Three Tariff Regimes in One Year: Rebuilding Landed Cost After July 24, 2026

By Bernardo Campelo, Forbes Business Council E-Commerce Leader, Amazon SPN Certified provider, Amazon SP-API authorized partner, and Founder of PrepVia.

Open a landed cost spreadsheet built in January and find the duty column. In a typical model it holds one percentage per SKU, typed once and copied down the page. Since then, only the number in the cell has changed.

Between February 20 and July 24, 2026, the broad U.S. tariff layer ran under three different legal bases, each with its own exemptions and its own cutoff minute. A unit that entered in March and a unit that entered in August can sit in the same FBA bin under different regimes. One edited cell cannot show that.

My position is simple. After July 24, the tariff in your landed cost is a variable set by entry date, origin and classification. It belongs in the model as dated sub-lines that your customs broker confirms, each one tied to a primary source.

Three Legal Bases in Five Months

On February 20, 2026, the Supreme Court decided Learning Resources, Inc. v. Trump and held that the International Emergency Economic Powers Act does not authorize the President to impose tariffs. The same day, Executive Order 14389, Ending Certain Tariff Actions, ordered that the IEEPA duties no longer be in effect and, as soon as practicable, no longer be collected. That covered the reciprocal tariffs and the IEEPA duties on Canada, Mexico, China and Brazil, among others.

Also on February 20, Proclamation 11012 imposed a 10% surcharge under Section 122 of the Trade Act of 1974 on goods entered from 12:01 a.m. EST on February 24 through 12:01 a.m. EDT on July 24. Section 122 allows up to 15% for no more than 150 days unless Congress extends it. The proclamation used 10%, and it excluded, among others, Section 232 articles and goods of Canada or Mexico entered duty-free under the USMCA.

Then came the handoff. After a presidential memorandum of July 23, 2026, USTR published a notice on July 28 (91 FR 47318) imposing Section 301 duties on all products of 60 investigated economies, for goods entered from 12:01 a.m. Eastern on July 24. The Section 122 surcharge ended at that same minute. Two days earlier, a separate Section 301 action on Brazil had taken effect at 25%.

The calendar below is keyed to the date of entry.

The Entry Date Decides, Not the PO Date

The Section 122 proclamation and both Section 301 notices use the same trigger: goods entered for consumption, or withdrawn from warehouse for consumption, on or after a stated minute. Your purchase order date is not in that test. Neither is the invoice date, the day freight reaches a prep center, or the day Amazon checks it in.

The only relief for goods already on the water was an in-transit window with two conditions. For Section 122, goods had to be loaded and in transit on the final mode before 12:01 a.m. EST on February 24, and entered before 12:01 a.m. EST on February 28. For the forced-labor duty, the USTR notice required loading before 12:01 a.m. Eastern on July 24 and entry before 12:01 a.m. Eastern on July 28. Both windows are closed.

Take a hypothetical container loaded on July 20 that was entered on July 30. It met the first condition and missed the second, so the exception did not cover it. Priced off the sailing date, it sits under the wrong regime in your spreadsheet.

This is where operators go wrong at volume. Units from three entries land in one FBA pool, the spreadsheet averages them, and the average hides that the lots entered under different rules. Keep the entry number and entry date on every lot instead. Our guide to customs documents for an Amazon FBA import in 2026 shows where the entry summary sits in the paper trail.

The Forced-Labor Layer, Origin by Origin

The forced-labor action sets its rate by origin; the product matters only through the exemptions and the MFN caps. Economies that ban forced-labor imports, committed to a ban in an Agreement on Reciprocal Trade, or run a partial regime got 10%. Every other investigated economy got 12.5%. Five of them get a combined cap instead of a flat add-on. The rates below come from CBP guidance CSMS # 69326983 of July 23, 2026, which gives each economy its own Chapter 99 heading, two for each capped economy.

China is inside this action at 12.5%, under heading 9903.05.31. So is Vietnam, under 9903.05.84.

For every economy, the notice exempts, among others, articles subject to Section 232 tariffs, civil aircraft, pharmaceutical articles, donations, informational materials and the product lists in its annexes, and 13 economies, among them the United Kingdom, the European Union and Taiwan, have their own exemption lists. CBP describes the Section 232 group as articles of aluminum, steel or copper, derivative aluminum and steel articles, vehicles and their parts, wood products and semiconductor articles, and for goods entered from July 31, 2026 the notice adds patented pharmaceutical articles. USTR also added 471 products to the exemptions it proposed in June. Whether your SKU is on a list is a classification question.

Where the Trade Agreements Help, and Where They Do Not

USMCA. Goods of Mexico or Canada entered free of duty under the USMCA are exempt. A Mexican good entered without that treatment falls back to the 10% heading unless another exemption applies.

CAFTA-DR. Only textile or apparel goods of the six partners entered duty-free under CAFTA-DR are exempt. Other goods from Costa Rica, the Dominican Republic and Nicaragua fall under 12.5% headings, and other goods from El Salvador, Guatemala and Honduras under 10% headings, unless a general exemption applies or, for El Salvador and Guatemala, the product is on their own annex lists.

Colombia, Peru and Chile. Their headings list only the general exemptions. There is no carve-out for goods entered under their free trade agreements with the United States. Panama is not among the 60 investigated economies.

How the Layers Sit on One Entry Line

The word stack misleads. CBP sets the reporting order on the entry line; the text of each heading decides whether its duty adds to another. U.S. note 52 in the forced-labor notice keeps covered goods subject to the general rate and to other additional duties in subchapters III and IV of Chapter 99, except where the note provides otherwise.

CBP’s filing instructions set the order on each line: Chapter 98 where it applies, then Chapter 99 numbers for additional duties. Among trade remedies, the Section 301 number goes first, followed by the Section 122, Section 232 and Section 201 numbers. The Chapter 1 to 97 classification comes last and carries the entered value. Read that way, the layers change what you model:

• Section 232 articles. They are exempt from the forced-labor duty, and under Proclamation 11012 the Section 122 surcharge did not apply to the part of an import covered by Section 232.
• Capped economies. For the European Union and Taiwan, the heading sets a combined column 1 and Section 301 rate of 10% when column 1 is below 10%, and no additional duty when it is 10% or more. Japan, South Korea and Switzerland work the same way at 12.5%. The layer tops up the MFN rate; it does not ride on it.
• Other duties survive. The guidance says covered products stay subject to antidumping, countervailing and other duties, taxes and fees.
• China. The 2018 Section 301 actions on technology transfer are separate from this one. They are now in a second four-year review opened on May 6, 2026, with 178 product exclusions extended through 11:59 p.m. EDT on November 9, 2026.
• Brazil. The 25% action uses heading 9903.05.01 and the forced-labor action uses 9903.05.27. Both are active in the Harmonized Tariff Schedule, and neither the CBP message on the Brazil action nor the forced-labor guidance exempts Brazilian goods from the other heading.

I will not print a combined figure for China or Brazil. No CBP message I have read states one, and the answer turns on your classification. So the model below gives each Chapter 99 number its own row.

The Landed Cost Model You Fill In

This is the instrument. It does not compute your duty. It shows which layers exist, which document proves each one, and who owns the number. You fill the last column, per unit, from paper you could show an auditor.

The non-tariff lines follow our landed cost worksheet from container to Amazon check-in and the 3PL invoice, read line by line.

Two rules keep it honest. Every duty figure comes from your broker’s entry, not from a rate you multiplied yourself. And a lot inherits only the rows that match its entry date: a May lot may carry a Section 122 row and no forced-labor row, and an August lot carries the reverse.

Five Questions for Your Broker, Per SKU and Origin

Re-run the model when a lot crosses a date in the first table, when you change factory or origin, when a classification changes, or when a Federal Register notice or CBP CSMS message names your origin or HTS code. The forced-labor guidance reached filers by CSMS on July 23, five days before Federal Register publication.

What Could Move the Numbers Before Year End

The forced-labor notice sets no expiration date. Section 122, by contrast, is capped by statute at 150 days without an act of Congress. Carry the layer until a notice or a court order changes it.

Importers have challenged it. Suits were filed from July 24, and on August 11, 2026 the Court of International Trade opened a consolidated docket, In re Section 301 Forced Labor Cases, No. 1:26-cv-03555. I will not predict the outcome; what a ruling means for past entries is a question for counsel.

Two dates are fixed. On October 1, 2026, CBP Dec. 26-14 takes effect: the merchandise processing fee stays at 0.3464% ad valorem, with a minimum of $34.58 and a maximum of $670.86 per formal entry. On November 9, 2026, the 178 China exclusions expire unless USTR extends them again.

Other Section 301 investigations are open with no action notice in the Federal Register as of October 1, 2026. They include one on structural excess capacity in 16 economies, among them China, Mexico, Vietnam and India, initiated on March 11, and one on Vietnam’s intellectual property enforcement, initiated on May 29.

What a Prep Center Changes, and What It Does Not

Nothing on a prep center dock changes your rate. The duty attaches at entry, and storing, relabeling or splitting cartons afterward is not part of that test.

Apart from warehouse withdrawal, already in the trigger, the notices single out one storage structure: the foreign trade zone. Product subject to the forced-labor duty that is admitted into an FTZ after the effective date may only be admitted in privileged foreign status, and Proclamation 11012 set the same rule for Section 122. PrepVia does not operate an FTZ.

PrepVia is the prep center at the end of the chain, in Miami. We receive the container after it clears, prep and label it, store it and send it to Amazon. We are not your customs broker, importer of record or forwarder, and we do not file entries. Our piece on the importer of record when a 3PL takes the container covers that line.

What we feed your model is the receiving side: the count of each container against its packing list and the condition photos taken at receipt. Your broker’s entry summary ties that container to an entry date. Together, the two records give every lot a regime.

One more check. If earlier freight moved DDP, look at whose IOR number appears on the entry summary. CBP’s IEEPA refund page says refunds go only to the importer of record or the party it designated on CBP Form 4811, and only to a party with U.S. bank details in its ACE Portal account. Our note on DDP versus DDU when the destination is a prep center explains why. Whether you have a claim is for your broker and counsel.

Frequently Asked Questions

Is China subject to the Section 301 forced-labor tariff?

Yes. CBP guidance lists China under heading 9903.05.31 at an additional 12.5% for goods entered on or after 12:01 a.m. Eastern on July 24, 2026, subject to the general exemptions. That action is separate from the 2018 Section 301 actions on China, which USTR placed in a second four-year review on May 6, 2026. Which actions apply to an HTS code is for your broker to say.

Did the Section 122 surcharge ever reach 15%?

No. Proclamation 11012 set 10% for goods entered from February 24 through July 24, 2026. The 15% figure is the statutory ceiling, for no more than 150 days unless Congress extends it. As of October 1, 2026, the Federal Register shows no later proclamation changing the 10% rate.

Does the Section 301 forced-labor duty have an end date?

No. The USTR notice of July 28, 2026 sets none, and importers are challenging the action in a consolidated case at the Court of International Trade. Carry the layer until a notice or a court order changes it.

Do goods from Colombia, Peru or Chile get a free trade agreement exemption?

No. The CBP headings for Chile, Colombia and Peru list only the general exemptions, and all three carry 12.5%. The only free trade agreement carve-outs in the guidance cover USMCA duty-free goods of Mexico or Canada and CAFTA-DR duty-free textile or apparel goods of six partners.

Which date decides whether my goods pay the forced-labor Section 301 duty?

The date of entry for consumption, or of withdrawal from warehouse for consumption. Goods entered on or after 12:01 a.m. Eastern on July 24, 2026 fall under the action unless an exemption applies. The only in-transit relief required loading before that minute and entry before 12:01 a.m. Eastern on July 28, 2026.

Does storing inventory at a US prep center or warehouse change the tariff?

No. The duty attaches at entry, and what happens to the inventory afterward is not part of the test. The notice does address foreign trade zones, where covered product admitted after the effective date may only take privileged foreign status, and PrepVia does not operate one.

Can PrepVia tell me the tariff rate for my product?

No. PrepVia is a prep center and 3PL in Miami, not a customs broker, importer of record or freight forwarder, and we do not classify goods or file entries. We handle the receiving side: we count each container against its packing list, photograph its condition, prep within a 24-36 hour window and ship to Amazon.

Final Take

The typical duty column was built for a year with one tariff regime. 2026 had three, with cutoffs set to the minute, and the third has no end date.

The fix is a structure, not a better guess: lots tagged with entry date and entry number, one sub-line per Chapter 99 number your broker reports, and a primary source beside each one. Built that way, the next notice only changes a row.

Keep the jobs separate. Your broker owns classification and the duty figure. Your counsel owns litigation and refunds. Your prep center owns the record of what arrived, in which container, and when it left for Amazon. Where those records meet, landed cost becomes something you can defend line by line.