Section 122 Tariff Raised to 15%: What US Importers Need to Recalculate
# Section 122 Tariff Raised to 15%: What US Importers Need to Recalculate
The Section 122 universal import tariff is now 15% — not 10%. If you've been using the initial rate to estimate landed costs since late February, your numbers are wrong and you're likely underestimating your duty exposure by a third.
Here's what happened, what's actually in effect, and what you need to do.
What Changed
On February 20, 2026, the Trump administration announced a new universal import surcharge under Section 122 of the Trade Act of 1974, following the Supreme Court's 6-3 ruling that IEEPA does not authorize tariffs. The initial proclamation cited a 10% rate.
Two days later, on February 22, Trump raised the rate to 15% — the statutory maximum permitted under Section 122 — before the surcharge took effect. The tariff became effective February 24, 2026 at 12:01 a.m. EST and runs for 150 days, expiring July 24, 2026.
The result: most US imports from most countries now carry a 15% universal surcharge on top of existing MFN duties, Section 301 tariffs, and other charges. For many importers, this is the single largest addition to landed cost they've seen.
Who Is Exempt
Not everything is subject to the full 15%. The February 24 proclamation carves out several categories:
Countries exempt from Section 122: - Canada and Mexico (USMCA-compliant goods only) - CAFTA-DR countries (Costa Rica, Dominican Republic, El Salvador, Guatemala, Honduras, Nicaragua) for textiles and apparel
Products exempt from Section 122: - Goods already subject to Section 232 tariffs (steel, aluminum, and derivative products) — these are NOT also subject to Section 122 - Critical minerals, metals used in currency, and bullion - Energy and energy products - Pharmaceuticals and pharmaceutical ingredients - Certain electronics and aerospace products - Passenger vehicles and related components - Select agricultural items (beef, tomatoes, oranges) - De minimis shipments are no longer exempt — low-value international postal goods now face the 15% duty
The Section 232 carve-out matters a lot. Steel importers already paying 50% Section 232 tariffs do NOT also owe the 15% Section 122 surcharge. These two tariffs do not stack.
How to Calculate Your New Landed Cost
For a typical non-USMCA, non-Section 232 shipment, your total US import duty is now:
Total duty = Base MFN rate + Section 301 (if China) + Section 122 (15%)
Example 1: Consumer electronics from Vietnam - Declared value: $50,000 - HTS 8528.72 (televisions) — MFN rate: 3.9% - Vietnam: no Section 301, no Section 232 - Section 122: 15% (Vietnam is not USMCA) - Total effective rate: 18.9% - Total duty: $9,450 on a $50,000 shipment - Landed cost: $59,450
At the old 10% rate you would have calculated $6,950 in duty — a $2,500 underestimate on a single shipment.
Example 2: Apparel from Bangladesh - Declared value: $30,000 - HTS 6109.10 (cotton T-shirts) — MFN rate: 16.5% - Bangladesh: no Section 301, no Section 232 - Section 122: 15% - Total effective rate: 31.5% - Total duty: $9,450 - Landed cost: $39,450
Example 3: Steel pipe from Germany - Declared value: $100,000 - Section 232 applies at 50% - Section 122: EXEMPT — Section 232 products are carved out of Section 122 - Total effective rate: 50% (not 65%) - Total duty: $50,000
What About IEEPA Refunds?
Importers who paid IEEPA tariffs before the Supreme Court ruling may be entitled to refunds. On March 4, 2026, CIT Judge Richard Eaton ruled that all importers whose entries were subject to IEEPA duties are entitled to refunds, and CBP has been instructed to liquidate affected entries without the IEEPA duties applied.
If you paid IEEPA tariffs between January and February 24, 2026, contact your customs broker about opening protest claims. CBP is expected to have automated refund processing in place by mid-April 2026.
What's Next
The 150-day Section 122 window expires July 24, 2026, unless Congress extends it. Treasury Secretary Scott Bessent has indicated the administration intends to replace the temporary Section 122 tariffs with permanent expanded Section 301 and Section 232 coverage — so the rate may change again before expiry.
New Section 301 investigations were also opened in mid-March 2026 targeting China, the EU, Vietnam, Taiwan, South Korea, and other countries for structural manufacturing overcapacity. These investigations typically take 12–18 months before any new rates are imposed, but importers from those countries should monitor developments.
Recalculate Now
Use the FreightFigures Duty & Tariff Calculator to run your shipments at the updated 15% Section 122 rate. The calculator has been updated to reflect the current rate, the Section 232 exemption from Section 122, and all other current tariff layers. Every product category and country of origin in the tool reflects tariff policy as of March 23, 2026.
If you're relying on landed cost estimates from late February or early March, rerun your numbers — the difference between 10% and 15% is material on any significant import volume.
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