processing), 80% (Review and Liquidation/Reliquidation), 63% (Refund). Testing of the Claim Portal had begun; Mass Processing testing expected "within the week." (CBP declaration PDF)IEEPA refund mechanicsMass Processing lagging behind other components; testing underway on the rest.
Mar 20, 2026Judge Eaton finds CBP is making "satisfactory progress" and continues the suspension of immediate compliance. Order clarifies the refund obligation covers IEEPA duties on imports from Brazil and India; de minimis entries excluded (litigated separately). Orders a further progress report by 12:00 p.m. EDT on March 31, 2026. (CIT order PDF)IEEPA refund mechanicsTwo additional country lanes added to refund scope; court continues weekly supervision of the buildout.
Mar 27, 2026Senior Judge Richard Eaton's amended order in Atmus Filtration, Inc. v. United States (Court No. 26-01259) expands the refund scope to include finally liquidated entries — entries past the 90-day voluntary reliquidation window (19 U.S.C. § 1501) — requiring CBP to reliquidate them without IEEPA duties. Previously the order covered only unliquidated and not-yet-final entries. The order is suspended to the extent it requires immediate compliance. (CIT order PDF (via Courthouse News), Dickinson Wright summary)IEEPA refund mechanicsSignificantly widens the mandatory refund universe and forces CBP to revise CAPE's build scope to cover a third entry category — deferred to Phase 2+.
Mar 31, 2026CBP files third CAPE declaration: completion updated to 85% (Claim Portal), 60% (Mass Processing), 80% (Review and Liquidation/Reliquidation), 75% (Refund). Phase 1 scope defined: unliquidated entries plus entries liquidated within the preceding 80 days — covering approximately 63% of all entries on which IEEPA duties were paid. Finally-liquidated entries deferred to a later phase. Refunds will be electronic only (ACH via ACE Portal). (CBP declaration PDF)IEEPA refund mechanicsPhase 1 scope and limits now defined: ~37% of IEEPA duty-paying entries (finally liquidated) will not receive Phase 1 refunds. ACH-only refund method confirmed.
Apr 1, 2026Judge Eaton finds CAPE is "on track" to meet the April 20 launch date and continues the suspension of immediate compliance. Orders a final pre-launch progress report by 12:00 p.m. EDT on April 14, 2026, with a closed conference to follow.IEEPA refund mechanicsApril 20, 2026 became the operative CAPE Phase 1 launch target, later confirmed by CBP CSMS #68315804.
Apr 2, 2026Trump signs two Section 232 proclamations, both effective April 6, 2026: (1) overhauls steel, aluminum, and copper tariffs — base metals raised to 50% ad valorem (previously applied only to metal-input value of derivatives); derivatives at 15–25%; Commerce exclusion requests remain closed (shut down Feb. 10, 2025); (2) imposes new tariffs on patented pharmaceuticals and APIs — default 100% rate (effective September 29, 2026 for most companies), reduced to 20% rising to 100% over four years for companies with approved domestic onshoring plans. Generic pharmaceuticals excluded. (Metals proclamation, Pharma proclamation)Section 232Two major Section 232 regimes issued the same day. Metals restructuring affects importers of steel, aluminum, and copper products. Pharma tariffs add a significant new sector. Both are entirely separate from the IEEPA/Section 122 litigation.
Apr 6, 2026Atmus Filtration, Inc. files a notice of voluntary dismissal in CIT No. 26-01259 — the lead IEEPA refund case that had been the vehicle for CBP's CAPE progress reports.IEEPA refund mechanicsLead case dismissed; court oversight of the CAPE rollout continues under a successor case.
Apr 7, 2026Judge Eaton lifts the stay in Euro-Notions Florida v. CBP (CIT No. 25-00595) and reissues his order requiring CBP to refund IEEPA duties across all three entry categories (unliquidated, not-finally-liquidated, and finally-liquidated). Euro-Notions is now the operative lead IEEPA refund case.IEEPA refund mechanicsCourt oversight of CAPE continues uninterrupted; the lead-case transition may restart the government's deadline to appeal the scope of Judge Eaton's refund order.
Apr 10, 2026CIT three-judge panel (Judges Barnett, Kelly, Stanceu) holds approximately 3-hour oral arguments on motions for summary judgment in both Section 122 cases. The panel repeatedly questioned whether a "trade deficit" qualifies as a "balance-of-payments deficit" under the 1974 statute, and raised standing concerns about the state plaintiffs specifically. No ruling issued at argument. (International Trade Today)Section 122 litigationLater resolved by Slip Op. 26-47 on May 7, 2026.
Apr 10, 2026CBP publishes CSMS #68315804 confirming CAPE Phase 1 deployment for April 20, 2026 in the ACE Secure Data Portal. Filers submit a CAPE Declaration as a CSV (up to 9,999 entries per file) via ACE. Only the IOR or the authorized broker who filed the entries may submit. Refund timeline: 60–90 days after CAPE Declaration acceptance. Contact: IEEPARefunds@cbp.dhs.gov. (CBP CSMS #68315804, CBP IEEPA refund page)IEEPA refund mechanicsOperational details confirmed: CSV via ACE portal; IOR or filing broker only; Phase 1 covers unliquidated + recently-liquidated entries (~63% of duty-paying entries); finally-liquidated entries deferred to Phase 2; 60–90 day refund cycle.
May 6, 2026USTR publishes the second four-year review notice for the China Section 301 technology-transfer, IP, and innovation actions. Continuation-request windows run May 7-July 5, 2026 for the July 6, 2018 action and June 24-August 22, 2026 for the August 23, 2018 action. (Federal Register Doc. 2026-08806)Section 301A review step for existing China Section 301 actions, not a new Chapter 99 list. Importers should monitor continuation requests and any second-phase review notice.
May 7, 2026CIT issues Slip Op. 26-47 in the consolidated Section 122 cases and declares Proclamation No. 11012 invalid as contrary to law. The court enters a permanent injunction for The State of Washington, Burlap and Barrel, and Basic Fun, orders refunds with interest for Section 122 duties those importer plaintiffs paid before implementation, and declines a universal injunction. (CIT Slip Op. 26-47, Judgment)Section 122 litigationMajor merits ruling, but not an automatic refund instruction for all importers. Non-party importers should preserve 9903.03.* entry records and watch for stay/appeal and CBP guidance.

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.
  • 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 and leaves non-party operational treatment dependent on later 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:

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.

Sources & Verification

Last verified: 2026-05-08

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Informational only — not legal advice. RefundArrow is not a law firm, and this resource does not create an attorney‑client relationship with Himmelstein & Adkins, LLC. Tariff/refund outcomes depend on your facts, entry records, and evolving CBP/court guidance; consult qualified customs counsel for advice on your situation.

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