The 150-Day Clock: Navigating the Imminent Expiration of Section 122 Tariffs

The trade world shifted rapidly earlier this year when the Supreme Court struck down the administration's sweeping reciprocal tariffs levied under the International Emergency Economic Powers Act (IEEPA). To maintain its trade policy framework, the administration quickly pivoted to Section 122 of the Trade Act of 1974 to establish a temporary 10% global import surcharge.

However, Section 122 operates under a critical constraint that is about to impact importers this week: a strict 150-day statutory limit.

The July 24 Deadline: What Happens Next?

Unless Congress steps in to extend them—which is highly unlikely at this stage—the Section 122 tariffs are set to expire by operation of law at 12:01 AM EDT on Friday, July 24.

Barring any last-minute legislative extensions or surprise replacement mechanisms, headings 9903.03.01 through 9903.03.11 will officially show as expired in the Automated Commercial Environment (ACE). Automated software systems will flag these codes as invalid, and entries should be prepared reflecting that the 10% surcharge no longer applies.

The Regulatory Mechanics

For trade compliance teams, understanding the exact legal application of this expiration is vital. The trigger for the Section 122 tariff has strictly been based on the date of entry for consumption (or withdrawal from a bonded warehouse for consumption), rather than the physical arrival date of the shipment at the port.

Because the surcharge applies exclusively to goods entered during the designated 150-day window, documentation timelines must be managed with absolute precision to mirror the true legal status of the goods at the exact moment of filing.

Compliance Meets Strategy: The ACM Advantage

This high-stakes deadline is a perfect example of why having a dedicated customs partner matters. Rapidly changing tariff rules require deep regulatory oversight to prevent administrative errors, automated filing rejections, and costly delays at the port.

At ACM, we actively track these moving regulatory targets so our clients don't have to. We analyze the exact language of customs proclamations to ensure your documentation matches the literal letter of the law—ensuring you pay exactly what is required, while maintaining total compliance with U.S. Customs regulations.

Have shipments filing this week? Contact the ACM team today to ensure your upcoming entry data is fully aligned with the July 24 regulatory transition.