The 10% Section 122 tariff that replaced IEEPA on February 24, 2026 has a hard sunset: it expires approximately July 24, 2026 — roughly 94 days from today. The President cannot extend it unilaterally, Congress has not acted to extend it, and bipartisan appetite is uncertain with the "Reclaim Trade Powers Act" moving in the opposite direction. Meanwhile, USTR initiated Section 301 investigations on March 11, 2026 targeting 16 economies for excess manufacturing capacity and 60+ economies for forced-labor enforcement. Public comment closed April 15. Section 301 has no statutory rate cap and no time limit — which is exactly why the administration is moving it fast. This guide walks through what July 24 actually looks like for importers, how Section 301 is likely to be scoped, and the alternative authorities still on the table.
The Countdown: ~94 Days Until Section 122 Sunsets
Section 122 of the Trade Act of 1974 caps emergency tariffs at 15% and time-limits them to 150 days. Trump signed the current 10% flat tariff on February 20, 2026; it took effect February 24, 2026; and it automatically expires around July 24, 2026 unless Congress passes legislation to extend or replace it. From today (April 21), that's roughly 94 calendar days. The President cannot extend Section 122 unilaterally. Congress has not passed extension legislation, and bipartisan support is uncertain — some members have introduced the 'Reclaim Trade Powers Act' aimed at constraining presidential tariff authority rather than extending it. Treasury Secretary Bessent publicly stated on March 4 that Section 122 rates could rise to the 15% statutory maximum, though no formal proclamation has followed. Plan for the 10% being the LOW end of any realistic 2026 scenario, not the ceiling.
What Replaces It: Section 301 Investigations Already Running
On March 11, 2026, USTR initiated two new Section 301 investigations. The first targets excess manufacturing capacity in 16 economies: China, the EU, Mexico, Japan, India, Singapore, Switzerland, Norway, Indonesia, Malaysia, Cambodia, Thailand, Korea, Vietnam, Taiwan, and Bangladesh. The second targets forced-labor enforcement across 60+ economies, including the UK. Public comment periods closed April 15. USTR Ambassador Greer has publicly signaled an 'accelerated timeline' to conclude findings before Section 122 expires — which is the critical signal. Unlike Section 122, Section 301 has NO rate cap and NO time limit. Legal analysts expect the resulting tariffs to be similar in scope to the invalidated IEEPA rates — meaning country-specific rates above 10%, potentially reaching the 20–40%+ range for countries like Vietnam, Cambodia, and Bangladesh that previously faced high IEEPA rates. Section 301 is the administration's legally durable replacement for what IEEPA couldn't deliver.
Other Authorities Still on the Table
Section 301 is the main play, but it's not the only one. Section 232 investigations into pharmaceuticals, pharmaceutical active ingredients, and medical devices are ongoing and could produce new national-security tariffs in 2026 — these would stack on top of any Section 301 rates. Section 338 of the Tariff Act of 1930 is a never-used retaliatory power that allows tariffs of up to 50% on imports from countries that discriminate against US commerce; unlike Section 301, Section 338 doesn't require an investigation and could be invoked rapidly if the administration wants a dramatic response. Congressional extension of Section 122 remains technically possible but politically uncertain. The realistic July 24 scenario for importers: Section 301 rates announced before the sunset, Section 232 rates extending into new product categories, and Section 122 either lapsing or being bumped to 15% in its final weeks.
Impact by Country for the 16 Under Investigation
The 16 economies under Section 301 investigation overlap heavily with the ones that saw the biggest IEEPA relief after the SCOTUS ruling. Vietnam (was 46% IEEPA, now 10% Section 122) could see Section 301 rates pull rates back toward 20–40%+. Thailand (was 36%), Bangladesh (was 37%), Cambodia, and Indonesia are in similar territory — all saw dramatic IEEPA drops and could see Section 301 partially reverse that. Taiwan (was 32%) and South Korea (was 25%) face a different mix because Section 232 semiconductor tariffs already apply. China gets less additional impact from Section 301 excess-capacity findings because existing Section 301 tariffs (25–100%) already cover most Chinese goods. EU countries (was 20% IEEPA, now 10% Section 122) could see rates return to the 15–20% range. Mexico and Japan — the USMCA and trade-deal partners — are the countries where Section 301 is most politically fraught and where the administration has the most leverage to negotiate bilateral deals before tariffs land. For country-specific implications, see our tariff pages for each of the 16.
What Importers Should Do Before July 24
Plan for rates to stay at or above 10% after July 24 under Section 301 — the 10% Section 122 baseline is likely the LOWEST rate importers will see for the foreseeable future. Section 301 tariffs could be HIGHER than current 10% for some countries, particularly Vietnam, Cambodia, Bangladesh, and Thailand where IEEPA rates were in the 35–46% range. Practical moves: (1) Lock in pricing and contracts now while the 10% rate is known; (2) Monitor USTR announcements weekly through June for preliminary findings on the excess-capacity investigation; (3) Consider accelerating shipments before July 24 if your lead times allow — inventory at the 10% rate may be cheaper than inventory at whatever Section 301 produces; (4) Use our scenario simulator to model cost impact under different assumed Section 301 rates for your specific country-product mix; (5) Track Section 122 payments separately from other duties in your accounting so that if Section 122 is also struck down (see below), you can file for those refunds too.
Section 122 Legal Challenges
Section 122 itself is being challenged. On March 5, 2026, 24 states filed suit in the US Court of International Trade arguing that the 10% flat tariff is not applied 'consistently' as Section 122 requires — since some countries have country-specific exemptions and agreements layered on. A separate business coalition lawsuit was filed March 9. The CIT held a hearing on April 10; a ruling is pending. If Section 122 is also struck down, importers who paid the 10% flat tariff from February 24 onward could become eligible for a second round of refunds — separate from the CAPE IEEPA refunds. That's why tariff-tracking tools including GingerControl and our own calculator flag Section 122 payments as a distinct line item: if the ruling comes down, you'll want records you can file against. The combined outcome if both IEEPA (already struck) and Section 122 (pending) are invalidated: US importers will have paid $166B+ in IEEPA duties and additional Section 122 duties that could also be refundable, leaving Section 232 and Section 301 as the only durable tariff authorities.
What a Post-Section 122 World Looks Like
Three realistic scenarios for July 25, 2026. Scenario A — Section 301 lands cleanly before the sunset: rates for the 16 investigated economies jump to country-specific levels (likely 15–40% depending on country and product), Section 232 expansions add coverage for pharma and medical devices, Section 122 lapses. This is the administration's preferred outcome. Scenario B — Section 301 is delayed past July 24: Section 122 lapses and there's a short window where MFN rates apply alone, creating a narrow import-acceleration opportunity before Section 301 catches up. Scenario C — Congress extends Section 122 at 10% or 15% while Section 301 is finalized: rates hold steady while Section 301 investigations complete, then stack. For importers, Scenario A is the most likely and also the most expensive. Model all three in our scenario simulator to see which drives the highest cost for your specific product-country mix, and prioritize inventory and contract actions on that case.
Key Takeaway
Section 122 expires around July 24, 2026. Congress has not acted to extend it, and the President cannot extend it unilaterally. USTR is running Section 301 investigations into 16 economies on an accelerated timeline, with no statutory rate cap and no time limit. Plan for rates to stay at 10% minimum and potentially rise to 20–40%+ for Vietnam, Thailand, Bangladesh, Cambodia, and other countries with high pre-SCOTUS IEEPA rates. Accelerate shipments where lead times allow, lock in contracts at the 10% rate now, track Section 122 payments separately in case that authority is also struck down, and model the three realistic post-July 24 scenarios using our scenario simulator.
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