By: Brian Walczyk, Compliance Manager, TradeInsights, LCB, CCS

V. Alexander & Co., Inc. continues to monitor the developing IEEPA & Section 122 tariff announcements and has compiled the below information relevant to each.

IEEPA

• CSMS # 67834313: IEEPA tariffs will no longer be collected by US CBP for “goods entered for consumption or withdrawn from warehouse for consumption, on or after 1200 AM EST on February 24, 2026.”

• Refunds for IEEPA tariffs are pending instruction/decision from the Court of International Trade.

Section 122

• President Trump issued a Proclamation for the implementation of Section 122 Tariffs on February 20, 2026.

• Section 122 tariffs are set to be effective for “goods entered for consumption or withdrawn from warehouse for consumption, on or after 1201 AM EST February 24, 2026.” We are pending final guidance on the implementation for this effective date – which will likely be published by US CBP via CSMS in short order.

• Section 122 tariffs in the Proclamation are listed at 10%, but President Trump issued a statement on social media that the tariff will be 15% – seen here. We are pending final guidance from US CBP and the Administration for exact implementation of Section 122.

• An in-transit exemption for Sec 122 does exist and must meet both criteria to be applied: (1) loaded onto the vessel destined for the US port, and in transit, before 1201 AM EST Feb 24, 2026, and (2) entered for consumption, or withdrawn from warehouse for consumption, before 1201 AM EST Feb 28, 2026.

• Section 122 tariffs will not stack with Section 232 tariffs. “To the extent a tariff imposed under section 232 applies to part of an import, the surcharge imposed in [Section 122] shall apply to the part of the import to which section 232 tariffs do not apply but shall not apply to the part of the import to which section 232 tariffs do apply.”

• Specific products are excluded from Section 122 as seen in paragraph 2 of Annex I and in Annex II.

• Section 122 will not apply to goods properly claimed under USMCA, or to textile and apparel goods properly claimed under DR-CAFTA.

Next Steps

• Formal guidance for Section 122’s implementation to be published in coming days. More details will follow with specific instructions to trade, we will publish and update once we know more!

• How does Section 122 interact with any trade agreements that were reached during the IEEPA period? This is not implicitly clear between the termination of IEEPA and implementation of Section 122.

• Importers should begin compiling ACE data for entries impacted by IEEPA in preparation for possible refund actions. Your data will be key in preparing for the eventual refunds – ask our TradeInsights team on how we can be of assistance here.

• Create open dialogue channels with your broker for post-entry preparedness. At V. Alexander we are focused on staying prepared for the future is coming – we are happy to field your questions and ease your concerns.

• Seek legal counsel where risk or exposure is high when considering filing a complaint with the CIT. While we offer professional opinion the environment may constitute the need for legal advice – we have trade attorneys we can refer if you need them.

We will continue to monitor this situation and issue updates as needed. Please contact your V. Alexander account team, or you may also contact our Trade Compliance team at tradeinsights@valexander.com with any questions, and you can always follow us on our website www.valexander.com for updates on this and other topics