Section by Section the Trump Administration Rebuilds its Tariff Regime

Brownstein Client Alert, May 11, 2026

Since the Supreme Court struck down the White House’s use of the International Emergency Economic Powers Act to impose unilateral tariffs, the Trump administration has moved quickly to preserve its economic leverage by pivoting to other trade authorities, including temporary duties under Section 122 and broader investigations under Sections 301 and 232. Our team unpacks how this strategy is taking shape, where the greatest risks now lie and what business leaders can do to protect their interests.


THIS DOCUMENT IS INTENDED TO PROVIDE YOU WITH GENERAL INFORMATION REGARDING NEW TRADE POLICIES BEING PERSUED BY THE WHITE HOUSE. THE CONTENTS OF THIS DOCUMENT ARE NOT INTENDED TO PROVIDE SPECIFIC LEGAL ADVICE. IF YOU HAVE ANY QUESTIONS ABOUT THE CONTENTS OF THIS DOCUMENT OR IF YOU NEED LEGAL ADVICE AS TO AN ISSUE, PLEASE CONTACT THE ATTORNEYS LISTED OR YOUR REGULAR BROWNSTEIN HYATT FARBER SCHRECK, LLP ATTORNEY. THIS COMMUNICATION MAY BE CONSIDERED ADVERTISING IN SOME JURISDICTIONS.