At 12:01 a.m. EDT on July 24, 2026, the 10% Section 122 global surcharge that replaced struck-down IEEPA tariffs expires by statute. That part of last week's story was never in doubt.
What changed late this week is the replacement. USTR announced Section 301 duties of 10% or 12.5% on imports from roughly 60 economies, framed around failure to impose — or effectively enforce — bans on goods produced with forced labor. The new layer takes effect on the same morning Section 122 dies. For most supply chains covering the bulk of U.S. trade, Friday is not a clean 10% cut. It is a swap.
If your landed-cost model still says "base duty + 10% Section 122," rebuild it before the next PO cycle.
What Died, What Replaced It
| Layer | Status after July 24 |
|---|---|
| Section 122 (10% global) | Expired by statute |
| Section 301 forced-labor (10% / 12.5%) | Effective July 24 on listed economies |
| Brazil Section 301 (25%) | Already live since July 22 |
| Section 232 / AD/CVD / legacy 301 lists | Still stack where they apply |
| USMCA-compliant goods | Generally remain exempt from the new 301 layer (confirm with counsel) |
Trade counsel at firms including Baker Donelson, Honigman, and Steptoe describe the forced-labor 301 as covering the majority of U.S. trading partners — USTR has claimed coverage near 99% of U.S. trade in public comments. The 10% rate generally applies where a country has a forced-labor import ban but weak enforcement; 12.5% applies where no ban exists. Details by economy belong on your broker's matrix, not in a one-page summary.
Unlike Section 122, Section 301 has no 150-day statutory sunset. Assume it stays until USTR amends it.
The Narrow In-Transit Window
There is a limited in-transit exception: goods already loaded on the final mode of transport before July 24 may enter without the new 301 layer if they are entered for consumption before 12:01 a.m. EDT July 28.
That is a broker timing problem, not a planning strategy. If cargo was already on the water before Friday, coordinate entry. If it was not, do not invent an exception.
Three Scenarios Worth Modeling Now
Rebuild your top HTS lines against:
- MFN + existing 232/AD/CVD only — the optimistic floor for economies that somehow escape the new 301 list (rare for volume lanes).
- MFN + new forced-labor 301 (10% or 12.5%) — the working base case for most Asia and many other origins.
- MFN + Brazil 25% 301 — for Brazilian-origin goods already hit on July 22.
Then check stacking: products already under Section 232 may stay exempt from the new forced-labor 301 the same way they were under Section 122 — verify, do not assume across every HTS.
What Not to Over-Read
A composite freight index falling the same week tariffs swap is not proof that all-in costs are falling. Ocean spot can soften while duty layers reset and bunker climbs. Quote duty-inclusive landed cost, not ocean alone.
Also watch the second Section 301 track trade press keeps floating around excess capacity investigations. Forced-labor 301 is the July 24 handoff; it may not be the last 301 action of 2026.
Operational Checklist
- Ask your broker for a country-of-origin × HTS matrix with the new 10% / 12.5% flags.
- Flag any July 24–28 entries that might qualify for the in-transit exception.
- Reprice open POs that assumed a clean Section 122 drop.
- Separate ocean all-in from duty all-in in every quote so procurement sees both levers.
Where Palletizr Fits
Duty math is only half the landed-cost story. At still-elevated container rates, a half-empty 40ft can erase the savings you thought Friday's "sunset" would deliver. Use load planning to maximize cube while your trade team rebuilds the duty map — both sides of the cost stack matter this month.
For container loading optimization that reduces wasted space and prevents damage, visit palletizr.com.