The 10% Section 122 global import surcharge expires by statute at 12:01 a.m. EDT on July 24, 2026. For the full background on how Section 122 came about and what may replace it, see our earlier article: Section 122 Expires July 24: What the Section 301 Replacement Means for Importers. This checklist is a quick-reference companion for the final days before the sunset takes effect.
Before July 24
- Confirm the country of origin for every active shipment and cross-check it against all three active Section 301 tracks: the now-final 25% Brazil tariff (effective July 22), the still-pending 46-economy forced-labor proposal (10%/12.5%), and the still-pending 16-economy structural excess-capacity investigation.
- Remember duty rate is set by date of entry, not date of departure; goods currently on the water may still arrive before or after the cutoff depending on transit time.
- Confirm whether USMCA-qualifying goods from Canada or Mexico, exempt from Section 122, will retain that exemption if a Section 301 replacement action takes effect.
- Review broker instructions, purchase orders, and Incoterms now for any shipments that will cross the July 24 threshold.
What Won’t Change on July 24
- Section 232 tariffs on steel, aluminum, copper, automobiles, and semiconductors are unaffected; they sit under separate legal authority.
- Existing China-specific Section 301 tariffs from earlier proceedings remain in place regardless of what happens to Section 122.
- The Brazil 25% tariff is already final and takes effect two days before the Section 122 sunset; treat it as settled, not part of the July 24 question.
What to Watch For
- Whether USTR publishes final action on the forced-labor or structural excess-capacity investigations before, on, or after July 24.
- Whether any grace period applies to goods already in transit when a replacement action takes effect.
- Whether new Section 301 duties stack on top of existing Section 232 or China-specific Section 301 tariffs on the same goods; the default legal presumption is that they do, unless an agency states otherwise.
ASK ALBA™: Want a personalized exposure review across your import portfolio before the July 24 transition? Contact our trade compliance team.
