If you’ve felt like the ground keeps shifting under your supply chain this year, you’re not imagining it. Since early 2025, U.S. trade policy has moved through emergency tariff declarations, sweeping “reciprocal” duties, sector-specific actions on steel, aluminum, and semiconductors, a landmark Supreme Court ruling, and a fast pivot to new legal authorities – all in the span of about 18 months. For importers, manufacturers, and anyone managing cross-border sourcing, keeping up has become a full-time job in itself. Here’s where things actually stand, and what it means for your business.
How We Got Here
The current tariff era began in early 2025 with a series of emergency declarations invoked under the International Emergency Economic Powers Act (IEEPA), which the administration used to impose broad “reciprocal” tariffs on dozens of trading partners. By May 2025, the average applied U.S. tariff rate had climbed to roughly 27% – the highest level in nearly a century. China bore the brunt of it, with cumulative tariff rates on some goods reaching 145% to well over 190% by April 2025. India saw tariffs jump from 25% to 50% on selected items by August 2025, largely tied to its energy trade with Russia. Meanwhile, Section 232 national security tariffs layered on top of the IEEPA actions, hitting steel, aluminum, automobiles, and pharmaceuticals, and Section 301 actions continued to target specific unfair trade practices.
The Supreme Court Changes the Picture
The single biggest development came on February 20, 2026, when the Supreme Court ruled 6-3 that the president lacked the statutory authority under IEEPA to impose tariffs at all. The decision struck down the sweeping IEEPA-based tariffs, including many embedded in bilateral agreements negotiated over the prior year, and opened the door to refund claims – companies with unliquidated entries can file post-summary corrections with Customs and Border Protection, while those with already-liquidated entries are pursuing protests or claims through the Court of International Trade. That refund process is still shaking out, and disputes over who’s entitled to the money – importers of record versus downstream buyers who actually absorbed the cost are already emerging.
But the ruling didn’t end tariffs; it just changed which legal lever the administration is pulling. Within weeks, the White House began reimposing duties under alternative statutes: Section 232 for national-security-linked goods (already active on steel and aluminum), Section 122 for a balance-of-payments-based universal tariff (started at 10%, with plans to raise it to 15%), and Section 301 as a potential path back to some of the bilateral agreement tariffs. Section 201 safeguard actions and Section 338 discrimination provisions remain additional tools in reserve. Each of these carries different procedural requirements and legal limits than IEEPA did, which means the rates, the goods covered, and the timelines are all still being worked out sector by sector.
For the full, running timeline of this ruling and everything that has followed, read our tariff policy and trade updates page.
What This Means for Your Business
For companies sourcing internationally, the practical upshot is that tariff exposure hasn’t gone away — it’s just become less predictable in the short term while the administration re-anchors its authority in different statutes. That volatility is exactly why proactive tariff management matters more now than it did even a year ago: rates that applied last quarter may not apply next quarter, and the compliance mechanism behind them may change even if the rate doesn’t.
A few things matter most right now: knowing whether your goods fall under IEEPA-origin tariffs that may be refundable, understanding which Section 232, 122, or 301 actions could apply to your specific products going forward, and having a sourcing strategy flexible enough to absorb further changes without blowing up your cost structure or lead times.
Staying Ahead of It
This is precisely the ground we track for our clients. Our tariff policy and trade updates page maintains a running, chronological record of every major development — from the original 2025 emergency declarations through the Supreme Court ruling and the statutes now replacing it — so you don’t have to piece it together from a dozen different sources. Beyond monitoring, our tariff optimization services help re-route sourcing to lower-risk regions, verify USMCA compliance, accelerate material certifications, and flag exposure before it hits your bottom line.
If your supply chain has tariff exposure you haven’t fully mapped, now is the moment to do it — the rules are being rewritten in real time, and the companies that stay closest to the details are the ones that come out ahead. Visit our tariff policy and trade updates page for the full timeline or reach out to talk through what it means for your specific sourcing footprint.
Contact: info@amfasinternational.com
