Following the Supreme Court decision striking down the president’s use of the International Emergency Economic Powers Act (IEEPA) to impose tariffs, the Trump administration has quickly leveraged other statutory authorities to advance its tariff agenda. Within hours of the court’s ruling, the White House issued a proclamation to impose a temporary 10% duty on most imports under Section 122 of the Trade Act of 1974. This Sec. 122 tariff is set to expire on July 24, 2026.
In order to maintain tariffs in the long term, the administration has separately launched a series of investigations under Section 301 of the Trade Act of 1974 and Section 232 of the Trade Expansion Act of 1962, both of which authorize tariff measures in response to specific trade practices or national security concerns posed by the activity of trading partners. Unlike the attempted use of IEEPA, these authorities do not authorize the president to unilaterally impose tariffs. Instead, they are governed by more structured procedures. This creates opportunities for stakeholder engagement and influence.
Below outlines the administration’s ongoing tariff actions and key deadlines for stakeholder engagement. Brownstein stands ready to assist impacted stakeholders in drafting and submitting comments as well as engaging the administration as well as Congress on the full range of trade and tariff issues.
Trump Tariffs: Upcoming Deadlines
| DATE | TRADE INVESTIGATION | ACTION | BACKGROUND |
| June 22 | Section 301 Investigation – Forced Labor Imports | All requests to appear at the public hearings, along with a summary of testimony, must be submitted. | Client Alert |
| June 22 | Section 301 Investigation – Brazil | All requests to appear at the public hearings, along with a summary of testimony, must be submitted. | Client Alert |
| June 23 | Section 232 Investigation – Robotics and Industrial Machinery | The Secretary of Commerce must deliver a (not public) report to the president, including an analysis of the import’s effect on “national security” as well as recommended action to mitigate the threat. | |
| June 23 | Section 232 Investigation – Medical Equipment | The Secretary of Commerce must deliver a (not public) report to the president, including an analysis of the import’s effect on “national security” as well as recommended action to mitigate the threat. | |
| July 1 | Section 301 Investigation – Brazil | Public comments must be submitted. | Client Alert |
| July 2 | Section 301 Investigation – Vietnam IP | Public comments must be submitted. | Client Alert |
| July 6 | Section 301 Investigation – Forced Labor Imports | Public comments must be submitted. | Client Alert |
| July 6 | Section 301 Investigation – Brazil | USTR will hold a public hearing. | Client Alert |
| July 7 | Section 301 Investigation – Forced Labor Imports | USTR will begin public hearings. | Client Alert |
| July 10 | Request for Comments – U.S.-China Board of Trade | Public comments must be submitted. | Client Alert |
| July 27 | Request for Comments – U.S.-China Board of Trade | Any rebuttals or responses to previous comments must be submitted. | Client Alert |
| Aug. 10 | Section 301 Investigation – Germany Pharmaceuticals | Public comments and all requests to appear at the public hearing, along with a summary of testimony, must be submitted. | |
| Sept. 22 | Section 301 Investigation – Germany Pharmaceuticals | USTR will hold a public hearing. |
THIS DOCUMENT IS INTENDED TO PROVIDE YOU WITH GENERAL INFORMATION REGARDING THE TRUMP ADMINISTRATION’S TRADE POLICIES. 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.
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