Executive Order ends all IEEPA-based additional ad valorem duties from several 2025–2026 tariff EOs; HTS updates and collection stop to follow.

REGULATORY BRIEFING – Ending Certain Tariff Actions (Executive Order, February 20, 2026)

1. What changed

• The President has ordered the termination of all additional ad valorem duties imposed under the International Emergency Economic Powers Act (IEEPA) in the following Executive Orders (EOs):
• EO 14193 (Imposing Duties To Address the Flow of Illicit Drugs Across Our Northern Border), as amended
• EO 14194 (Imposing Duties To Address the Situation at Our Southern Border), as amended
• EO 14195 (Imposing Duties To Address the Synthetic Opioid Supply Chain in the People’s Republic of China), as amended
• EO 14245 (Imposing Tariffs on Countries Importing Venezuelan Oil)
• EO 14257 (Regulating Imports With a Reciprocal Tariff To Rectify Trade Practices That Contribute to Large and Persistent Annual United States Goods Trade Deficits), as amended
• EO 14323 (Addressing Threats to the United States by the Government of Brazil), as amended
• EO 14329 (Addressing Threats to the United States by the Government of the Russian Federation), as amended
• EO 14380 (Addressing Threats to the United States by the Government of Cuba)
• EO 14382 (Addressing Threats to the United States by the Government of Iran)

• All additional ad valorem duties imposed under IEEPA in these EOs “shall no longer be in effect and, as soon as practicable, shall no longer be collected.”
• Only the IEEPA-based additional ad valorem duties and related implementation steps are terminated. Other actions under those national emergencies that do not involve additional ad valorem duties remain in effect.
• The underlying national emergencies declared or described in those EOs remain in force.

2. Affected products and scope

The EO does not list specific HTS codes or duty rates. Instead, it terminates the IEEPA-based additional ad valorem duties created under the listed EOs. In practice, this will affect:

• Any HTSUS subheadings that were subject to additional IEEPA-based ad valorem duties under:
• Northern border illicit drug-related tariffs (likely targeting specific goods from Canada or other northern-border trade partners, as defined in EO 14193 and its implementing notices).
• Southern border situation tariffs (likely targeting specific goods from Mexico or other southern-border trade partners, as defined in EO 14194 and its implementing notices).
• Synthetic opioid supply chain tariffs on products from the People’s Republic of China (PRC) (e.g., certain chemicals, precursors, pharmaceutical intermediates, equipment, or related goods identified in EO 14195 implementation).
• Tariffs on countries importing Venezuelan oil (likely additional duties on imports from countries identified as importing Venezuelan oil, as defined in EO 14245 implementation).
• Reciprocal tariff measures to address large and persistent U.S. goods trade deficits (EO 14257), which may have imposed additional ad valorem duties on a broad range of products from selected countries.
• Country-specific measures on Brazil, Russia, Cuba, and Iran (EOs 14323, 14329, 14380, 14382), which may have imposed additional ad valorem duties on designated products from those countries.

Because the specific HTS lines and rates were defined in subsequent Federal Register notices and/or HTSUS Chapter 99 provisions implementing each EO, importers must refer to those implementing documents to identify exactly which products are affected. This new EO directs agencies to end those additional duties and, if needed, modify the HTSUS accordingly.

3. Rate changes

• All additional ad valorem duty rates imposed under IEEPA by the listed EOs are reduced from their prior IEEPA-enhanced rate back to the underlying MFN or other applicable rate (e.g., normal Column 1, Column 2, Section 232/301/ADD/CVD rates, etc.).
• The EO text does not specify the numerical rates (e.g., +10%, +25%), which were set in the original implementing actions for each EO. However, the change is categorical:
• Old: Base duty rate (MFN/other) + additional IEEPA ad valorem duty (e.g., base 5% + extra 10% IEEPA = 15% total).
• New: Base duty rate only (e.g., 5%), with the IEEPA additional ad valorem component removed.

• The EO explicitly states that it does NOT affect:
• Duties imposed under Section 232 of the Trade Expansion Act of 1962 (19 U.S.C. 1862).
• Duties imposed under Section 301 of the Trade Act of 1974 (19 U.S.C. 2411).
• Any other non-IEEPA duties (e.g., antidumping, countervailing, safeguard, ordinary MFN rates).

4. Dates and timing

• EO date: February 20, 2026.
• Legal status: The EO states that the additional ad valorem duties “shall no longer be in effect and, as soon as practicable, shall no longer be collected.”
• Effective timing in practice:
• The EO is effective upon issuance, but actual cessation of collection at the border will depend on:
• CBP and other agencies issuing implementing guidance.
• Any necessary HTSUS modifications via Federal Register notice.
• Agencies are directed to “immediately begin taking steps” and to terminate collection “as soon as practicable,” but no specific calendar date is given for when CBP will stop collecting the additional duties.

• Other measures explicitly unaffected by this EO and still in force as of February 20, 2026:
• Executive Order of February 20, 2026: “Continuing the Suspension of Duty-Free De Minimis Treatment for All Countries.”
• De minimis duty-free treatment remains suspended; this EO does not restore de minimis.
• Proclamation of February 20, 2026: “Imposing a Temporary Import Surcharge to Address Fundamental International Payments Problems.”
• The temporary import surcharge remains in effect.

5. Required actions for importers, brokers, and compliance teams

A. Identify impacted entries and products

• Compile a list of all products and HTS codes in your portfolio that were subject to additional IEEPA-based ad valorem duties under the following regimes:
• Northern border illicit drug-related tariffs (EO 14193 implementation).
• Southern border situation tariffs (EO 14194 implementation).
• PRC synthetic opioid supply chain tariffs (EO 14195 implementation).
• Tariffs on countries importing Venezuelan oil (EO 14245 implementation).
• Reciprocal tariff measures for large trade deficits (EO 14257 implementation).
• Country-specific measures on Brazil, Russia, Cuba, and Iran (EOs 14323, 14329, 14380, 14382 implementation).

• Use prior Federal Register notices and HTSUS Chapter 99 notes that implemented these EOs to identify:
• The specific HTS subheadings.
• Any special Chapter 99 numbers used to assess the additional IEEPA duties.
• The additional ad valorem rates that applied.

B. Monitor HTSUS and Federal Register updates

• The EO directs:
• The Secretary of Commerce, Secretary of Homeland Security, and USTR, in consultation with CBP and USITC, to determine whether HTSUS modifications are necessary and to make such modifications via Federal Register notice.

• Compliance steps:
• Monitor the Federal Register for:
• Notices from USTR, Commerce, DHS, or USITC announcing:

· Termination of specific IEEPA-based additional duties.

· Deletion or modification of related HTSUS Chapter 99 provisions.

· Clarification of effective dates for cessation of collection.

• Monitor the USITC HTSUS website for updated tariff schedules reflecting removal of the IEEPA-based additional duties.

C. Adjust entry filing and duty calculations

• Once CBP and HTSUS updates are issued:
• Stop declaring any Chapter 99 or other special tariff provisions that were solely used to assess the IEEPA-based additional ad valorem duties under the affected EOs.
• Ensure your customs broker updates their systems to remove the additional IEEPA duty lines from entry summaries.
• Update internal landed cost and pricing models to reflect the removal of the additional IEEPA duties, while retaining:
• Base MFN/Column 2 rates.
• Any Section 232 or Section 301 duties.
• Any ADD/CVD or other applicable measures.
• The temporary import surcharge and the continued suspension of de minimis, where applicable.

D. Review for potential refunds or post-summary corrections

• For entries filed on or after the EO date (February 20, 2026) and before CBP operational guidance is fully implemented:
• Track whether CBP continues to collect the IEEPA-based additional duties during the transition.
• If CBP later confirms that such duties should not have been collected as of a specific effective date, consider:
• Filing Post Summary Corrections (PSCs) to remove the additional IEEPA duty lines.
• Filing protests within the statutory time limits to seek refunds of overpaid IEEPA-based duties.

• Maintain detailed documentation of:
• Entry numbers and dates.
• HTS classifications and Chapter 99 numbers used.
• Amounts of IEEPA-based additional duties paid.

E. Distinguish from unaffected measures

• Ensure internal and broker teams clearly understand that this EO does NOT:
• Remove or reduce Section 232 duties (e.g., on steel, aluminum, or derivatives).
• Remove or reduce Section 301 duties (e.g., on Chinese-origin goods or other Section 301 lists).
• Restore de minimis duty-free treatment.
• Remove the temporary import surcharge imposed by the February 20, 2026 Proclamation.

• Compliance controls:
• Update internal guidance and SOPs to specify which additional duties are terminated (IEEPA-based under the listed EOs) and which remain.
• Train relevant staff to avoid mistakenly discontinuing payment of Section 232/301 or other non-IEEPA duties.

6. Practical examples (conceptual)

Note: Specific HTS codes and rates must be confirmed from the original implementing notices. The following are conceptual examples of how the change operates:

• Example 1 – Product from PRC under EO 14195 (synthetic opioid supply chain):
• Before EO (under IEEPA measure):
• Base MFN duty: 3% ad valorem.
• Additional IEEPA duty under EO 14195: +15%.
• Total duty: 18%.
• After implementation of this EO:
• Additional IEEPA duty: 0% (terminated).
• Total duty: 3% (plus any applicable Section 301 or other duties, if separately in force).

• Example 2 – Product from a country targeted under EO 14257 (reciprocal tariff for trade deficits):
• Before EO:
• Base MFN duty: 0%.
• Additional IEEPA duty under EO 14257: +10%.
• Total duty: 10%.
• After implementation of this EO:
• Additional IEEPA duty: 0%.
• Total duty: 0% (unless other measures apply).

7. Key caveats and limitations

• The EO does not itself amend the HTSUS; it authorizes and directs agencies to make necessary HTSUS modifications via Federal Register notice.
• The precise effective date for cessation of collection at the port may be clarified in subsequent CBP and USTR guidance.
• The EO does not provide for automatic retroactive refunds; any refunds will depend on:
• How agencies define the effective date.
• Whether CBP collected duties after that date.
• Timely filing of PSCs or protests by importers.

8. References and where to find details

Because this is a White House Executive Order, detailed implementation (HTS codes, rates, and effective dates) will be in subsequent agency documents. Key reference points:

• Executive Order: “Ending Certain Tariff Actions,” dated February 20, 2026 (White House Presidential Actions page).
• White House Presidential Actions portal: https://www.whitehouse.gov/briefing-room/presidential-actions/

• Prior EOs establishing the IEEPA-based duties (for background and scope):
• EO 14193 – Imposing Duties To Address the Flow of Illicit Drugs Across Our Northern Border.
• EO 14194 – Imposing Duties To Address the Situation at Our Southern Border.
• EO 14195 – Imposing Duties To Address the Synthetic Opioid Supply Chain in the People’s Republic of China.
• EO 14245 – Imposing Tariffs on Countries Importing Venezuelan Oil.
• EO 14257 – Regulating Imports With a Reciprocal Tariff To Rectify Trade Practices That Contribute to Large and Persistent Annual United States Goods Trade Deficits.
• EO 14323 – Addressing Threats to the United States by the Government of Brazil.
• EO 14329 – Addressing Threats to the United States by the Government of the Russian Federation.
• EO 14380 – Addressing Threats to the United States by the Government of Cuba.
• EO 14382 – Addressing Threats to the United States by the Government of Iran.

• HTSUS and implementing details:
• U.S. International Trade Commission (USITC) HTSUS: https://hts.usitc.gov/
• Federal Register (for implementing and termination notices, HTS amendments): https://www.federalregister.gov/

• Related, unaffected measures:
• Executive Order (February 20, 2026): “Continuing the Suspension of Duty-Free De Minimis Treatment for All Countries.”
• Presidential Proclamation (February 20, 2026): “Imposing a Temporary Import Surcharge to Address Fundamental International Payments Problems.”

9. Immediate next steps for compliance teams

• Map exposure: Identify all imports that were subject to IEEPA-based additional ad valorem duties under the listed EOs.
• Watch for guidance: Assign responsibility to monitor Federal Register, CBP CSMS messages, and USTR/USITC updates for:
• HTSUS amendments removing the IEEPA-based duties.
• CBP instructions on effective dates and refund procedures, if any.
• Update systems: Prepare to adjust broker instructions, ERP/tariff engines, and landed cost models once effective dates are confirmed.
• Preserve rights: Track entries and maintain documentation to support PSCs or protests if CBP confirms retroactive or specific effective dates for duty termination.

This EO represents a broad rollback of IEEPA-based additional ad valorem duties imposed under multiple 2025–2026 tariff actions, but leaves other major trade remedies and surcharges intact. Importers must carefully separate IEEPA-based measures from Section 232/301 and other duties when updating their compliance posture.