Following the Supreme Court ruling invalidating IEEPA tariff rates, President Trump enacted a temporary (150 days) 10% global tariff rate under Section 122. With that temporary rate set to expire on July 24th, the Trump Administration prepared new Section 301 investigations focused on forced labor and excess manufacturing capacity in dozens of countries.
Following a public comment period and public hearings, the United States Trade Representative (USTR) and President Trump have made their first decision on the forced labor investigation, setting longer-term tariff rates that are effective as of 12:01 am on July 24th. Section 301 tariffs are more ‘legally durable’ than the IEEPA authority and Section 122 (also challenged in court). Home furnishings retailers should prepare for new Section 301 tariffs that will take effect with very little notice. The scope and complexity of the changes will require customs brokers, importers, and federal agencies to review affected Harmonized Tariff Schedule (HTS) classifications, countries of origin, and entry requirements.
Retailers need to know
- Use 12.5% as a conservative planning estimate. When calculating landed costs, retailers and importers should initially plan for an additional duty of up to 12.5%. Many products may be subject to a 10% rate, while others may qualify for an exemption. The correct treatment will depend on the product’s HTS classification and country of origin. Countries that qualify for the 10% rate are: Canada, Ecuador, the European Union, Indonesia, Mexico, and Pakistan.
- The previous 10% Section 122 tariff has ended. For some products, replacing that tariff with the new Section 301 duty may result in little or no net change. Each product and shipment must still be evaluated individually.
- Section 232 products are excluded from the new Section 301 duty. Products already subject to Section 232 duties, including certain upholstered furniture, steel, aluminum, and copper, will not also be subject to this Section 301 tariff.
- There is effectively no general grace period. A narrow exemption may apply only to articles that:
- Were loaded at the port of loading and in transit on their final mode of transportation before 12:01 a.m. Eastern time on July 24, 2026; and
- Are entered for consumption, or withdrawn from a warehouse for consumption, before 12:01 a.m. Eastern time on July 28, 2026.
Importers should not assume that pre-filing an entry establishes eligibility. Customs determines the entry date based on the goods’ arrival at the port of entry. Transportation delays or processing constraints could therefore affect whether a shipment qualifies for the narrow exemption.
Recommended actions for retailers
HFA encourages affected businesses to:
- Contact customs brokers and import partners immediately to review pending and in-transit shipments.
- Confirm HTS classifications and countries of origin for imported products rather than applying a single rate across an entire product line.
- Model an additional 12.5% duty when estimating near-term landed costs, while recognizing that the final rate may be lower or the product may be exempt.
- Review purchasing, pricing, and inventory decisions based on potential tariff exposure.
- Maintain complete shipping and entry documentation, particularly for goods that may fall within the July 24–28 exemption window.
- Prepare for possible post-entry adjustments as federal customs systems and tariff programming are updated.
HFA will continue monitoring implementation and communicating the retail impact to policymakers. Retailers experiencing shipment disruptions, unexpected duty assessments, or other significant effects are encouraged to document those impacts and share them with HFA to support its advocacy.
Important: This update is based on the trade information provided to HFA and is intended for general educational purposes. It is not legal, tax, or customs advice. Tariff treatment depends on the specific HTS code, country of origin, product composition, and entry circumstances. Importers should confirm applicable duties with a licensed customs broker or qualified trade counsel.
