IEEPA tariffs in 2026: what changed for importers

Last updated: 2026-06-02

If your landed costs jumped in 2025 and you couldn’t trace it to a Section 301 list change, the cause may have been IEEPA. As of June 23, 2026, that is no longer the right shorthand for the broad country-level layer.

Executive Order 14389 ended a set of 2025 IEEPA tariff actions effective February 20, 2026, after the Supreme Court held that those tariff actions were unlawful. The current broad-origin layer is the Section 122 temporary import surcharge: a 10% ad valorem surcharge that began February 24, 2026 and is scheduled to run for 150 days, through July 24, 2026, unless replaced, extended, or superseded.

What IEEPA is

IEEPA — the International Emergency Economic Powers Act — is the statute the executive branch used in 2025 to impose tariffs by country, outside the older Section 301/232 framework. Two things made it different for importers:

• It was country-level, not product-level. Where Section 301 targets specific HTS lines and product lists, an IEEPA surcharge could apply broadly to a country’s exports.
• It introduced effective-date interactions — orders that started, paused, resumed, and were later terminated. The duty owed depended on the entry date.

What replaced the broad layer

For current entries, use the temporary import surcharge framework instead of assuming an IEEPA or reciprocal-tariff layer is still active. The current broad-layer formula is generally:

Base MFN + Section 301 or Section 232 if applicable + Section 122 temporary import surcharge (+ AD/CVD, + MPF/HMF)

Section 301, Section 232, AD/CVD orders, and customs fees did not disappear just because the IEEPA actions ended. They still need to be checked against the HTS code, origin, date, product scope, and any exclusions.

What to do

Do not rely on a 2025 quote, landed-cost worksheet, or supplier note that says “IEEPA” or “reciprocal” without checking the entry date. Re-check before each purchase order with the tariff calculator, which applies the measures in force on the date you run it. For the basics of how the layers add up, see tariff stacking explained.

Informational only — not customs advice. Classification and valuation decisions are the importer’s responsibility under 19 USC §1484. For declarations or binding rulings, consult a licensed customs broker.