What Changed
Effective January 20, 2025President Trump invoked the International Emergency Economic Powers Act (IEEPA) on January 20, 2025, declaring the US trade deficit a national emergency and imposing emergency tariffs on imports from all trading partners. IEEPA authority was used as the legal basis for country-specific tariff rates throughout 2025 until the Supreme Court struck it down on February 20, 2026. The tariff action was one of the most sweeping uses of executive trade authority in modern US history.
Rate Changes
| Item | Before | After |
|---|---|---|
| Universal IEEPA tariff authority | Not invoked | Active — country-specific rates imposed |
Who's Affected
All US importers across every product category and sourcing country. The IEEPA tariffs created a new tariff regime on top of existing MFN rates, S232, and S301, significantly raising the effective tariff rate on imports throughout 2025. Businesses that had planned around pre-2025 tariff rates faced immediate cost increases requiring urgent supply chain and pricing reviews.
Analysis
IEEPA Tariff Authority Invoked: Universal Tariffs Imposed Across All Trading Partners (effective 2025-01-20). President Trump invoked the International Emergency Economic Powers Act (IEEPA) on January 20, 2025, declaring the US trade deficit a national emergency and imposing emergency tariffs on imports from all trading partners. The International Emergency Economic Powers Act (IEEPA) was enacted in 1977 to grant the President broad authority to regulate international commerce in response to a national emergency. The Trump administration used IEEPA as the primary legal authority for its tariff program beginning in 2025, arguing that the US trade deficit constituted a national emergency warranting tariff action. The Supreme Court's February 20, 2026 ruling held that while IEEPA grants broad economic powers, the authority to impose tariffs — a core legislative power — is reserved to Congress under Article I, Section 8. The ruling was a significant constraint on executive trade authority, though the administration moved rapidly to find alternative statutory bases, most notably enacting Section 122 tariffs four days later. The IEEPA ruling has broader implications for trade policy: it establishes constitutional limits on executive tariff authority and could affect how future administrations structure trade actions. Importers who paid IEEPA-based tariffs during 2025 may have legal grounds for refund claims; the CBP has not issued specific guidance on this as of this writing. For current US tariff rates and calculations, the relevant authorities are now Section 122, Section 232, Section 301, and bilateral trade deals — not IEEPA.
Impact & Next Steps
For most importers, the practical effect of the IEEPA ruling is minimal — the Section 122 tariffs enacted 4 days later maintain similar aggregate tariff levels. However, importers who paid tariffs under IEEPA authority in 2025 should consult with a customs attorney about potential refund claims. Ongoing trade litigation may further affect which tariff authorities remain in effect; monitor USTR and CBP bulletins for updates.