Two Pivots in 18 Months

The U.S. tariff landscape has changed twice in less than 18 months. After President Trump's Liberation Day reciprocal tariffs in April 2025 and the China-specific IEEPA fentanyl tariffs imposed earlier that year, the U.S. Supreme Court in February 2026 ruled 6–3 that IEEPA does not authorize the President to impose such tariffs. The administration has responded by initiating new Section 301 investigations covering China and 14 other economies, signaling that tariff pressure will continue — just under different legal architecture. For U.S. importers, the practical question is not whether to plan around tariffs, but how to build a sourcing and logistics strategy resilient enough to absorb the next round of changes.

The State of Play in May 2026

• IEEPA tariffs were struck down by the Supreme Court on February 20, 2026, and the refund process opened via CBP's CAPE Phase 1 on April 20, 2026.
• Pre-2025 Section 301 tariffs on China (between 7.5% and 100% depending on category) remain in force.
• New Section 301 investigations were initiated March 11, 2026, covering China, the EU, Singapore, Switzerland, Norway, Indonesia, Malaysia, Cambodia, Thailand, Korea, Vietnam, Taiwan, Bangladesh, Mexico, Japan, and India.

The net effect: importers are processing refunds for IEEPA portions while the underlying Section 301 layer continues to apply. New Section 301 tariffs, when finalized, are expected to land at similar levels to the previous IEEPA structure.

The IEEPA Refund Window — Don't Leave Money on the Table

CBP's CAPE Phase 1, launched April 20, 2026, enables electronic filing of IEEPA tariff refund requests through the ACE Portal. Importers and brokers who paid IEEPA tariffs between February 2025 and February 2026 should:

• Audit entries paid under IEEPA tariff codes,
• File refund requests through ACE with required documentation,
• Track CBP processing timelines, expected to extend through 2026 given the volume of claims.

For high-volume importers, the refund opportunity can be material, often running into the seven figures.

The Country-by-Country Picture

Sourcing decisions in 2026 cannot be reduced to China-or-not-China. The new Section 301 investigations cover many of the destinations importers shifted to during the first wave of diversification.

The implication: no single origin is "safe." Importers need a portfolio approach.

Beyond the Tariff Line: True Cost-Out Math

Sourcing diversification looks simple on a tariff comparison sheet. In practice, importers should model:

• Tariff differential — the headline number.
• Unit production cost differential — often offsets some or all of the tariff savings.
• Logistics cost — longer ocean transit from South Asia adds USD 200–600 per FEU versus China.
• Inventory carrying cost — longer lead times require higher safety stock.
• Compliance and audit cost — new origin documentation, factory audits, CTPAT / SCAN requirements.
• Quality and ramp-up cost — new factories typically run higher defect rates for 6–18 months.

Rule of thumb: a 10-percentage-point tariff differential rarely justifies a country switch on its own. The case usually requires either a much wider differential, strategic risk reduction, or alignment with customer demands.

Logistics Implications of the New Map

• Longer ocean lanes from India and Bangladesh ( 35–45 day transit to U.S. East Coast vs. 25–30 from North China).
• Tighter container availability and equipment shortages at smaller export ports.
• New customs brokerage relationships and origin-specific HS classification challenges.
• Need for consolidation and LCL services as factory volume per location decreases.

A freight forwarder with multi-origin coverage and CBP-experienced brokerage can absorb much of this complexity.

Transshipment Compliance: The CBP Trap

The temptation to transship — moving goods of Chinese origin through a third country to claim lower duties — is dangerous and increasingly enforced. CBP applies a substantial transformation test: simple repacking, relabeling, or minor assembly does not change country of origin. CBP audits, EAPA petitions, and detention actions have intensified. Importers should document the genuine production process in the country of origin claimed, avoid any structure where Chinese inputs dominate value-added, and maintain origin certificates, bills of materials, and process documentation that can withstand audit.

A 90-Day Playbook for U.S. Importers

How Mingsung Can Help

Mingsung International Logistics provides multi-origin ocean freight forwarding from China, Taiwan, and Southeast Asia, with our own fleet operating Taiwan–Shanghai/Ningbo and Japan Inland Sea routes and partner-carrier capacity arranged on the lanes we do not sail. We support FCL, LCL, and consolidation services across multiple sourcing hubs, plus origin documentation that holds up to CBP scrutiny. When you are building a 60-30-10 portfolio, we can be the consistent operational layer underneath multiple suppliers in multiple countries.

Sources

• Tax Foundation, "Tariff Tracker: 2026 Trump Tariffs & Trade War by the Numbers"
• Trade Compliance Resource Hub, "Trump 2.0 tariff tracker" (May 2026)
• CNBC, "Trump administration launches Section 301 trade probes" (March 11, 2026)
• White House, "Ending Certain Tariff Actions" (February 2026)