With the start of the new year, we anxiously await the Supreme Court’s decision in the IEEPA tariff cases. The Court issued its first opinion of the term last Friday, but it was not the highly anticipated IEEPA tariff opinion. Nevertheless, Court-watchers expect the see the opinion in the next month.
With the legality of the Trump Administration’s IEEPA based tariffs hanging on the decision of the Supreme Court, the future of the trade agreements the Administration has made with a number of countries based on the IEEPA tariffs also hang in the balance. Since the IEEPA reciprocal tariffs have been implemented, the Trump Administration has extracted concessions through trade deals with 18 countries, with a number of other countries still seeking deals. Whether these deals continue to go forward will likely depend on the decision of the Supreme Court.
On January 2, U.S. Customs and Border Protection (“CBP”) published an interim final rule, mandating that, with limited exceptions, all refunds of duties will be issued electronically via Automated Clearing House (ACH) transfers, effective February 6, 2026. This change effectively ends the issuance of paper checks. While not specific to potential refunds of IEEPA tariffs, this new rule will require any importer seeking a refund from CBP to be enrolled in the ACH Refund program through an ACE Portal account. Currently only around 30% of issued refunds are ACH payments. This new requirement may pose a hurdle to smaller importers receiving a refund in the event the Supreme Court strikes down the IEEPA tariffs.
A new bill has been introduced in the House of Representatives that would codify the Trump Administration’s baseline reciprocal tariffs. The Fair Trade Act of 2026 (H.R. 6991), introduced by Representative Beth Van Duyne (R-TX), would formalize a 10% baseline tariff on all imported goods, with a 15% tariff for countries with which the U.S. has a persistent trade deficit. The bill has been referred to the House Ways and Means Committee.
President Trump announced that the increase in Section 232 duties on imports of upholstered furniture, kitchen cabinets, and vanities will be delayed one year. The President issued a proclamation on December 31, 2025, delaying an increase in the duty rates for certain derivative wood products for one year until January 1, 2027. These products have been subject to 25% tariffs, which were expected to increase to 50% on January 1, 2026. The President’s proclamation will keep the tariff rate at 25% on certain upholstered wooden products, kitchen cabinets and vanities for the next year.
On January 12, 2026, President Trump announced in a Truth Social post that “[e]ffective immediately, any Country doing business with the Islamic Republic of Iran will pay a Tariff of 25% on any and all business being done with the United States of America.” No official action has been published. While no specific countries have been identified for the tariffs, a number of U.S. trading partners have regular trade with Iran, including Brazil, China, Turkey and the United Arab Emirates.
Keeping track of all the tariffs that have been promulgated or proposed during the Trump Administration continues to be a head-spinning task. To help follow the proliferation of tariffs in the Trump Administration, I have put together the following list of each of the tariff measures that have been implemented, pending, or proposed since January 20, 2025.
Here is the developing landscape of U.S. tariffs as of January 12, 2026:
This list will be updated weekly as new tariffs are implemented and new targets for tariffs are identified by President Trump and the administration.
