The 10% Section 122 tariffs are set to expire at 12:01 a.m. EDT on July 24, and Congress has given no indication it intends to extend them. USTR Ambassador Jamieson Greer testified before the Senate Finance Committee on July 22 that his office expects to announce final action on its Section 301 forced labor investigation “as early as tomorrow” (July 23). As of this writing, no final action has been published, so the new tariffs remain at the proposed rates: 10% on 14 economies and 12.5% on the remaining economies under investigation. Customs can typically implement new 301 rates within about 24 hours of announcement, and depending on timing, there is a possibility of a brief gap between the 122 tariffs lapsing and the new 301 tariffs taking effect. Importers with shipments prepped for clearance or possibly ready to remove from a bonded warehouse should discuss this timing with their broker to potentially take advantage of a window with no additional duties levied.

To reiterate the economies and proposed rates:

Proposed 10%: Canada; Ecuador; Indonesia; Mexico; Pakistan; Argentina; Bangladesh; Cambodia; Ecuador; El Salvador; Guatemala; Indonesia; Malaysia; Taiwan; The European Union; and the United Kingdom.

Proposed 12.5%: Algeria; Angola; Australia; The Bahamas; Bahrain; Brazil; Hong Kong, China; Chile; Colombia; Costa Rica; Dominican Republic; Egypt; Guyana; Honduras; India; Iraq; Israel; Japan; Jordan; Kazakhstan; Kuwait; Libya; Morocco; New Zealand; Nicaragua; Nigeria; Norway; Oman; Peru; Philippines; Qatar; Russia; Saudi Arabia; Singapore; South Africa; South Korea; Sri Lanka; Switzerland; Thailand; Trinidad and Tobago; Türkiye; the United Arab Emirates; Uruguay; Venezuela; and Vietnam.

Brazil: Separately, a 25% Section 301 tariff on Brazil-origin goods took effect at 12:01 a.m. ET on July 22, per USTR’s Notice of Action published in the Federal Register on July 15. This investigation covered issues including digital trade barriers, preferential tariffs, anti-corruption enforcement, IP protection, ethanol market access, and deforestation. Beef, orange juice, aircraft and aircraft parts, and energy products are exempted. Alcoholic beverages are unfortunately subject to the new tariff.

Exemptions:  There are possible exemptions from the 301 tariffs, including UK Scotch based on a statement from President Trump at the time of King Charles III’s state visit. We are hoping that this will be included in the Section 301 announcement and will provide an update as soon as we have more information. There are other commodities that may receive exemptions and we will report as soon as available.

We’re continuing to monitor USTR’s final 301 announcement and will follow up with confirmed rates, exemptions, and effective dates the moment they’re released.