Section 122 reaches the expiration week

The temporary import surcharge reaches its July 24 clock, putting entry timing, landed-cost assumptions, de minimis lanes, and replacement-tariff risk on one review list.

The most important trade date this week is not a new product-specific notice. It is the clock on the broad temporary import surcharge.

Proclamation 11012 imposed a 10 percent ad valorem temporary import surcharge under Section 122 of the Trade Act of 1974, effective February 24, 2026. The proclamation says the HTS modifications continue through 12:01 a.m. eastern daylight time on July 24, 2026, unless the surcharge is suspended, modified, terminated earlier, or extended by Congress.

That creates a short operating window. Importers need to know which open entries, quotes, purchase orders, landed-cost models, and customer commitments assumed Section 122 would continue - and which ones assumed it would disappear cleanly. The risk is not only the 10 percent line item. It is the transition: replacement measures, de minimis timing, Chapter 99 cleanup, refund posture, and broker instructions can all move around the same date.

The operator read: treat July 24 as a duty-stack control date, not a headline.

Read This First

• Signal: broad tariff sunset and replacement-risk week.
• Exposure: importers with non-excluded goods subject to Section 122, ecommerce operators affected by de minimis changes, customs brokers, landed-cost teams, and finance owners.
• Watch dates: July 24, August 10, September 22, September 30, and October 22, 2026.
• First move: pull top lanes and open entries where Section 122 appears in the duty stack, then decide what changes if the surcharge expires, is replaced, or is extended by Congress.

Bottom Line

What changed: Section 122 is in its expiration week. Proclamation 11012 set the temporary import surcharge at 10 percent ad valorem for a 150-day period beginning February 24, 2026, with HTS modifications continuing through 12:01 a.m. eastern daylight time on July 24, 2026 unless changed or extended. Separately, CBP's de minimis suspension rules also hit a July 24 effective/comment date, and the postal rule ties its interim duty treatment to the expiration date of the Section 122 surcharge or the new postal entry process, whichever comes first.

Operator impact: Importers may have one rate stack in quotes, one in broker instructions, one in landed-cost tools, and another in actual entries if July 24 is handled casually. A broad surcharge sunset can create refund questions, pricing disputes, entry-timing choices, and controls work even when no new product duty is announced.

What to do next: Build a July 24 review list: affected HTS/origin lanes, open entries, in-transit shipments, pending quotes, purchase orders, customer pricing, refund/protest posture, and broker instructions. Do not assume "expires" means "no action."

The Clearance Brief

1. Section 122 is the lead because it changes the base operating assumption

The operative proclamation imposed a 10 percent temporary import surcharge on certain imports under Section 122, effective February 24, 2026, for a 150-day period. It also lists exclusions, including certain critical minerals, energy products, pharmaceuticals, some electronics, passenger vehicles and certain vehicle parts, Section 232-covered articles, qualifying USMCA goods, and qualifying CAFTA-DR textile/apparel goods.

Operator read: separate covered, excluded, and uncertain lanes before July 24. The worst review is a blended spreadsheet where excluded goods, Section 232 goods, USMCA goods, and fully covered goods are treated as one population.

2. De minimis also points at July 24

CBP's June 24 interim final rule for non-postal low-value shipments says merchandise valued at $800 or less arriving through modes other than the international postal network must use formal or informal entry procedures. The companion postal rule is effective July 24, with comments also due July 24 and certain postal data requirements reaching a later October 22 compliance date.

The postal rule adds an important connection: interim duty treatment for covered postal products is assessed until the expiration date of the temporary import surcharge established by Proclamation 11012, or until the effective date of the new postal entry process, whichever comes first.

Operator read: ecommerce, marketplace, express, and postal lanes need a combined July 24 review. Do not treat Section 122 and de minimis as separate calendars if the same product or customer promise depends on both.

3. Solar AD/CVD is a narrower but real trade-remedy signal

Commerce initiated a country-wide circumvention inquiry covering crystalline silicon photovoltaic cells and modules completed in Ethiopia using Chinese parts and components, including scenarios where additional assembly occurs in Vietnam before export to the United States.

Operator read: if a solar lane relies on Ethiopia, Vietnam, or Chinese-origin inputs, freeze any "non-China" assumption until trade-remedy counsel reviews scope, supplier affidavits, production records, and cash-deposit exposure.

4. The Section 301 Germany pharma clock is still moving

USTR's Section 301 investigation into Germany's pricing of innovative pharmaceutical products remains on the calendar. Written comments and hearing requests are due August 10, 2026, and the public hearing is scheduled for September 22, 2026.

Operator read: pharma importers should not read Section 122 exclusion language as a broad safe harbor. Track the August 10 comment date, identify affected product families, and model what a remedy could do to sourcing and contract pricing.

5. HTS and sanctions controls still need the weekly refresh

USITC's latest HTS archive still shows 2026 Revision 11, published July 1. OFAC's recent-actions page also shows July activity including Russia-related designations updates on July 20, Venezuela guidance on July 17, Hong Kong-related updates on July 17, and non-proliferation/counter-terrorism designations on July 15.

Operator read: treat the July 24 review as a data-control pass: HTS version, Chapter 99 logic, sanctions screening date, broker instruction date, and landed-cost model version should all be visible.

6. Freight relief is modest, not a reason to ignore landed-cost exposure

Drewry's July 16 World Container Index fell 2 percent to $4,547 per 40-foot container after the recent peak-season climb. That is useful context, but not enough to offset tariff uncertainty by itself.

Operator read: do not let a softer weekly freight reading bury a tariff-control problem. If quotes were built with both high freight and Section 122, update both assumptions deliberately.

July 24 Duty-Stack Review

Use this as the working pass before the clock runs out.

1. Pull every active HTS/origin lane where Section 122 appears in the current rate stack or broker instructions.
2. Split lanes into covered, excluded, and needs-review populations. Pay special attention to Section 232 goods, USMCA goods, pharmaceuticals, electronics, vehicles/parts, critical minerals, and energy products.
3. Mark open entries, in-transit shipments, bonded/warehouse timing, purchase orders, customer quotes, and landed-cost tools that rely on the current surcharge.
4. Ask the broker how July 24 will be handled in entry instructions, Chapter 99 reporting, post-entry review, and any refund/protest workflow.
5. Review low-value/postal lanes separately, then connect them back to Section 122 where interim duty treatment or customer pricing depends on the same date.
6. Create a one-page variance note for finance: what changes if the surcharge expires, continues by congressional extension, is modified, or is replaced by another measure.

Dates / Watchlist

Now in effect

• February 24, 2026: Section 122 temporary import surcharge effective date under Proclamation 11012.
• July 1, 2026: USITC HTS Revision 11 is the current archived 2026 HTS revision.
• July 16, 2026: Drewry World Container Index reading fell 2 percent to $4,547 per 40-foot container.
• July 20, 2026: OFAC posted Russia-related sanctions list updates.

Coming up

• July 24, 2026: Section 122 HTS modifications continue through 12:01 a.m. eastern daylight time unless changed or extended; CBP de minimis postal and non-postal rule dates/comment deadlines also hit July 24.
• August 10, 2026: USTR Section 301 Germany pharma comments and hearing requests due.
• September 22, 2026: USTR Section 301 Germany public hearing.
• September 30, 2026: OFAC annual Report of Blocked Property due.
• October 22, 2026: compliance date for specified postal informal-entry data requirements.

Operator Checklist

• Pull top affected lanes and confirm whether Section 122 is currently included, excluded, or unresolved.
• Check open entries, in-transit goods, warehouse timing, customer quotes, and purchase orders against the July 24 clock.
• Ask brokers for written handling instructions on Chapter 99 reporting, post-entry review, and any refund/protest path if the surcharge expires or changes.
• Re-run landed-cost models under three cases: surcharge expires, surcharge is extended, surcharge is replaced or modified.
• For low-value lanes, map postal versus non-postal treatment and decide whether July 24 changes entry type, broker responsibility, or customer-facing pricing.
• For solar lanes, review Ethiopia/Vietnam/China input chains against the new circumvention inquiry before relying on third-country processing assumptions.
• Refresh HTS version, sanctions screening, and restricted-party review dates in the same control pass.

Operator Tool - From Our Partner

CLEARANCE partners with US Tariff Rates, a tariff intelligence platform built for import operators. Its tariff tracker helps teams check current duty layers, including Section 122, Section 232, Section 301, and tariff-change signals in one place. Use it to pressure-test affected lanes, then confirm entry treatment, origin, exclusions, and filing responsibility with your broker or customs counsel.

CLEARANCE is a weekly trade-operations brief for importers, exporters, customs brokers, and compliance teams.

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This briefing is for operational awareness only. It is not legal advice, customs advice, or a substitute for broker or counsel review.