At midnight on July 24, 2026, the U.S. formally imposed a new round of tariffs on 60 trading partners, replacing the 150-day global temporary tariffs previously authorized under Section 122 of the Trade Act of 1974. The new tariffs are based on findings from formal investigations, giving them greater legal resilience against legal challenges.
Tiered Rate Structure:
10% Rate: Applies to economies that have implemented or committed to implementing forced labor import bans, including Canada, the European Union, India, the United Kingdom, as well as Argentina, Bangladesh, Cambodia, Malaysia, Mexico, Pakistan, and others.
12.5% Rate: Applies to China, Japan, South Korea, Vietnam, and dozens of other countries.
Exemptions and Reductions:
Steel and aluminum products (already subject to national security tariffs under Section 232) are exempt from these new measures;
Certain energy products, fertilizers, and goods covered under the USMCA agreement are also exempt;
The EU, Taiwan, Japan, South Korea, and Switzerland may qualify for partial reductions based on prior trade agreements.
Trade attorneys note that the administration has chosen to establish a baseline tariff structure while preserving the threat of further escalation, maintaining leverage over trading partners. As Atlantic Council expert Lipsky observed: "This signals that the world's largest economy is moving toward a more protectionist stance."
Even more significant than the tariffs is Executive Order 14411, signed on June 3, 2026. Rather than imposing additional duties, this executive order targets the import regulatory system itself, strengthening enforcement at its source by restructuring the importer of record (IOR) framework.
Five Core Changes:
Dual-Track IOR Regulation: U.S.-based importers of record must meet stringent substantive domestic criteria (U.S. citizenship/permanent residency, domestic incorporation, physical place of business, and adequate tangible assets). Those failing to meet these criteria are classified as foreign-based IORs and subject to stricter restrictions.
Foreign IORs Barred from Informal Entry: Foreign-based IORs are no longer eligible for informal entry procedures; all shipments must undergo formal customs clearance. In principle, they are limited to using single-entry bonds only.
Introduction of a "Good Standing" System: A company's historical compliance record directly determines its audit frequency and market access privileges. IORs failing to maintain "good standing" status will be prohibited from importing or engaging in related activities.
Significantly Expanded Disclosure Requirements: Importers must disclose equity structures, beneficial ownership, supply chain information, product identifiers, manufacturer details, component specifications, and other comprehensive data.
Upgraded Penalty Mechanisms: Standard fines shall not be less than 50% of the assessed amount; CBP is authorized to expedite seizure and forfeiture proceedings.
Impact and Timeline: This is particularly impactful for Chinese exporters relying on DDP (Delivered Duty Paid) models or low-cost compliance clearance. The long-standing practice of using a foreign entity as the IOR will face sharply higher compliance costs and may become unsustainable. Key deadlines are September 1, 2026 (initial rulemaking publication) and November 30, 2026 (core reforms take full effect).
The EU faces multiple systemic changes in the second half of 2026:
€150 De Minimis Threshold Eliminated (Effective July 1): Low-value B2C shipments entering the EU no longer enjoy tariff exemption, and consolidated clearance applications are now substantially restricted.
CBAM Carbon Border Mechanism Fully Operational: The transitional period ended in 2025. As of 2026, importers must declare product carbon emissions and purchase CBAM certificates.
EU Deforestation Regulation (EUDR) Countdown: By December 30, 2026, medium and large enterprises must demonstrate that cattle, wood, cocoa, coffee, rubber, and derived products do not originate from recently deforested land.
Additionally, Switzerland implemented new precious metals control regulations in April; goods from brands not registered with Swiss authorities cannot be cleared. Poland has expanded its SENT system to cover clothing and footwear.
In response to rising compliance barriers overseas, China Customs has introduced a series of support measures under the 15th Five-Year Plan framework:
Simplified declaration procedures with "one registration, nationwide clearance" for highly creditworthy enterprises;
Replication of Yiwu's "inspect-before-loading" reform to address pain points in small-commodity exports;
Support for cross-border road transport with "single declaration, single permit, direct delivery";
Promotion of air cargo pre-clearance terminals integrated with comprehensive bonded zones, enabling inland enterprises to benefit from port customs facilitation;
Strengthened research on destination countries' technical standards and regulations to enhance enterprises' overseas compliance capabilities.
The keyword for the second half of 2026 is "compliance restructuring":
Reassess Your U.S. Import Structure: If you are currently using a foreign entity as the IOR for U.S. exports, evaluate before November 2026 whether transitioning to a U.S.-based IOR is feasible. Alternatives include engaging a CBP-approved customs broker or switching to FOB (Free on Board) trade terms.
Immediately Audit EU Supply Chain Compliance: Ensure that products subject to EUDR have fully traceable sources; CBAM reporting systems must be implemented concurrently.
Build a Customs Credit Management System: The U.S. "good standing" regime requires continuous compliance maintenance. Establish a standardized supply chain data disclosure framework and conduct regular internal audits.
Closely Monitor Implementing Regulations: Supporting rules for EO 14411 will be released between September and November 2026. Continuous tracking is essential.
The window of "low compliance cost" in global trade is closing. Enterprises that take the lead in restructuring their import architecture and compliance systems will secure a competitive edge in the next round of market consolidation.
