U.S. 10% Tariff Update

New United States import tariffs took effect at 12:01 a.m. EST on February 24, 2026, at a uniform 10 percent ad valorem rate under Section 122 of the Trade Act of 1974. From a U.S. customs brokerage and compliance standpoint, the implementation of this new tariff measure introduces immediate operational, classification, valuation, and post-entry considerations for importers of record and their customs representatives.

The 10 percent duty is being applied as a supplemental ad valorem rate on covered imported merchandise, in addition to existing duties, fees, and other applicable trade remedies unless specifically exempted. This includes the standard Column 1 General rate of duty under the Harmonized Tariff Schedule of the United States, Merchandise Processing Fees, Harbor Maintenance Fees where applicable, and any pre-existing Section 301, Section 232, or antidumping and countervailing duties. Importers must therefore evaluate cumulative duty exposure on a line-by-line basis at the HTSUS subheading level.

From a filing perspective, brokers must ensure proper declaration of the additional tariff using the designated Chapter 99 HTSUS reporting provision issued in the corresponding Customs Bulletin notice and CSMS guidance. As with other supplemental tariffs, the Chapter 99 number must be reported in conjunction with the underlying 8 or 10 digit statistical classification. Failure to properly transmit the secondary tariff line may result in rejection at entry summary or post-entry duty bills following CBP review.

One key compliance consideration is scope. While the 10 percent rate is broadly described as a general import measure, brokers must carefully review implementing instructions for exclusions, country-specific carve-outs, and product-level exceptions. Goods qualifying under USMCA, for example, may or may not be exempt depending on how CBP interprets the interaction between preferential origin claims and Section 122 authority. Until formal clarification is issued, brokers should not assume automatic exemption based solely on free trade agreement eligibility.

Valuation becomes even more critical under a flat ad valorem regime. Because the duty is calculated as a percentage of the customs value, accurate transaction value reporting under 19 U.S.C. §1401a is essential. Importers should reexamine transfer pricing policies, assists, royalties, and any additions to value that may increase duty liability. Where related party transactions are involved, the acceptability of transaction value must be supportable under the circumstances of sale test or test values methodology. An understated customs value in this environment materially increases audit risk.

Another immediate technical issue concerns goods in transit. For shipments exported prior to the effective date but arriving after implementation, importers must review the specific “entered for consumption” and “withdrawn from warehouse” timing rules. Unless CBP has provided a grace period based on export date, the controlling factor is typically the date of entry or withdrawal for consumption. Brokers should verify entry type 01 and 11 filings to ensure the correct duty rate is applied based on the official effective timestamp.

Foreign Trade Zone admissions require special attention. Merchandise admitted into an FTZ in privileged foreign status prior to the effective date may retain the duty rate in effect at the time of admission. However, non-privileged foreign status merchandise is generally subject to the rate in effect at the time of entry for consumption. Importers operating FTZs should review status elections carefully, particularly for high-value inventory where a 10 percent differential materially affects landed cost.

Bond sufficiency is another operational concern. A sudden increase in duty outlay directly impacts continuous bond calculations, which are typically set at 10 percent of the previous 12 months’ duties, taxes, and fees, with a minimum of $50,000. Importers experiencing a sharp rise in aggregate duties may receive CBP bond insufficiency notices. Brokers should proactively model projected annualized duty exposure under the new rate to determine whether bond riders are required to avoid cargo release delays.

Drawback eligibility should also be evaluated. If the 10 percent duty qualifies as a duty eligible for substitution or unused merchandise drawback under 19 U.S.C. §1313, exporters may recover up to 99 percent of the duty paid, subject to compliance with drawback regulations. Companies with significant re-export volumes should immediately assess recordkeeping alignment between import entries and export documentation.

Post-entry strategy will become increasingly important. If legal challenges ultimately modify or invalidate the current tariff authority, importers may seek refunds through protests under 19 U.S.C. §1514 or post-summary corrections where eligible. Maintaining precise entry documentation, valuation support, and proof of payment will be essential to preserve refund rights should the regulatory landscape shift again.

From a systems standpoint, importers using automated broker interfaces or self-filing through ACE must ensure software updates reflect the new Chapter 99 provisions and duty calculations. Internal ERP landed cost modules should be recalibrated to prevent margin distortion. For companies operating on thin margins, a 10 percent across-the-board increase can materially affect pricing models, inventory turns, and customer contracts that were negotiated on pre-tariff assumptions.

The introduction of a uniform rate simplifies certain aspects of classification analysis but does not eliminate risk. Misclassification to avoid the supplemental tariff remains a high-penalty exposure area under 19 U.S.C. §1592. Brokers should exercise heightened reasonable care standards and encourage importers to obtain binding rulings where product scope is unclear.

For supply chain planning, importers may consider tariff engineering strategies such as country of origin shifts consistent with substantial transformation rules, first sale valuation where legally defensible, or alternative sourcing that remains compliant with U.S. origin marking and valuation laws. However, aggressive restructuring without legal foundation exposes companies to enforcement action.

At the operational level, cash flow impact is immediate. Duties are payable at time of entry summary filing, generally within 10 working days of release. ACH debit programs will reflect increased withdrawals, and finance departments must adjust forecasting accordingly. Importers operating on periodic monthly statements should still account for materially higher aggregate payments due on the 15th working day of the following month.

PNG is actively monitoring implementation details, including CSMS messages, Federal Register notices, and technical guidance from U.S. Customs and Border Protection. PNG is also waiting clarification from the National Association of Customs Brokers regarding interpretation of scope, interaction with free trade agreements, and recommended best practices for entry reporting.

In the near term, the priority for importers and brokers is disciplined execution: correct classification, accurate valuation, precise reporting of Chapter 99 provisions, proactive bond management, and meticulous recordkeeping. The 10 percent rate may appear straightforward, but its cumulative interaction with existing trade remedies, origin rules, and compliance obligations makes careful technical management essential.