If you thought keeping up with U.S. customs was getting complicated in past years, welcome to 2026!
This year has brought some of the biggest changes we have seen in U.S. import regulations in a long time. Tariffs have changed, some tariffs have disappeared, new Section 301 tariffs have been introduced, Section 232 rules have been modified, de minimis treatment has changed, and new electronic filing requirements are being implemented.
And just when we think we have everything figured out, another CBP CSMS message comes out!
So, let’s make this simple.
What’s new right now in the world of customs and duties?
Here are some of the biggest changes importers and customs brokers should be watching:
1. IEEPA Tariffs & Refunds
The IEEPA tariff situation has changed significantly, and CBP is processing refunds through the CAPE system.
2. Section 301 Forced Labor Tariffs
New 10% or 12.5% Section 301 tariffs took effect July 24th, 2026, covering goods from 60 trading partners.
3. Brazil: 25% Section 301
Many products of Brazil are subject to a new 25% additional tariff.
4. Section 232
Steel, aluminum and copper tariffs continue to change, including how certain derivative products are treated and how duties are calculated.
5. De Minimis
The traditional $800 duty-free treatment is no longer something importers can automatically rely on.
6. CPSC eFiling
Mandatory CPSC electronic filing began July 8th, 2026, with additional FTZ requirements coming in January 2027.
And there’s more coming…
IEEPA Tariffs: What Happened to Them?
One of the biggest customs stories of 2026 has been International Emergency Economic Powers Act (IEEPA) tariffs.
Following the Supreme Court’s February 2026 decision that the IEEPA did not authorize President Trump to impose tariffs, the government stopped collecting those IEEPA tariffs.
Of course, since many already paid, refunds are required. That’s the more difficult part.
Refunds
CBP created the Consolidated Administration and Processing of Entries (CAPE) system to handle the refund process.
If your company paid IEEPA duties, this is not something you want to forget about.
We recommend reviewing:
- Entry numbers
- Entry dates
- Liquidation dates
- IEEPA amounts paid
- Liquidation status
- Protests filed
- CAPE refund status
- Refunds received
And, here’s another tip from MTS Logistics:
Keep your IEEPA entry report!
If you paid the tariff, you want to know exactly which entries were affected and what happened to the money.
Section 122: the 10% Tariff is Gone
The temporary 10% Section 122 import surcharge expired on July 24th, 2026.
That means this is another tariff that should not simply be carried forward into today’s entry calculations.
This is a good reminder: Always check the effective date before adding a Chapter 99 tariff.
Tariff rates and programs can change while the product, supplier, and HTS number remain exactly the same.
New Section 301 Forced Labor Tariff
Below is one of the biggest changes importers need to understand.
Effective July 24th, 2026, the U.S. Trade Representative imposed new Section 301 duties on goods from 60 trading partners based on findings concerning forced-labor import prohibitions. The additional duty is generally 10% or 12.5%, depending on the trading partner and applicable provisions.
This means your broker needs to check: Country of Origin, HTS, Chapter 99, Section 301, and Exclusions.
And don’t forget: A tariff payment does NOT make forced-labor merchandise automatically admissible.
That is where UFLPA comes into play.
UFLPA: A Tariff is Not the Same as Admissibility
This is something we want all importers to understand. There is a big difference between: “I have to pay an additional tariff” and “CBP will allow my merchandise into the United States.”
UFLPA enforcement can result in merchandise being detained or otherwise subject to enforcement based on forced-labor concerns.
So importers should know:
- Who made the product?
- Where was it made?
- Where did the raw materials come from?
- Who supplied the components?
Good supply-chain documentation is becoming more important every day.
Brazil: 25% Additional Tariffs
Brazil is another country importers need to watch closely.
A new 25% Section 301 tariff applies to many products of Brazil, subject to specific exemptions and special provisions.
For a Chapter 99 reminder: remember 9903.05.01.
But don’t stop there! Depending on the merchandise, Brazilian goods could potentially have:
- Brazil Section 301
- Forced Labor Section 301
- ADD/CVD** (normal duty)
The exact treatment depends on the product and applicable exclusions.
Here’s another tip from MTS Logistics:
Never tell a customer: “Brazil is 25%.” Instead, say: “Let’s check the HTS and applicable Chapter 99 provisions.” That’s the safer answer given all of the specifics and changes.
Canada: Another New Tariff to Watch
Canada has also seen new tariff actions under Section 338.
Certain Canadian products can be subject to an additional 50% duty, while specific products and categories have different treatment or exclusions.
This is another situation where the answer isn’t simply: Canada = 50% tariffs. The actual HTS classification, product type and applicable Chapter 99 provision must be reviewed.
And of course, don’t forget to check USMCA eligibility where applicable.
Section 232: Still One of the Biggest Headaches
If you work in customs, you already know: Section 232 is not going away anytime soon. The rules surrounding steel, aluminum and copper have continued to evolve.
The current framework includes:
- Steel
- Aluminum
- Copper
- Derivative products
- Special treatment for certain industrial equipment
- Country-specific provisions
- Different Chapter 99 reporting requirements
The June 2026 proclamation continued to modify the Section 232 tariff structure, including a 50% rate on certain metal products, 25% on certain predominantly metal derivatives, and a temporary 15% rate for certain fixed industrial machinery and power equipment.
This next part is important. Don’t assume: “The product contains steel, therefore 232 applies.”
You need to determine:
- What is the product?
- What is the HTS?
- Is it a derivative?
- What is the metal content?
- What Chapter 99 provision applies?
- Are there exemptions?
- Does another tariff stack?
CBP’s current Section 232 guidance should be checked before filing.
CPSC E-Filing: Already in Effect
Another major change that isn’t technically a tariff but is very important to customs brokers: CPSC e-filing became mandatory July 8th, 2026.
Covered consumer products now require electronic certificate information through the CBP ACE/PGA process.
Information can include:
- Product identification
- Certifying party
- Applicable safety requirements
- Manufacturing information
- Testing information
- Testing location
- Recordkeeping information
For FTZ Importers, we suggest you mark your calendars.
For applicable FTZ merchandise: starting January 8th, 2027, CPSC e-filing will also apply to qualifying FTZ withdrawals.
If you have an FTZ customer, don’t wait until January 2027 to figure this out.
What’s Coming Next?
Now let’s look ahead towards the rest of 2026 and into early 2027.
1. Polysilicon and Solar Products
A new Section 232 action involving polysilicon and certain derivative products is coming. On December 4th, 2026, certain covered products are expected to be subject to a 15% tariff along with additional requirements.
If you have customers importing solar or semiconductor-related materials, this should be reviewed before December 2026.
2. Sugar Importers: October 1st, 2026 is an Important Date
Sugar importers should have October 1st, 2026, on their calendar. That’s the beginning of the FY2027 sugar TRQ year. The FY2027 WTO raw cane sugar allocation is: 1,117,195 metric tons, raw value.
There are also allocations for refined sugar and sugar-containing products.
Here’s a tip from MTS Logistics:
If you have sugar customers, make sure your quota procedures are ready before October 1st, 2026.
CBP is Looking More Closely at Supply Chains
This is something we expect to become even more important. Importers should be prepared to provide accurate information about the following components of their supply chains:
- Manufacturer
- Factory
- Country of Origin
- Raw Materials
- Components
- Supplier
- Purchase Price
- Related Parties
- Transportation
- U.S. Importer
Customs is increasingly focused on:
- Transshipment
- Country-of-origin accuracy
- Duty evasion
- Forced labor
- Valuation
- Importer information
- Supply-chain transparency
In simple terms: Know your supplier, know your manufacturer, and know where your product is really coming from, in order to be prepared.
The Biggest Takeaway
If there is one thing we want every importer to remember, it is this: Don’t assume yesterday’s tariff treatment is today’s tariff treatment.
The U.S. tariff system has become much more complicated. One shipment could potentially involve:
- Section 232
- Section 301
- Forced Labor
- ADD/CVD** (normal duty)
At the same time, another shipment with a similar product could have completely different treatment because of the country of origin, HTS number, product composition, exemption, trade agreement, or effective date.
That is why Chapter 99 is now just as important as Chapter 1–97 when reviewing an entry.
99A final tip from MTS Logistics
2026 has definitely kept all of us in customs on our toes!
The best way to stay ahead is to keep your tariff information updated, communicate with your customers, review Chapter 99 carefully, and always verify the effective date before filing.
The only thing worse than a new tariff is finding out about the new tariff AFTER the entry has already been filed! So, stay informed, stay organized, check the HTS, review Chapter 99, and when in doubt, check again.
