When Section 122 expires July 24, 2026, three plausible scenarios follow: (A) Congressional extension or replacement legislation, (B) Section 232 sectoral expansions covering specific industries, or (C) tariff vacuum where most non-Section-301 imports revert to MFN. Each has different implications by sector. Forward-pricing decisions through expiration require modeling under all three.
This guide covers section 122 successor scenarios – what comes after july 24 for SMB importers. Each section walks through the practical implications and the documentation required.
For background, see /section-122-tariff-guide/ and /ieepa-refund-guide/.
Scenario A – Congressional extension or replacement
Most operationally stable. Bill extends Section 122 or replaces it with a parallel statute before July 24. Probability low-moderate; trade-policy votes have political costs.
Scenario B – Section 232 sectoral expansion
Most likely. Pharma 232 takes effect July 31. MedTech and semiconductor 232 in flight. Other sectors revert to MFN. Probability moderate-high.
Scenario C – Tariff vacuum
Section 122 expires; minimal sectoral coverage. Most non-Section-301 imports revert to MFN. Politically unappealing but operationally possible.
What SMB importers should be doing now
Track exposure under each scenario. Verify USMCA qualification status. File IEEPA refunds (separate process). Build successor scenarios into rest-of-2026 budget.
Frequently asked questions
How does this affect my forward planning?
Build the relevant scenario into your 2026 budget. We can run a fixed-fee scenario model for $4,500-$8,500 covering your specific exposure.
What documentation supports this?
Standard CBP Form 7501 entry summary, supplier-provided Certificates of Origin where USMCA-relevant, and origin documentation for substantial transformation claims. We review documentation as part of typical engagements.
Are there court cases I should track?
Yes – see /ieepa-litigation-cit-watch/ for current case status.
When should I engage a consultant?
For exposure above $50,000 annual or filings above $50,000 recoverable. Below those thresholds, self-management with our written guides usually works.
How do I get started?
Book a 15-minute scoping call. We confirm fit and scope before any engagement letter.
Get started
Book a 15-minute scoping call to discuss your situation.