2025: the tariffs
| Date | Event |
|---|---|
| Feb 1, 2025 | Executive orders impose IEEPA duties on Canada, Mexico, and China. |
| Feb 4, 2025 | 10 percent duty on Chinese goods takes effect. |
| Mar 4, 2025 | Duties on Canada and Mexico take effect; China duty rises to 20 percent. |
| Mar 7, 2025 | USMCA-qualifying goods from Canada and Mexico become exempt. |
| Apr 2, 2025 | Reciprocal tariff order (Executive Order 14257) signed. |
| Apr 5, 2025 | 10 percent baseline reciprocal tariff takes effect. |
| Apr 9-10, 2025 | Country rates take effect and are paused for 90 days, except China, which rises to 125 percent. |
| May 2, 2025 | De minimis ends for goods from China and Hong Kong. |
| May 14, 2025 | China reciprocal rate cut to 10 percent. |
| May 28, 2025 | Court of International Trade rules against the IEEPA tariffs in V.O.S. Selections. |
| Aug 1, 2025 | Canada rate on non-USMCA goods rises to 35 percent. |
| Aug 6, 2025 | Additional 40 percent duty on Brazil. |
| Aug 7, 2025 | Revised country-specific reciprocal rates take effect. |
| Aug 27, 2025 | Additional 25 percent duty on India. |
| Aug 29, 2025 | Federal Circuit, sitting en banc, affirms 7-4; de minimis suspended for all countries. |
| Sep 8, 2025 | Annex II exemptions revised. |
| Nov 5, 2025 | Supreme Court hears argument. |
| Nov 10, 2025 | China opioid-related duty cut to 10 percent. |
| Nov 13, 2025 | Agricultural products exempted from the reciprocal tariff. |
2026: the ruling and refunds
| Date | Event |
|---|---|
| Feb 6, 2026 | CBP moves to ACH-only refunds. |
| Feb 20, 2026 | Supreme Court rules 6-3 in Learning Resources v. Trump that IEEPA does not authorize tariffs; IEEPA tariff orders terminated; Section 122 surcharge proclaimed. |
| Feb 24, 2026 | CBP stops collecting IEEPA duties; 10 percent Section 122 surcharge begins. |
| Mar 4, 2026 | Court of International Trade orders refunds for all importers of record (later appealed). |
| Apr 20, 2026 | CAPE Phase 1 opens. |
| May 7, 2026 | Court of International Trade strikes down the Section 122 surcharge for three plaintiffs; stayed on appeal May 12. |
| May 29, 2026 | CBP says it needs a court order to refund finally liquidated entries. |
| Early June 2026 | Government appeals orders extending refunds to importers that did not sue. |
| Jun 29, 2026 | CAPE Phase 2 opens for reconciliation-flagged entries. |
| Jul 15, 2026 | Court orders reliquidation of finally liquidated entries for importers that sued. |
| Jul 24, 2026 | Section 122 surcharge reaches its 150-day limit. |
| Aug 6, 2026 | Class certification motion argued. |
| Aug 13, 2026 | Court of International Trade upholds the IEEPA suspension of de minimis. |
| Oct 6, 2026 | CAPE Phase 3 scheduled, for importers that sued. |
What this means for importers
The date each entry was made decides which IEEPA duties it paid. See the country guides for rates by origin.
General information, not legal or customs advice. Facts last reviewed September 24, 2026. Confirm dates and options for your entries with a licensed professional.
Sources
- Federal Register: EO 14195 (Feb 7, 2025)
- Executive Order 14257 and Annex II (Federal Register, Apr 7, 2025)
- Holland & Knight: Federal Circuit strikes down IEEPA tariffs (Sep 9, 2025)
- Supreme Court opinion (Feb 20, 2026)
- Federal Register: EO 14389, Ending Certain Tariff Actions (Feb 25, 2026)
- CBP CSMS #67834313: IEEPA collection ends Feb 24, 2026
- Sullivan & Cromwell: CIT order on refunds (Mar 5, 2026)
- Skadden: trade court strikes down Section 122 tariffs (May 2026)
- Holland & Knight: File now (Jul 27, 2026)
- Mohawk Global: Phase 3 on Oct 6 (Sep 17, 2026)
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General information, not legal advice. Tariff refund rules and court rulings are changing. Deadlines depend on your own entries. Confirm your options with a licensed customs broker or attorney. TariffClarity is not a law firm or customs broker.