The $175 Billion Trade Reset: What 9 New Reciprocal Agreements Mean for Importers

The Supreme Court just invalidated $175 billion in tariffs. The administration responded within hours with a new 10% global surcharge — and a sprint to sign bilateral trade deals with dozens of countries. If you're importing goods into the United States, your landed costs are shifting under your feet. Here's exactly where things stand and what you should be doing about it.

On February 20, 2026, the Supreme Court dropped a bomb on the U.S. trade landscape. In a 6-3 decision authored by Chief Justice Roberts and joined by an unusual coalition spanning Gorsuch to Kagan, the Court ruled that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs. Just like that, the entire reciprocal tariff framework built since April 2025 — covering rates from 10% to 41% across 95 countries — was struck down.

The Penn-Wharton Budget Model estimates those tariffs had collected roughly $175 billion to $179 billion from importers. Whether any of that money comes back remains an open question. But the administration didn't wait around to find out.

Within hours of the ruling, President Trump signed a proclamation imposing a new 10% global import surcharge under Section 122 of the Trade Act of 1974. That surcharge took effect on February 24, 2026. And here's the catch that every importer needs to understand: Section 122 tariffs are capped at 15% and can only last 150 days without Congressional approval. That clock runs out on July 24, 2026.

So what's the long game? Agreements on Reciprocal Trade (ARTs) — bilateral deals that lock in tariff rates and market access concessions country by country. Nine are already signed. More are in the pipeline. And a newly released 500+ page government report is telegraphing exactly where negotiations are headed.

The New Three-Layer Tariff Cake

Before diving into the ARTs, you need to understand the current tariff structure, because it's no longer one-size-fits-all. Your goods now face up to three layers of duties:

1. Normal duty rate — the MFN rate from the Harmonized Tariff Schedule
2. Section 122 surcharge — 10% on virtually all imports, effective February 24, 2026
3. Section 232 and 301 tariffs — steel, aluminum, Chinese goods, and other targeted products remain fully in effect

The Section 122 surcharge uses HTS subheading 9903.01.25 on entry summaries. If your goods qualify for an exclusion, you'll report 9903.01.32 instead. Articles with 20% or more U.S. content get the surcharge applied only to the non-U.S. portion under 9903.01.34.

The ARTs are designed to eventually replace this patchwork. Countries that sign deals get preferential treatment. Countries that don't keep paying the full surcharge — or worse, whatever comes after it when the 150-day window closes.

Nine Deals Signed: The ART Landscape

The administration has been moving fast. As of April 2026, nine ARTs have been formally signed:

The Bangladesh deal is the most detailed example of how these agreements work. The U.S. maintains a 19% reciprocal tariff on most Bangladeshi imports but grants a zero percent rate on products listed in Annex III of Executive Order 14346. In exchange, Bangladesh committed to:

• Accept vehicles meeting U.S. Federal motor vehicle safety and emissions standards
• Accept FDA certificates for medical devices and pharmaceuticals
• Remove restrictions on remanufactured U.S. goods
• Join key international IP treaties
• Permit free transfer of data across trusted borders
• Prohibit forced and compulsory labor in imports

The deal also included $3.5 billion in agricultural commercial deals covering wheat, soy, and cotton. For context, the U.S. goods trade deficit with Bangladesh was $6.1 billion in 2024 — so these purchase commitments are substantial.

Framework Deals: Who's Next in Line

Beyond the nine signed agreements, framework deals have been announced with some of the biggest U.S. trading partners:

• European Union
• Japan
• South Korea
• India (reciprocal rate lowered from 25% to 18% before IEEPA was struck down)
• Switzerland and Liechtenstein
• Thailand
• Vietnam
• North Macedonia

These frameworks signal intent but aren't binding yet. The speed at which they convert to signed ARTs will determine tariff rates for billions of dollars in trade. And there's a very specific document telling us which countries face the most pressure to close deals quickly.

The NTE Report: USTR's Negotiating Playbook

On March 31, 2026, the USTR released the 2026 National Trade Estimate (NTE) Report on Foreign Trade Barriers — and it's not just a dry policy document. At over 130 pages longer than last year's edition, it's essentially a country-by-country catalog of every trade barrier the administration plans to use as leverage in ART negotiations.

Here's what makes this year's report different:

• The phrase "excess capacity" appears 137 times, up from just 26 in the 2025 edition
• References to "forced labor" more than doubled
• New sections on non-market policies and practices were added for the first time
• Commitments made under existing ARTs are woven throughout the country chapters

Think of the NTE as a preview of coming attractions. If a country's section got longer, expect tougher negotiations. If specific barriers are called out by name, those are the concessions the U.S. will demand.

South Korea: A Case Study in NTE Pressure

South Korea's section expanded from 7 to 10 pages — despite Seoul pledging $350 billion in U.S. investment in November 2025. The report flagged:

• Soybean quotas: Korea plans to limit 2026 imports to the WTO minimum of 185,787 tons, potentially reducing U.S. exports by 30,000 tons
• Rice bidding suspensions: Frequent suspensions of U.S. table rice sales under the 132,304-ton annual quota
• AI procurement discrimination: A May 2025 government tender for GPUs and cloud services excluded foreign companies entirely
• High-precision map restrictions: New requirements mandating domestic data centers as a condition for map data exports

For importers sourcing from South Korea, the message is clear: until an ART is signed, expect continued uncertainty and potentially higher rates.

What This Means for Your Bottom Line

The practical impact on importers depends entirely on where you're sourcing from:

Sourcing from ART countries (9 signed deals): Your tariff rate is defined by the specific agreement. Review the tariff schedules published with each ART to determine whether your products qualify for reduced rates. The Bangladesh deal, for example, offers zero-rate treatment for products on the Annex III aligned-partner list.

Sourcing from framework countries (EU, Japan, Korea, India): You're currently paying the 10% Section 122 surcharge plus normal duties. Rates could improve when a deal is signed — or get worse if negotiations stall and the administration moves to Section 232 or 301 actions.

Sourcing from countries with no deal: You're paying the full 10% surcharge, and there's no indication that will improve. If anything, the July 24 expiration creates a cliff where rates could jump if Congress authorizes higher tariffs or the administration finds alternative legal authority.

Action Steps for Importers

1. Map your supply chain to the ART landscape — For every country you source from, determine whether an ART is signed, a framework is announced, or neither. This is now the single biggest variable in your landed cost calculations.

2. Read the tariff schedules for signed ARTs — Each agreement publishes specific product schedules. Don't assume your goods qualify for reduced rates — verify against the actual schedules on USTR.gov.

3. Audit your HTS classifications now — With the shift from IEEPA to Section 122, Chapter 99 secondary classifications have changed. Confirm your entries use the correct subheadings (9903.01.25 for the surcharge, 9903.01.32 for exclusions, 9903.01.34 for U.S.-content adjustments).

4. Monitor the NTE report for your source countries — If your key sourcing country got a longer section in the 2026 NTE, expect trade friction. Consider identifying alternative suppliers in ART countries as a hedge.

5. Preserve your IEEPA refund rights — The Supreme Court ruled IEEPA tariffs unlawful, but refund mechanisms are still being worked out. File protests on any unliquidated entries where you paid IEEPA tariffs. The window for action is limited.

6. Model the July 24 scenario — Build financial models for three scenarios: Section 122 expires with no replacement, Congress extends at 10-15%, or new tariff authority raises rates. Your procurement decisions for Q3 should account for all three.

The July 24 Cliff: What's Coming Next

The 150-day clock is the most important date on every importer's calendar right now. Here's what could happen when Section 122 authority expires on July 24, 2026:

Scenario 1: Congress extends. The administration lobbies Congress to authorize the surcharge beyond 150 days, potentially at the higher 15% rate Trump floated but never implemented. This requires affirmative legislation — not just inaction.

Scenario 2: New legal authority. Administration officials have publicly signaled they're developing tariff actions under Section 232 (national security) and Section 301 (unfair trade practices) to take effect before the Section 122 window closes. These authorities don't have the same time limits.

Scenario 3: Tariffs lapse. Without Congressional action or new executive authority, the surcharge simply expires. The only remaining tariffs would be those under Sections 232 and 301 — meaning many goods would see a dramatic cost reduction overnight.

The administration appears to be betting on a combination of Scenarios 1 and 2, using the 150-day window to build a more legally durable tariff framework. But the uncertainty is real, and importers who wait until July to plan will be too late.

Reading the Tea Leaves

The trade landscape hasn't been this fluid since April 2025, when the original reciprocal tariffs were announced. But there's actually more clarity now than there was then. The ARTs tell you exactly where the administration wants to end up — bilateral deals with defined rates and specific concessions. The NTE report tells you which countries face the most pressure. And the Section 122 clock tells you when the next inflection point hits.

Smart importers are using this window to diversify supply chains toward ART countries, lock in favorable classifications, and build contingency plans for the July deadline. The tariff landscape is going to look very different by the end of Q3 — and the importers who planned ahead will have a significant cost advantage.

Tools like TariffLens can help you model these scenarios across your full product catalog, flagging which HTS codes are affected by each ART and tracking rate changes in real time as new agreements are signed.

This article is for informational purposes only and does not constitute legal, tax, or customs advice. Consult a licensed customs broker or trade attorney for guidance specific to your situation.