White House 2026 Trade Policy Agenda confirms broad, ongoing tariff programs (Section 232, 301, ART) that materially affect U.S. import duties and compliance.

REGULATORY BRIEFING – WHITE HOUSE / USTR 2026 TRADE POLICY AGENDA

1. What changed / key policy signals

The materials are primarily policy and programmatic, not a single discrete tariff notice, but they confirm and extend several U.S. import-impacting regimes:

• Continuation and expansion of the "America First" tariff strategy launched April 2, 2025 ("Liberation Day"), including:
• Broad use of supplemental tariffs above MFN rates via the Agreement on Reciprocal Trade (ART) program.
• Ongoing and potentially expanded Section 232 actions on a wide range of industrial and strategic products.
• Continued and possibly expanded Section 301 actions (China and other targets).
• Confirmation that ART agreements are legally binding and enforceable, and that the U.S. will maintain modified (higher) tariffs on imports from ART partners while those partners reduce their tariffs and non-tariff barriers on U.S. exports.
• Announcement of a forthcoming plurilateral Agreement on Trade in Critical Minerals (ATCM) that will establish "border-adjusted price mechanisms" for specific minerals and downstream products, effectively a coordinated tariff/price regime.
• Statement that Section 232 investigations were initiated or tariff modifications made in 2025 for a long list of sectors, with an intent to continue using Section 232 to secure supply chains.
• Commitment to robust enforcement of U.S. trade laws, including:
• Ongoing and new Section 301 investigations.
• Measures to support customs enforcement and prevent duty evasion.
• Forced labor-related import bans by multiple ART partners (which may interact with U.S. forced labor enforcement and supply chain expectations).

These documents do not provide specific HTS subheadings or exact duty rates, but they clearly confirm that elevated and targeted tariffs on U.S. imports in many sectors are intended to remain in place and may expand.

2. Affected products and sectors

The agenda identifies multiple import-sensitive sectors where tariffs or other trade measures are active or expected. While no HTS codes are listed, the sectors map to broad HTS chapters and headings.

2.1 Section 232 – critical sectors (imports)

The document states that in 2025, Section 232 investigations were initiated or tariff modifications made for the following sectors (all import-relevant):

• Steel and steel derivatives
• Likely HTS Chapters 72–73 and related derivative products.
• Aluminum and aluminum derivatives
• Likely HTS 7601–7616 and derivative products.
• Automobiles, light trucks, and auto parts
• Likely HTS 8703, 8704 (light trucks), 8708 (parts), and related headings.
• Copper and copper derivatives
• Likely HTS 7401–7419 and derivative products.
• Timber, lumber, and wood products
• Likely HTS Chapters 44 and related wood articles.
• Pharmaceuticals and pharmaceutical ingredients
• Likely HTS 2933–2937, 3001–3006.
• Semiconductors and semiconductor manufacturing equipment
• Likely HTS 8541–8542, 8486, and related equipment headings.
• Medium/heavy duty trucks, truck parts, and derivatives
• Likely HTS 8704 (other trucks), 8708 (parts).
• Processed critical minerals and derivatives
• Various HTS headings across Chapters 26–28, 38, and others depending on mineral.
• Commercial aircraft, jet engines, and parts
• Likely HTS 8802, 8803, 8407–8408 (aircraft engines and parts).
• Polysilicon and components
• Likely HTS 2804.69 and related photovoltaic inputs.
• Robotics and industrial machinery
• Likely HTS 84-series machinery, including 8479, 8428, etc.
• Personal protective equipment, medical consumables, and medical equipment
• Likely HTS 3926.90 (PPE items), 4015, 6307.90, 9018–9020, etc.

These sectors are explicitly tied to Section 232 investigations or tariff modifications, implying:

• Existing or increased additional duties under Section 232.
• Potential new or adjusted Chapter 99 provisions for these products.

2.2 Section 301 – enforcement focus

The agenda confirms ongoing and potential new Section 301 actions, which directly affect import duties via additional tariffs (typically implemented through HTS Chapter 99 subheadings). Key areas:

• Ongoing Section 301 actions:
• China’s compliance with the Phase One Agreement.
• Nicaragua’s labor practices.
• China’s shipbuilding practices.
• China’s semiconductor practices.
• Forthcoming reviews/actions:
• Four-Year Review of the Section 301 action on forced technology transfer (China) starting May 2026.
• Possible action in the Section 301 investigation related to enforcement of U.S. rights in WTO large civil aircraft disputes (could affect EU-origin aircraft and parts).

These may result in:

• Continuation, modification, or expansion of additional duties on Chinese-origin goods (and possibly other countries) across many HTS lines.
• New or adjusted Chapter 99 provisions for targeted sectors (e.g., shipbuilding, semiconductors, aircraft).

2.3 Agreement on Reciprocal Trade (ART) – supplemental tariffs

The ART program is structurally important for importers:

• ARTs signed with: Argentina, Bangladesh, Cambodia, El Salvador, Guatemala, Indonesia, Malaysia, Taiwan.
• Framework deals announced with: Ecuador, EU, India, Japan, North Macedonia, South Korea, Switzerland & Liechtenstein, Thailand, Vietnam (with intent to upgrade to full ARTs).

Key import-side feature:

• Each ART requires the United States "to maintain a modified tariff on the trading partner (i.e., a supplemental tariff higher than the statutory MFN rate)."

This means:

• Imports from ART partners are subject to additional duties above the standard Column 1 MFN rate, implemented via special tariff lines (likely Chapter 99) or modified rates.
• The document does not specify the exact percentages or HTS lines, but confirms the structural presence of these higher tariffs.

2.4 Critical minerals – forthcoming ATCM

The planned Agreement on Trade in Critical Minerals (ATCM) will:

• Establish "common border-adjusted price mechanisms" for specific minerals and downstream products.
• Include provisions on labor, environment, export controls, stockpiling, and competitiveness.

For importers, this likely means:

• Coordinated tariff or fee-like adjustments on imports of designated critical minerals and certain downstream products.
• Possible preferential treatment for imports from ATCM partners vs. non-partners.

Specific minerals and HTS lines are not listed, but expect coverage across:

• Ores and concentrates (Chapter 26).
• Refined metals and compounds (Chapters 28, 29, 38, 81).
• Battery materials and related intermediates.

3. Rate changes / duty impacts

The documents do not provide explicit numerical duty rates for U.S. imports (e.g., "10% to 25%") or specific Chapter 99 codes. However, they clearly indicate:

• The U.S. will maintain "supplemental" tariffs above MFN on imports from ART partners.
• Section 232 tariffs have been initiated or modified across numerous sectors in 2025 and will continue.
• Section 301 tariffs on China and potentially other countries will remain and may be adjusted after the Four-Year Review.
• A new ATCM will introduce border-adjusted price mechanisms (functionally similar to tariffs or variable levies) on critical minerals and downstream products.

Because no specific percentages are given, importers must refer to:

• Current HTSUS (including Chapter 99) for applicable Section 232 and 301 rates.
• Any USTR/Commerce Federal Register notices implementing ART-related supplemental tariffs.

4. Dates and timelines

Key dates and periods mentioned:

• April 2, 2025 – "Liberation Day":
• Launch of the reciprocal tariff program and the ART framework.
• 2025 – Section 232 actions:
• Investigations initiated or tariff modifications made in the listed sectors (steel, aluminum, autos, etc.).
• 2025–2026 – ART implementation:
• ARTs signed with multiple partners within 10 months of April 2, 2025.
• Framework deals with EU, India, Japan, etc., ongoing; upgrades to full ARTs expected in 2026.
• May 2026 – Section 301 Four-Year Review:
• USTR will commence the statutorily required Four-Year Review of the Section 301 action on forced technology transfer (China).
• July 2026 – Potential Section 301 action:
• USTR will consider whether to take action in the Section 301 investigation involving enforcement of U.S. rights in WTO large civil aircraft disputes.
• 2026 – USMCA Joint Review:
• USTR will lead the USMCA Joint Review with Mexico and Canada, which may result in changes to rules of origin, anti-transshipment measures, and other provisions that indirectly affect import treatment.

No explicit expiration dates are given for the existing Section 232/301 tariffs or ART supplemental tariffs; the policy intent is to maintain and potentially expand them.

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

5.1 Immediate review of tariff exposure

• Map your product portfolio against the sectors explicitly targeted by Section 232 and Section 301:
• Steel, aluminum, copper, timber/wood, autos and parts, trucks, semiconductors, pharmaceuticals, medical equipment/PPE, aircraft and parts, robotics/industrial machinery, polysilicon, critical minerals.
• For each product, confirm:
• Correct HTS classification (10-digit) and any applicable Chapter 99 provisions (Section 232, 301, or other trade remedies).
• Country of origin and whether it is an ART partner, Section 232 target, or Section 301 target.

5.2 ART partner imports – check for supplemental tariffs

• Identify imports from ART partners: Argentina, Bangladesh, Cambodia, El Salvador, Guatemala, Indonesia, Malaysia, Taiwan (and potentially Ecuador, EU, India, Japan, South Korea, Switzerland/Liechtenstein, Thailand, Vietnam as they upgrade to full ARTs).
• For these countries:
• Review current HTSUS and USTR/CBP guidance for any special tariff lines or Chapter 99 provisions imposing supplemental tariffs above MFN.
• Ensure broker instructions and internal systems correctly apply these additional duties.
• Reassess landed cost models and pricing for goods sourced from ART partners.

5.3 Section 232 sectors – monitor and document

• For products in the listed Section 232 sectors:
• Confirm whether additional Section 232 duties currently apply (and at what rate) for each country of origin.
• Monitor Commerce/BIS and CBP for any new or modified Section 232 measures in 2026.
• Maintain documentation to support any claims for exclusions or special treatment (if applicable under specific 232 programs).

5.4 Section 301 – prepare for Four-Year Review and potential changes

• For China-origin goods and other Section 301 targets:
• Inventory all imports subject to Section 301 duties and the applicable Chapter 99 subheadings.
• Monitor USTR announcements around May 2026 for the Four-Year Review of the forced technology transfer action.
• Be prepared for:
• Continuation of existing rates.
• Possible rate increases or expansions to additional HTS lines.
• Potential modifications or removals of some lines.
• Consider submitting comments or participating in any public consultation process if USTR opens one.

5.5 Critical minerals – anticipate ATCM impacts

• Identify any imports of critical minerals and related downstream products (e.g., battery materials, rare earths, strategic metals).
• Monitor USTR and Commerce for details of the ATCM, including:
• List of covered minerals and products.
• Structure of border-adjusted price mechanisms (tariff-like charges, variable levies, etc.).
• Participating countries and any preferential treatment.
• Begin scenario planning for:
• Higher effective duty/price levels on imports from non-ATCM countries.
• Potential sourcing shifts to ATCM partners.

5.6 Forced labor and supply chain compliance

• Note that multiple ART partners have committed to import bans on products made with forced labor.
• While this is a partner-side obligation, it reinforces U.S. expectations and may influence U.S. enforcement posture.
• Ensure:
• Robust supply chain due diligence and documentation for high-risk sectors (e.g., textiles, agriculture, seafood, mining, electronics).
• Alignment with U.S. forced labor enforcement (e.g., Uyghur Forced Labor Prevention Act) to avoid detentions and admissibility issues.

5.7 USMCA Joint Review – rules of origin and transshipment

• For imports under USMCA preferences (from Canada and Mexico):
• Expect potential tightening of rules of origin and anti-transshipment measures, especially in autos, steel, and other strategic sectors.
• Review origin documentation and supplier declarations to ensure they can withstand stricter scrutiny.
• Monitor the Joint Review outcomes for any changes that could affect eligibility for preferential duty rates.

5.8 Internal communication and budgeting

• Communicate to finance, sourcing, and operations that:
• Elevated tariffs on many imports are intended to be long-term.
• Additional measures (ATCM, expanded 301/232, ART supplemental tariffs) may further increase duty costs.
• Update:
• Duty budgets and landed cost models.
• Contract terms with suppliers (e.g., who bears tariff risk, price adjustment clauses).

6. References / where to find details

Primary policy document:

• The President’s 2026 Trade Policy Agenda (USTR):
• https://ustr.gov/sites/default/files/files/Press/Releases/2026/2026%20Trade%20Policy%20Agenda.pdf

Key implementation sources to monitor for concrete tariff/HTS details:

• Harmonized Tariff Schedule of the United States (HTSUS):
• For base MFN rates and Chapter 99 provisions (Section 232, 301, and any ART-related supplemental tariffs).
• Federal Register (USTR and Commerce/BIS notices):
• For specific Section 232 and 301 actions, including HTS lines and duty rates.
• USTR Section 301 page:
• For lists of covered products, rates, and review processes.
• Commerce/BIS Section 232 investigations page:
• For investigation reports, presidential proclamations, and tariff/exclusion details.
• CBP Cargo Systems Messaging Service (CSMS):
• For operational guidance to brokers and importers on applying new or modified tariffs and Chapter 99 codes.

7. Bottom line for compliance

• The White House and USTR documents confirm that higher and more targeted tariffs on U.S. imports are a central, ongoing policy tool, not a temporary measure.
• Importers in the named sectors and sourcing from ART partners, China, and other targeted countries should assume sustained elevated duty exposure and potential new measures in 2026.
• Proactive classification review, origin analysis, supply chain mapping, and monitoring of USTR/Commerce/CBP notices are essential to manage risk and cost under this evolving regime.