Updated October 19, 2026. Facts current as of that date.

For importers who feel they can no longer keep track of what they owe, the feeling has a basis. The official record shows a pace of change with little precedent in recent decades.

One plain measure is the Harmonized Tariff Schedule (HTS), the legal list of duty rates maintained by the US International Trade Commission. Each time a rate or rule changes, the Commission publishes a new revision. According to its public release list, the 2023 schedule was revised 11 times and the 2024 schedule 10 times. The 2025 schedule was revised 32 times. The 2026 schedule reached Revision 21 on October 9, 2026, and between July 21 and September 15 alone a new revision took effect roughly every week.

Behind those revisions sits a long chain of executive orders, proclamations, agency notices and court rulings. Below is a condensed timeline built from the primary documents. It is not complete. It is meant to show the shape of the problem.

2025: the tariffs arrive in waves

February 1, 2025. The President signed three executive orders under the International Emergency Economic Powers Act (IEEPA) imposing additional duties on goods from Canada, Mexico and China, citing drug trafficking and border concerns (Executive Orders 14193, 14194 and 14195).

February 10, 2025. Proclamations 10895 and 10896 restored and expanded the Section 232 tariffs on aluminum and steel, ending country exemptions as of March 12, 2025. Section 232 of the Trade Expansion Act of 1962 lets the President adjust imports that threaten national security.

March 26, 2025. Proclamation 10908 imposed a 25 percent Section 232 tariff on automobiles from April 3, 2025, with parts to follow.

April 2, 2025. Executive Order 14257 imposed a 10 percent “reciprocal” tariff on imports from nearly all trading partners from April 5, with higher country-specific rates scheduled for April 9.

April 9, 2025. Executive Order 14266 suspended the higher country rates for 90 days for every country except China, and raised the reciprocal rate on Chinese goods to 125 percent from April 10.

May 12, 2025. Executive Order 14298 cut the reciprocal rate on Chinese goods to 10 percent from May 14, for 90 days, following talks with China.

June 3, 2025. Proclamation 10947 doubled the Section 232 steel and aluminum tariffs from 25 to 50 percent, effective June 4.

July 30, 2025. Two actions on the same day. Proclamation 10962 imposed a 50 percent Section 232 tariff on semi-finished copper products from August 1. Executive Order 14324 suspended duty-free “de minimis” treatment for low-value shipments from all countries, effective August 29, 2025.

August 2025. The Commerce Department’s Bureau of Industry and Security added 407 HTS codes to the list of steel and aluminum “derivative” products subject to Section 232 duties, effective August 18.

Fall 2025. New Section 232 tariffs followed on softwood lumber, upholstered furniture, kitchen cabinets and vanities (Proclamation 10976, effective October 14, 2025) and on medium- and heavy-duty trucks and buses (Proclamation 10984, effective November 1, 2025). Scheduled increases on furniture and cabinets, first set for January 1, 2026, were later pushed back to January 1, 2027 (Proclamation 11000).

2026: struck down, replaced, reshaped

January 14, 2026. Proclamation 11002 imposed a 25 percent Section 232 tariff on a narrow category of advanced semiconductors from January 15.

February 20, 2026. The Supreme Court ruled in Learning Resources, Inc. v. Trump that “IEEPA does not authorize the President to impose tariffs.” The same day, the President signed Executive Order 14389 ending the IEEPA tariff actions, and Proclamation 11012 imposing a temporary 10 percent import surcharge under Section 122 of the Trade Act of 1974, effective February 24. The surcharge stayed in force until it expired at 12:01 a.m. EDT on July 24, 2026, the end of the 150-day period the proclamation set. A separate order, Executive Order 14388, kept the suspension of de minimis treatment in place.

March 4, 2026. The Court of International Trade began ordering CBP to liquidate or reliquidate entries without IEEPA duties. On April 20, CBP opened its refund tool in ACE, called CAPE (Consolidated Administration and Processing of Entries).

April 2, 2026. Proclamation 11021 changed how the metals tariffs are calculated: from April 6, the Section 232 duty on aluminum, steel and copper products applies to the full customs value of the product, “regardless of metal content.” The same day, Proclamation 11020 announced a 100 percent Section 232 tariff on patented pharmaceuticals, phased in from July 31 and September 29, 2026, with generics excluded for now.

May 7, 2026. In Oregon v. United States and Burlap and Barrel, Inc. v. United States, a three-judge panel of the Court of International Trade held the Section 122 surcharge unlawful, by a 2–1 vote. The court granted relief to the named importer plaintiffs and the State of Washington, but declined to issue a universal injunction. The Federal Circuit temporarily stayed the judgment on May 12. The CIT denied the government’s own stay request on May 20, and on June 11 the Federal Circuit granted a stay pending appeal, so that relief is on hold while the appeal (Nos. 2026-1804, -1805 and -1928) continues.

June 1, 2026. Proclamation 11032 adjusted the metals tariffs again from June 8, 2026. It set a temporary 25 percent rate, through December 31, 2027, for mobile industrial equipment and machinery in a new Annex I-C, with lower rates for some trading partners. It moved agricultural equipment and certain residential heating and air-conditioning products into the 15 percent category, and lowered the threshold for counting a product’s metal as US-origin to 85 percent by weight.

July 20–24, 2026. Proclamations 11046 to 11048 imposed 50 percent duties under Section 338 of the Tariff Act of 1930 on certain Canadian alcoholic beverages, dairy products and motor vehicles. Their start date moved from August 19 to August 22 (Proclamation 11056). USTR imposed a 25 percent Section 301 tariff on goods of Brazil from July 22. And from 12:01 a.m. on July 24, the same moment the Section 122 surcharge was set to expire, USTR’s new Section 301 tariffs of 10 or 12.5 percent began applying to goods of the 60 economies it investigated over forced-labor import bans, with exemptions that include goods subject to Section 232 tariffs.

August 2026. Proclamation 11051 imposed a four-year Section 201 safeguard, in the form of a tariff-rate quota, on quartz surface products from August 15. Proclamation 11052 set a minimum-import-price program and a 15 percent Section 232 duty on polysilicon and its derivatives, both taking effect December 4, 2026. And Proclamation 11055 imposed Section 232 tariffs on drones and listed components from September 3, including a 100 percent rate on larger drones, drones with thermal imagers, docking stations and certain components.

September 8, 2026. Proclamations 11064 and 11065 changed which Canadian alcoholic beverages and motor vehicles are covered by the Section 338 duties, from September 15. Proclamations 11061 to 11063 barred certain Canadian products from import altogether, for goods imported on or after September 29. CBP said on September 28 that entries containing covered products would be rejected.

October 2026. CBP opened CAPE Phase 3 on October 6, at first only to court plaintiffs. On October 7, USTR confirmed that the 2018 Section 301 actions on China will continue. On October 8, the CIT certified a class of IEEPA importers in Freestyle World, Inc. v. United States.

What this pace does to a small importer

Each item above is a separate legal instrument, often with its own annex of HTS codes, its own effective time, its own in-transit exception and its own interaction with other tariffs. Some have applied only to part of a product’s value, or only to products of certain origins, or at different rates for countries with trade agreements. A single shipment can be affected by more than one action at once.

For a business with a compliance department, this is a workload. For a business where the owner also handles purchasing and pricing, it can be overwhelming. In a survey by the National Federation of Independent Business, a small-business advocacy group, conducted in November and December 2025 (782 responses), 95 percent of owners said they had at least some familiarity with the new tariffs, but only 60 percent were very or moderately confident they understood how tariffs affected their own business. Thirteen percent were not confident at all. When asked to rank priorities, owners put “predictable pricing of supplies” first, ahead of low prices.

The consequences of falling behind show up in reporting. NPR followed Richard Brown of Proof Culture, a two-person sneaker accessory company that Brown runs from Ohio, as he tried to claim a tariff refund in the spring of 2026. NPR reported that as replacement tariffs rolled out, his new shipments “arrived with ever-changing customs fees,” and that he spent weeks digitizing old purchase orders to document his claim. “We’re not equipped to deal with this,” he said in an audio diary he shared with the network.

Business Insider reported in May 2026 that Megan Sweeney, CEO of Pacific International Bearing, a California ball-bearing seller, spent several weeks trying to get into CBP’s ACE portal so she could claim a refund. “We never had the need to be active on the ACE portal,” she told the publication. “For a small business, the process is much more difficult with limited time and resources.”

The practical takeaway

Small and medium importers are not a niche. The Census Bureau’s 2024 profile of importing companies, released May 5, 2026, counted 240,535 identified US importers, of which 234,023 were small and medium-sized companies, defined generally as firms with fewer than 500 employees. Most of them do not have a trade lawyer on call.

What they do need is a reliable way to know, each week, what changed, whom it affects, and what date to put on the calendar, with a link to the official text. That is the gap Importer Weekly was built to fill. A few public tools make the official record easier to follow:

• The HTS release list. Each revision and its effective date is posted on hts.usitc.gov, so the schedule in force on a given entry date can be identified.
• The effective-date clause. Most new actions apply to goods “entered for consumption” on or after a specific minute, and many include exceptions for goods already in transit.
• Chapter 99 lines on the entry summary. These codes record which tariff actions were actually charged on each entry.
• The ACE Portal. An importer’s own ACE account shows its entry, liquidation and refund data directly, without relying on others to report it.

Sources

• US International Trade Commission, HTS release list (revision counts by year): https://hts.usitc.gov/reststop/releaseList
• Executive Orders 14193, 14194, 14195 (Feb. 1, 2025): https://www.federalregister.gov/documents/2025/02/07/2025-02406/imposing-duties-to-address-the-flow-of-illicit-drugs-across-our-northern-border ; https://www.federalregister.gov/documents/2025/02/07/2025-02407/imposing-duties-to-address-the-situation-at-our-southern-border ; https://www.federalregister.gov/documents/2025/02/07/2025-02408/imposing-duties-to-address-the-synthetic-opioid-supply-chain-in-the-peoples-republic-of-china
• Proclamation 10896 (steel, Feb. 10, 2025): https://www.federalregister.gov/documents/2025/02/18/2025-02833/adjusting-imports-of-steel-into-the-united-states
• Proclamation 10908 (autos): https://www.federalregister.gov/documents/2025/04/03/2025-05930/adjusting-imports-of-automobiles-and-automobile-parts-into-the-united-states
• Executive Order 14257 (reciprocal tariffs): https://www.federalregister.gov/documents/2025/04/07/2025-06063/regulating-imports-with-a-reciprocal-tariff-to-rectify-trade-practices-that-contribute-to-large-and
• Executive Order 14266: https://www.federalregister.gov/documents/2025/04/15/2025-06462/modifying-reciprocal-tariff-rates-to-reflect-trading-partner-retaliation-and-alignment
• Executive Order 14298: https://www.federalregister.gov/documents/2025/05/21/2025-09297/modifying-reciprocal-tariff-rates-to-reflect-discussions-with-the-peoples-republic-of-china
• Proclamation 10947 (50% steel and aluminum): https://www.federalregister.gov/documents/2025/06/09/2025-10524/adjusting-imports-of-aluminum-and-steel-into-the-united-states
• Proclamation 10962 (copper): https://www.federalregister.gov/documents/2025/08/05/2025-14893/adjusting-imports-of-copper-into-the-united-states
• Executive Order 14324 (de minimis): https://www.federalregister.gov/documents/2025/08/05/2025-14897/suspending-duty-free-de-minimis-treatment-for-all-countries
• BIS, Section 232 inclusions (407 HTS codes): https://www.federalregister.gov/documents/2025/08/19/2025-15819/adoption-and-procedures-of-the-section-232-steel-and-aluminum-tariff-inclusions-process
• Proclamation 10976 (timber and lumber): https://www.federalregister.gov/documents/2025/10/06/2025-19482/adjusting-imports-of-timber-lumber-and-their-derivative-products-into-the-united-states
• Proclamation 11000 (lumber amendments): https://www.federalregister.gov/documents/2026/01/09/2026-00327/amendments-to-adjusting-imports-of-timber-lumber-and-their-derivative-products-into-the-united
• Proclamation 10984 (trucks and buses): https://www.federalregister.gov/documents/2025/10/22/2025-19639/adjusting-imports-of-medium–and-heavy-duty-vehicles-medium–and-heavy-duty-vehicle-parts-and-buses
• Proclamation 11002 (semiconductors): https://www.federalregister.gov/documents/2026/01/20/2026-01052/adjusting-imports-of-semiconductors-semiconductor-manufacturing-equipment-and-their-derivative
• Supreme Court, Learning Resources, Inc. v. Trump (Feb. 20, 2026): https://www.supremecourt.gov/opinions/25pdf/24-1287_4gcj.pdf
• Executive Order 14389 (ending IEEPA tariff actions): https://www.federalregister.gov/documents/2026/02/25/2026-03832/ending-certain-tariff-actions
• Proclamation 11012 (Section 122 surcharge): https://www.federalregister.gov/documents/2026/02/25/2026-03824/imposing-a-temporary-import-surcharge-to-address-fundamental-international-payments-problems
• Executive Order 14388 (continuing de minimis suspension): https://www.federalregister.gov/documents/2026/02/25/2026-03829/continuing-the-suspension-of-duty-free-de-minimis-treatment-for-all-countries
• CBP, IEEPA duty refunds page: https://www.cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds
• Proclamation 11021 (metals on full value): https://www.federalregister.gov/documents/2026/04/09/2026-06960/strengthening-actions-taken-to-adjust-imports-of-aluminum-steel-and-copper-into-the-united-states
• Proclamation 11020 (pharmaceuticals): https://www.federalregister.gov/documents/2026/04/09/2026-06956/adjusting-imports-of-pharmaceuticals-and-pharmaceutical-ingredients-into-the-united-states
• Federal Circuit, State of Oregon v. Trump, Nos. 2026-1804, -1805, order granting stay pending appeal (June 11, 2026): https://storage.courtlistener.com/recap/gov.uscourts.cafc.24360/gov.uscourts.cafc.24360.61.0.pdf ; docket: https://dockets.justia.com/docket/circuit-courts/cafc/26-1804
• CBP, CSMS # 67844987 (Section 122 duties, through 12:01 a.m. EDT July 24, 2026): https://content.govdelivery.com/accounts/USDHSCBP/bulletins/40b3b7b
• Court of International Trade, Slip Op. 26-47 (May 7, 2026): https://www.cit.uscourts.gov/sites/cit/files/26-47.pdf ; Slip Op. 26-53 (May 20, 2026): https://www.cit.uscourts.gov/sites/cit/files/26-53.pdf
• Proclamation 11032 (metals, June 2026): https://www.federalregister.gov/documents/2026/06/04/2026-11314/further-adjusting-the-tariff-regimes-for-imports-of-aluminum-steel-and-copper-into-the-united-states
• Proclamation 11046 (Canada, Section 338): https://www.federalregister.gov/documents/2026/07/23/2026-14991/imposing-additional-duties-to-offset-canadian-discrimination-against-the-commerce-of-the-united
• Proclamation 11056 (start date moved to Aug. 22): https://www.federalregister.gov/documents/2026/08/24/2026-17294/temporary-suspension-of-additional-duties-to-offset-canadian-discrimination-against-the-commerce-of
• USTR, Section 301 action on Brazil: https://www.federalregister.gov/documents/2026/07/20/2026-14542/notice-of-action-brazils-acts-policies-and-practices-related-to-digital-trade-and-electronic-payment
• USTR, Section 301 actions on 60 economies: https://www.federalregister.gov/documents/2026/07/28/2026-15181/notice-of-actions-in-section-301-investigations-of-acts-policies-and-practices-of-various-economies
• Proclamation 11051 (quartz surface products, Section 201): https://www.federalregister.gov/documents/2026/08/05/2026-15975/to-facilitate-positive-adjustment-to-competition-from-imports-of-quartz-surface-products
• Proclamation 11052 (polysilicon): https://www.federalregister.gov/documents/2026/08/11/2026-16400/adjusting-imports-of-polysilicon-and-its-derivatives-into-the-united-states
• Proclamation 11055 (drones): https://www.federalregister.gov/documents/2026/08/19/2026-16979/adjusting-imports-of-unmanned-aircraft-systems-and-unmanned-aircraft-systems-components-into-the
• Proclamation 11061 (Canadian import exclusions): https://www.federalregister.gov/documents/2026/09/14/2026-18835/excluding-certain-canadian-products-from-importation-into-the-united-states-in-response-to-continued
• Proclamations 11064 and 11065 (Section 338 scope): https://www.federalregister.gov/documents/2026/09/14/2026-18838/modifying-the-scope-of-products-of-canada-subject-to-the-additional-duties-imposed-to-offset ; https://www.federalregister.gov/documents/2026/09/14/2026-18839/modifying-the-scope-of-products-of-canada-subject-to-the-additional-duties-imposed-to-offset
• CBP, CSMS # 70050970 (Canada exclusions guidance): https://content.govdelivery.com/accounts/USDHSCBP/bulletins/42ce49a
• CBP, CSMS # 69326983 (Section 301 forced-labor duties guidance): https://content.govdelivery.com/accounts/USDHSCBP/bulletins/421d887
• CBP declaration of Brandon Lord, ECF No. 58, Freestyle World (Oct. 6, 2026; CAPE Phase 3): https://storage.courtlistener.com/recap/gov.uscourts.cit.19175/gov.uscourts.cit.19175.58.0.pdf
• USTR, continuation of China Section 301 actions (Oct. 7, 2026): https://www.federalregister.gov/documents/2026/10/07/2026-20510/continuation-of-actions-chinas-acts-policies-and-practices-related-to-technology-transfer
• Court of International Trade, Freestyle World, Inc. v. United States, Slip Op. 26-123 (Oct. 8, 2026): https://www.cit.uscourts.gov/sites/cit/files/26-123.pdf
• NFIB, Tariff & Trade Policy Report (February 2026): https://www.nfib.com/wp-content/uploads/2026/04/2026-NFIB-Tariff-and-Trade-Policy-Report.pdf
• NPR, “He recorded his quest for tariff refunds. It shows why billions may never get repaid” (May 3, 2026): https://www.npr.org/2026/05/03/nx-s1-5805045/tariff-refunds-small-business
• Business Insider, “Getting a tariff refund has become a bureaucratic nightmare for small businesses” (May 23, 2026): https://www.businessinsider.com/businesses-face-hurdles-getting-us-tariff-refunds-forgotten-passwords-2026-5
• US Census Bureau, A Profile of U.S. Importing and Exporting Companies, 2023-2024 (release CB26-73, May 5, 2026): https://www.census.gov/foreign-trade/Press-Release/edb/edbrel2024.pdf

Tariff rules will keep moving. Subscribe free to the Importer Weekly briefing for a short, sourced summary of what changed each week and what date to watch.

For decisions about your own entries, refunds or filings, talk to your licensed customs broker or trade attorney.

General information, not legal or customs advice.