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TIMELINES FOR TARIFF ACTION: THE KNOWN AND THE UNKOWN




While information on forthcoming tariff actions is incomplete and contradictory, some parameters have become clearer in recent weeks. The following general guidance is subject to change and interpretation.

Section 232 Timeline: The administration is considering sectoral tariffs of global reach under Sector 232 of the Trade Expansion Act of 1962 on imported goods valued at approximately $1.5 trillion. The Chamber, member companies, and other organizations have been submitting comments in recent weeks in an effort to influence any forthcoming action. It is anticipated that some may target China more than other countries; some may be more limited in scope (e.g., on copper, the aim may be to contest China’s near monopoly on processing as opposed to imposing new limits on copper mined in allied and FTA partner countries).

 

The Commerce Department has signaled that it is aiming to act on these Section 232 investigations approximately 90 days after their initiation, suggesting the following rollout timeline. However, other intelligence—and comments by Secretary Howard Lutnick—suggest a faster rollout.

  • Copper | mid-June
  • Lumber and forest products | mid-June
  • Semiconductors, electronics, and related equipment | early July
  • Pharmaceuticals | early July
  • Critical minerals | mid-July
  • Medium- and heavy-weight trucks and parts | late July
  • Civil aircraft, jet engines, and parts | early August

The Chamber understands additional Section 232 investigations focusing on different sectors are expected.

“Reciprocal” Tariffs: Talks are ongoing with about 20 countries (including the EU) with the goal of concluding deals by July 9, the date when the administration has threatened to increase its “reciprocal” tariffs to the levels announced on April 2. (The 90-day pause on higher tariffs on goods from China ends August 12.) Like the U.S.-UK deal reached on May 8, these deals are expected to mostly leave the Sector 232 tariffs and the 10% global “baseline” tariff in place. Whether the deadline may be extended likely depends on the tenor of discussions as well as economic and financial indicators as the date approaches.

Tariff Litigation: Litigation against the tariffs imposed using the International Emergency Economic Powers Act (IEEPA) is proceeding:

May 28: The U.S. Court of International Trade struck down the administration’s “fentanyl” tariffs on Canada, Mexico, and China; its 10% “baseline” tariff on other WTO members; and the authority to impose the deferred “reciprocal tariffs. The tariffs remain in place as an appeals court has issued an administrative stay.

  • Mid to late June: The Federal Circuit will either rule to leave the tariffs in place while it considers the appeal, or deny a stay, lifting the tariffs while it considers the appeal.
  • June/July: If the Federal Circuit denies a stay, the government will ask the Supreme Court to get involved. The Supreme Court may order oral argument on the stay motion.
  • July/August: Briefing of the case in the Federal Circuit.
  • September: Oral argument in the Federal Circuit.
  • Fall: The Federal Circuit will uphold or strike down the tariffs. The loser will appeal to the Supreme Court.
  • Spring 2026: Oral argument in the Supreme Court.
  • June 2026: Supreme Court term ends, latest date for a Supreme Court decision.

For further information, please contact Senior Vice President and Head of International John Murphy (jmurphy@uschamber.com).

 



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Western DuPage Chamber of Commerce
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