Friday, July 24, 2026, is not a normal customs calendar day. At 12:01 a.m. EDT, the 10% global Section 122 surcharge — the flat rate that replaced the struck-down IEEPA tariffs in February — expires by statute. The president cannot extend it unilaterally. Congress has not passed renewal legislation.
That sounds like a 10% cost cut for nearly every import. For many suppliers, it is not — because a separate Section 301 track may swap in 10–12.5% duties on 46 countries, and Brazil gets its own 25% Section 301 layer two days earlier.
If your team still quotes "base duty + 10%" without a scenario model, this week is when that habit gets expensive.
What Actually Dies on July 24
Section 122 was authorized for a 150-day maximum when it took effect February 24, 2026. The clock runs out July 24 — not "around late July," not "when USTR is ready."
| Element | Status as of July 16 |
|---|---|
| Section 122 (10% global) | Active until July 24, 12:01 a.m. EDT |
| Existing Section 232 | Unaffected (steel, aluminum, autos, etc.) |
| Legacy Section 301 (China lists, etc.) | Unaffected |
| MFN / preferential rates | Baseline underneath everything |
Entries cleared before the deadline keep the rate in force at liquidation. Entries after revert to whatever stack applies that morning — which is where the modeling gets messy.
Scenario A: Clean 10% Drop (Optimistic)
If no replacement action lands by Friday, many imports simply lose the 10% Section 122 layer and return to MFN + existing 232/301 only.
Who benefits most: EU-origin goods, products already on low MFN rates, and categories where Section 232 does not apply.
Reality check: The administration has signaled it does not intend to let tariff pressure disappear. Trade counsel and industry press widely expect Section 301 action on or near the same date. Treat Scenario A as the floor, not the plan.
Scenario B: Section 301 Replacement (Most Likely for Asia)
USTR opened parallel Section 301 investigations in March — one on structural excess capacity (16 economies) and one on forced-labor enforcement (60+ economies). The proposal on the table: 10–12.5% additional duties on 46 countries, including China, Vietnam, India, Thailand, Japan, and South Korea.
Unlike Section 122, Section 301 has no statutory rate cap and no fixed expiration date.
| Country bucket | Practical effect if 301 finalizes |
|---|---|
| 46 listed economies | Possible 12.5% instead of today's 10% — a net increase for some lanes |
| EU / UK (not on 46 list) | Likely clean 10% drop if no other action |
| Brazil | See Scenario C — separate track |
Action: Pull your top 20 HTS lines by spend and run landed cost at today's rate, MFN-only after July 24, and MFN + 12.5% 301. The spread between those three numbers is your decision range for PO timing this week.
Scenario C: Brazil Hits Wednesday
Before Section 122 expires, Brazil activates its own layer. At 12:01 a.m. EDT Wednesday, July 22, a 25% Section 301 tariff on Brazilian imports takes effect — the outcome of a year-long investigation into Brazilian trade practices.
If you source coffee, pulp, aircraft parts, or agricultural inputs from Brazil, July 22 is your deadline — not July 24.
How This Intersects With Ocean Freight
Tariff math and freight math are converging this week for a reason.
SCFI fell 3.28% to 3,080.31 on July 17 — the second weekly drop — as front-loading cooled ahead of the tariff cliff. Drewry's WCI also slipped 2% to $4,547 on July 16, ending its own ten-week climb. Carriers had announced July 15 FAK/GRIs in the $7,000–$8,500 range; Drewry reports many of those increases did not hold on spot.
That does not mean cheap boxes. It means landed cost is now a three-variable problem:
- Duty rate (122 sunset vs 301 replacement)
- Ocean all-in (base + surcharges that may or may not stick)
- Cube utilization (wasted space at $4,500+ WCI is still margin destruction)
A 10% duty swing on a $50,000 FOB order is $5,000. A half-empty 40ft at current Transpacific spot can waste more than that in freight alone.
CAPE Refunds: Separate Clock, Same Week
While rates are in flux, CAPE Phase 3 remains targeted around July 29 for certain finally liquidated IEEPA entries. The July 15 CIT order clarified that ~3,700 individual litigants get a reliquidation path — non-litigants still face uncertainty pending the Federal Circuit appeal.
Tariff planning and refund recovery are not the same workflow, but they share a deadline culture this month. Do not let PO urgency crowd out Phase 2 filings or 1581(i) counsel conversations on legacy entries.
Practical Checklist Before July 22
- Segment suppliers into 46-country list, Brazil, EU/other — three different math tracks.
- Model three duty scenarios per top HTS line; do not assume a headline "10% cut."
- Align with freight desk on whether July 15 surcharges stuck on your lanes (ask for all-in, not base rate).
- Time entries — Brazil July 22, global 122 July 24 — with broker lead time for ISF/entry filing.
- Maximize container utilization on whatever sails this week; duty savings do not offset shipping air.
Bottom Line
July 24 is a statutory sunset, not a guaranteed discount. For a large slice of the Asia sourcing base, the practical outcome may be 12.5% Section 301 replacing 10% Section 122 — a rate increase, not relief. Brazil shippers face a 25% layer even sooner.
Build three scenarios. Quote three numbers. Then decide whether to accelerate, hold, or reroute — with landed cost that includes the box you actually fill.