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

Informational only — not legal advice.

In 2025–2026, multiple U.S. tariff programs ran simultaneously under different legal authorities — IEEPA, Section 122, Section 232, Section 301, and de minimis. The Supreme Court struck down IEEPA tariffs in February 2026, but the other programs remain in effect. This timeline separates each authority lane so importers can identify which duties they paid and whether refund paths exist.

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.
• Section 301 trade remedies: remained in effect; USTR periodically updates exclusions and related mechanics.

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 March 13, 2026 (based on the sources linked in this page):

• IEEPA tariffs: held invalid by the Supreme Court; CBP ended collection; refund mechanics remain procedural and entry-specific.
• Section 122 surcharge: in effect (separate authority); challenged in new litigation.
• Section 232 / Section 301: not affected by the IEEPA decision; still part of the “normal” special-duty landscape.
• De minimis: still suspended per CBP guidance.

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

This table is meant to prevent a common mistake: treating every “tariff line” as part of the IEEPA refund story.

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.
• Section 122 duties: a different surcharge program; not part of the IEEPA merits ruling.
• 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/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.