Tariff Update 2026: IEEPA Ends, New 15% Global Tariff Begins — What Importers Need to Know
Global sourcing strategy just shifted again.
On February 20, 2026, the U.S. Supreme Court ruled that the Administration did not have legal authority under the International Emergency Economic Powers Act (IEEPA) to impose the broad tariffs that had been in effect. The case has been sent back to lower courts for further proceedings.
While this ruling ends one chapter of tariff policy, it does not eliminate tariffs altogether. Within hours of the decision, a new tariff framework was introduced.
Here’s what that means for importers, wholesalers, and procurement teams right now.
What Changed Immediately
U.S. Customs and Border Protection (CBP) confirmed that:
• IEEPA tariffs stopped being collected at 12:00 a.m. ET on February 24, 2026
• Imports filed after that time are no longer charged IEEPA duties
However, there is currently no guidance or timeline regarding refunds for IEEPA tariffs that were already paid.
For companies that imported significant volume under IEEPA, this creates an open question around potential duty recovery and cash flow impact.
What Replaces IEEPA: Section 122
The Administration has now invoked Section 122 of the Trade Act of 1974.
Unlike IEEPA, Section 122 is specifically trade-related authority. It allows the President to temporarily impose tariffs in response to serious economic concerns. By statute, it can last for up to 150 days.
Effective 12:01 a.m. ET on February 24, 2026:
A 15% global tariff took effect on imports.
This means tariffs continue — but under a different legal foundation and with a defined time limit.
For sourcing teams, this creates both cost certainty in the near term and strategic uncertainty beyond the 150-day window.
What About IEEPA Refunds?
The Supreme Court invalidated the legal basis for IEEPA tariffs, but refunds are not automatic.
The case has been remanded to lower courts and will likely involve proceedings before the U.S. Court of International Trade (CIT). The CIT is the federal court that handles customs and international trade disputes.
Key questions now include:
• Whether refunds are owed
• Whether refunds will be automatic or require formal claims
• How refund processing would work
• Whether additional litigation will be necessary
As of today, CBP has not issued formal guidance on how previously paid IEEPA duties will be handled.
Importers should work closely with their customs brokers, trade counsel, and sourcing partners to monitor developments and preserve documentation.
Tariffs That Remain Unchanged
It is important to clarify what this ruling does not affect.
The following remain in full effect:
• Section 232 tariffs on steel and aluminum
• Section 232 tariffs on certain automobiles
• Section 301 tariffs on goods from China
• Anti-dumping and countervailing duties
• Standard tariff rates applicable to most imports
In other words, this is not a tariff reset. It is a legal shift in one category of authority.
Strategic Implications for Sourcing and Procurement
For brands and wholesalers sourcing from Asia and other global markets, this moment reinforces several critical realities:
First, tariff volatility is now structural. Legal challenges, executive authority shifts, and trade policy adjustments can materially change landed cost models within days.
Second, total cost of ownership modeling must be dynamic. Procurement teams should be running multiple cost scenarios — including expiration of Section 122 after 150 days or replacement by another measure.
Third, supplier diversification remains essential. A diversified sourcing footprint provides leverage and flexibility when tariff policy changes quickly.
Fourth, documentation discipline matters. With potential refund litigation ahead, maintaining clean import records and duty payment data is critical.
What to Watch Next
Several developments will shape the next phase:
• Lower court proceedings regarding potential IEEPA refunds
• Possible legal challenges to the new Section 122 tariffs
• Whether the 15% tariff expires after 150 days or is replaced
• Any congressional action related to tariff authority
Guidance from CBP and the courts is expected as proceedings continue.
The Bottom Line
IEEPA tariffs ended at 12:00 a.m. ET on February 24.
A 15% global tariff under Section 122 began at 12:01 a.m. ET on February 24.
Section 122 is limited to 150 days.
Refund procedures for prior IEEPA duties have not been announced.
Other major tariff programs remain unchanged.
In 2026, sourcing is no longer just about finding the right factory. It is about navigating policy, forecasting risk, and building resilient procurement strategies that can absorb sudden change.
At Flywheel Sourcing, we continue to monitor tariff developments closely and support our partners with scenario modeling, supplier diversification strategies, and landed cost analysis to help protect margins in an evolving trade environment.
Further updates will be shared as guidance becomes available.
