Current trade landscape entering 2026

U.S. businesses are beginning 2026 operating in a trade climate reshaped by an unprecedented burst of tariff actions introduced in 2025. Those moves have altered sourcing decisions, cost bases, compliance duties, and long-term planning across nearly every sector involved in cross-border trade.

Companies now face continued policy fluidity as administrations, courts, and enforcement agencies influence the rules that govern imports. Preparing for 2026 requires understanding both the measures already in place and the legal and negotiation processes that could change them quickly.

Section 301 tariffs on imports from China and their impact

Section 301 measures remain a cornerstone of U.S. trade policy. The tariffs targeting Chinese goods, first implemented in 2018 and expanded since then, now apply to a wide range of imports.

Current rates span from 7.5% to 25%, with certain categories subject to duties as high as 50% or even 100%. Throughout 2025, the administration signaled a readiness to increase those rates further, citing earlier findings on forced technology transfer. Because changes can be announced quickly via the Federal Register, companies often have limited time to adjust contracts, inventory plans, or supplier arrangements.

Section 232 expansions and derivative product challenges

Actions under Section 232 expanded markedly in 2025. Tariffs on steel and aluminum were raised to 50% that year, and the scope was widened to include derivative products.

Importers must now determine the share of steel or aluminum within complex goods covered by derivative rules and apply additional duties on that metal content. That task is frequently difficult when suppliers do not supply precise material breakdowns or when supply chains are multi-tiered, prompting more documentation requests, supplier outreach, and tariff classification reviews.

New sector investigations and broadened 232 coverage

Section 232 tariffs were extended to other commodities, including wood products and copper, while the administration opened new probes into sectors such as:

• semiconductors
• pharmaceuticals
• commercial aircraft
• robotics
• industrial machinery
• critical minerals

Each inquiry includes a public comment period, but implementation timetables remain short, meaning markets can be affected quickly once measures are adopted.

IEEPA measures, Liberation Day duties, and legal contention

The International Emergency Economic Powers Act (IEEPA) provided the basis for some of 2025’s most sweeping changes. Fentanyl-related tariffs imposed under IEEPA applied 20% duties on goods from China and Hong Kong and 25% duties on non-USMCA imports from Canada and Mexico, with certain carve-outs for some Canadian energy shipments.

In April 2025, the IEEPA “Liberation Day” measures established a 10% global baseline duty plus a set of country-specific reciprocal tariffs ranging from 11% to 70%. Some of the highest reciprocal rates are paused while bilateral talks continue, but the administration has indicated it may rely on IEEPA more aggressively if negotiations fail to produce desired concessions.

Several legal challenges to IEEPA authority are underway, and although appeals have proceeded through the system, these tariffs have remained in effect and are now under consideration by the U.S. Supreme Court.

Layered tariffs and shifting federal guidance

By mid-2025 the U.S. tariff regime had become a complex overlay of overlapping and frequently changing duties. Federal agencies issued guidance to explain which measures could be stacked and which were mutually exclusive, but those interpretations changed multiple times.

As a result, importers repeatedly revisited product classifications, tariff-mapping tools, and duty calculations to stay current with evolving requirements and to avoid surprise liabilities.

CBP enforcement intensification and inspection focus

U.S. Customs and Border Protection strengthened enforcement in response to concerns about circumvention. The agency expanded inspections of shipments from countries commonly associated with transshipment risk, including:

• Vietnam
• Thailand
• Malaysia
• Indonesia
• Mexico

CBP also stepped up scrutiny of valuation methods, origin declarations, and the use of shell companies intended to mask routing. For many importers, the threat of compliance findings became nearly as consequential as the tariffs themselves, leading firms to conduct internal audits, upgrade controls, and bolster documentation across global supply chains.

Corporate strategies to manage tariff exposure

To handle cost volatility and potential further changes, companies increasingly build multiple tariff scenarios into pricing, budgets, and customer strategies. Common approaches include forward purchasing and creating specific inventory buffers to hedge against expected increases or regulatory shifts.

Use of U.S. Foreign-Trade Zones (FTZs) expanded as well. Storing merchandise in an FTZ allows firms to defer duties until goods enter U.S. commerce and avoid duties, taxes, and fees if the goods are re-exported—providing cash-flow advantages and greater flexibility in allocating inventory in response to tariff developments.

Industry engagement and legal monitoring

Engagement with trade associations and advocacy networks became a central part of companies’ trade strategies. Such participation helps businesses respond in a coordinated way and stay informed about fast-moving issues.

When regulatory opportunities arise—such as public comment periods during Section 232 investigations—businesses can help shape the administrative record. Many organizations are also tracking litigation over tariff authority and assessing whether to support legal efforts aimed at clarifying or limiting executive powers.

Congressional debate and legislative prospects

Congress continues to consider proposals that could reshape long-term tariff authority. Procedural limits in the House slowed consideration of measures to unwind national emergencies, and work on major items such as the fiscal year 2026 budget has delayed broader debate, which is expected to resume in 2026.

Any statutory changes would take time to implement, but the discussions themselves indicate the overall policy framework remains unsettled. Some lawmakers are weighing proposals to incorporate certain recently imposed tariffs into the formal U.S. tariff schedule to provide more predictability and longer notice periods for businesses.

What to expect in 2026 from courts, negotiations, and enforcement

Policy outcomes in 2026 will be driven by a mix of ongoing bilateral and multilateral negotiations, court rulings, and enforcement priorities. Country-by-country agreements with the E.U., Japan, South Korea, India, Canada, and Mexico could alter reciprocal tariff rates or create more granular commodity- and origin-specific rules.

Court decisions may clarify the scope of executive authorities under IEEPA or the National Emergencies Act. Even if certain authorities are constrained, the administration has signaled interest in alternative legal paths, so a quick return to predictability is unlikely.

Enforcement by CBP will remain a focal point, with continued emphasis on validating origin claims, detecting circumvention, reviewing valuation practices, and examining supply-chain routing. Firms with robust controls, transparent supplier relationships, and current classification practices will be better positioned.

USMCA joint review and its implications for North American supply chains

The first six-year joint review of the U.S.–Mexico–Canada Agreement begins on July 1, 2026. That review will determine whether the agreement continues beyond 2036 and whether any party seeks changes to the terms.

In preparation, the U.S. initiated public consultations on Sept. 17, 2025, including opportunities for written comments and a public hearing held from Dec. 3 to Dec. 5, 2025. After reviewing submissions, the administration will prepare a report to Congress outlining proposed actions, and the U.S. Trade Representative will decide whether to confirm renewal during the July 2026 meeting.

Likely topics include the automotive rules of origin, North American steel usage requirements, and sector-specific disputes in areas such as energy and agriculture. The review is a major planning milestone for firms with integrated North American supply chains and may introduce additional uncertainty during negotiations.

Preparing for lasting structural change

Businesses should plan for a tariff landscape that has changed structurally as a result of 2025 actions. A return to pre-2025 conditions appears unlikely in the near term, even though the specific configuration of duties may continue to shift.

Many policymakers emphasize bolstering domestic manufacturing, treating tariffs as a tool to advance that objective. Firms should therefore prepare for the possibility that elevated tariff levels remain part of the trade environment for the foreseeable future and invest in resilient sourcing, flexible tariff-mapping, and strong supply-chain documentation.

Contact for further information

Melissa Irmen is director of advocacy at the National Association of Foreign-Trade Zones (NAFTZ). She can be reached at [email protected].