New U.S. tariff structure is emerging and USMCA is up in the air

Overview of U.S. tariff environment

The U.S. tariff environment continues to transition from short-term disruption to a more durable structure.

• While refunds of “emergency” tariffs that were declared unlawful are now moving through a phased process, timing and eligibility remain uneven as litigation continues.
• The temporary 10% Section 122 tariffs on goods from most countries are expected to expire in late July.
• They are increasingly viewed as a bridge to a new framework for Section 301 tariffs linked to unfair trade practices, which are moving quickly toward approval on goods from dozens of trading partners.
• At the same time, multiple Section 232 investigations related to national security are nearing decision points, signalling additional targeted tariffs in key industries.

Taken together, the direction is clear: Tariffs are likely to remain elevated, but under a more stable and legally durable regime that increases complexity and reinforces the importance of customs strategy and execution.

U.S. Customs deploys Phase 2 of tariff refunds

On 29 June, 2026, U.S. Customs deployed Phase 2 of refunds for tariffs that were imposed under the International Emergency Economic Powers Act then struck down by the Supreme Court. Phase 2 only covers entries flagged for reconciliation for which the reconciliation entry has not been filed. Like Phase 1, this is limited to unliquidated entries and entries within 80 days of liquidation.

Phase 2 does not include entries flagged for reconciliation with the reconciliation entry already on file, but those are to be included in a future phase of the refund system.

New Section 301 investigation on pharmaceuticals

On 18 June, 2026, the U.S. Trade Representative initiated a Section 301 investigation into Germany’s pharmaceutical pricing practices to assess whether they are unreasonable or discriminatory and restrict U.S. commerce. The trade representative has requested consultations with Germany and is gathering input, with written comments due by 10 August 2026 and a public hearing scheduled for 22 September.

USMCA trade negotiations update

The 1 July 2026, review date for the trade agreement between the United States, Mexico and Canada, is a decision point, not a hard deadline. A clean renewal of the six-year-old agreement is unlikely as negotiations intensify and shift into a broader, ongoing process.

The United States is using the review as leverage to push for changes on issues like Chinese content in goods, labour and automotive manufacturing, while Canada and Mexico are focused on preserving stability and market access in a highly integrated North American supply chain.

What’s at stake is a trade framework supporting more than $1.6 trillion in annual commerce and deeply interconnected manufacturing and energy flows. If no agreement is reached, the deal does not end. Instead, it moves into a 10‑year period of annual reviews, keeping current rules in place but increasing long-term uncertainty because side deals can be made among any of the parties.

For shippers, this means planning for ongoing friction and volatility, with particular focus needed on increased rules-of-origin compliance, supplier visibility and flexibility. Canadian shippers in particular are looking for continuity and predictability, but are quickly seeking to diversify their trading partners going forward.

EU-Mexico trade agreement still awaits ratification

The European Union and Mexico signed a modernised trade agreement in May that expands market access, reduces trade barriers and updates rules for services, digital trade and investment. Both governments have yet to ratify it.

For supply chain professionals, the deal should make it easier and more cost-effective to move goods between Europe and Mexico while creating new opportunities for nearshoring and supplier diversification and creating long term certainty for trade rules.

U.S. Customs issues orders against Jordanian garment firms

CBP issued two Withhold Release Orders on 23 June, 2026. These orders target garments produced by two companies in Jordan, Needle Craft Ltd. and Casual Wear Apparel LLC, due to suspected forced labour. All deliveries from these companies will now be detained at U.S. ports of entry. Importers can either export or destroy detained goods or provide proof the products were not made with forced labour. This action brings the total number of active withhold release orders to 58.

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