A Trade Policy Traffic Jam: Tariff Deadlines Collide in Late July 2026

The clearest deadline is mechanical. Section 122 of the Trade Act of 1974 lets the president impose a temporary import surcharge of up to 15% for a maximum of 150 days to address balance-of-payments problems. The administration used that authority in Proclamation 11012 to impose a 10% tariff on the vast majority of imports from all countries, effective February 24, 2026 — meaning the 150-day clock runs out on July 24, 2026. Congress could extend it, but that's considered unlikely, and the president cannot extend Section 122 tariffs unilaterally. Adding to the uncertainty, a divided three-judge panel at the US Court of International Trade ruled on May 7, 2026 that the Section 122 tariffs were unlawful; the government has appealed, but the underlying statutory expiration date arrives regardless of how that appeal proceeds.

Running in parallel, the US Trade Representative is conducting two Section 301 investigations covering 76 separate potential tariff determinations, which are expected to conclude before the Section 122 tariffs expire — effectively positioned as a potential replacement mechanism for at least part of the expiring blanket tariff.

The Brazil-specific track moves on its own separate timeline. On June 1, 2026, USTR determined that a range of Brazilian trade practices — spanning digital trade and electronic payments rules, preferential tariffs, anti-corruption enforcement, intellectual property protection, ethanol market access, and deforestation policy — were actionable under Section 301, and proposed a 25% tariff on Brazilian goods in response. After a public comment period through July 1 and a hearing on July 6, USTR faces a statutory deadline of July 15, 2026 to take responsive action, which could mean finalizing, modifying, or deferring the tariff. Some categories, including beef, coffee, rare earth metals, and aircraft parts, are proposed for exemption.