Q4 2026 is shaping up to be one of the most consequential quarters for importers in recent memory. Between forced-labor tariffs already in effect, a second wave of overcapacity tariffs still pending, and active litigation that could shift the landscape again, there’s a lot to track. Here’s where things stand, what’s coming, and what you should be doing right now.
Where Things Stand Today
If you’ve been following along, you know the basics: after the Supreme Court struck down IEEPA tariffs in February 2026, the administration moved quickly to replace them. Effective July 24, the Section 122 global surcharge was replaced by new tariffs of 10% or 12.5% imposed under Section 301 on imports from 60 trading partners representing approximately 99% of U.S. imports.
Those tariffs are in effect now, and they’re being challenged in court — by 25 state attorneys general, two private importers, and a consumer advocacy group. The administration’s answer to the states’ complaint is due October 2. That’s worth watching, but don’t plan your Q4 around it. Litigation moves slowly. Tariffs are collected today.
The Second Wave Is Still Coming
Here’s the part that’s still ahead: USTR launched two parallel Section 301 investigations in March 2026 — one targeting manufacturing overcapacity across 16 countries, and one targeting forced labor enforcement failures across 60 countries. The forced-labor action is done and in effect. The overcapacity investigation is still pending.
The overcapacity investigation targets sectors including aluminum, automobiles, batteries, cement, chemicals, electronics, energy goods, glass, machinery, non-ferrous metals, robotics, semiconductors, ships, solar modules, steel, and transportation equipment — across 16 economies: China, the EU, Singapore, Switzerland, Norway, Indonesia, Malaysia, Cambodia, Thailand, Korea, Vietnam, Taiwan, Bangladesh, Mexico, Japan, and India.
No tariff determination has been announced yet. But if your supply chain touches any of those sectors or countries, this is not something to monitor passively. The forced-labor investigation moved from initiation to tariffs in about four months. The overcapacity investigation has been running since March.
Your Q4 Action Checklist
1. Confirm your tariff tier and make sure the math is right.
The forced-labor tariffs aren’t uniform. Countries like the UK, India, and Canada carry a flat 10% add-on. China, Brazil, Vietnam, and 35 others carry 12.5% — and for China, that stacks on top of pre-existing Section 301 duties from the original 2018 actions. The EU, Taiwan, Japan, South Korea, and Switzerland operate under net-of-MFN capped rates. If your landed cost models haven’t been updated to reflect the correct tier and stacking behavior for every origin country, that’s the first fix.
2. Verify your exemptions — don’t assume.
USMCA-qualifying goods from Canada and Mexico that are entered duty-free are exempt from the forced-labor duty. Goods already subject to Section 232 steel, aluminum, and copper tariffs are also exempt. But eligibility isn’t automatic — it has to be correctly documented and claimed on entry. If your broker hasn’t verified this at the line-item level, it’s worth a review.
3. Check your customs bond.
This one catches people off guard. A 10–12.5% duty increase across a broad import portfolio can significantly raise your total annual duty liability, which means your continuous customs bond limit may no longer be adequate. CBP can issue insufficiency notices with limited warning. Talk to your surety now, before Q4 volume picks up.
4. Get your supply chain documentation in order.
CBP is actively focused on forced-labor compliance, and inquiry timelines are tight. If a shipment is flagged, you may need to produce a comprehensive traceability portfolio within 24 hours — covering country-of-origin documentation, supplier maps through at least Tier 2 or 3, and recent labor compliance records for foreign facilities. If that documentation doesn’t exist or isn’t organized, now is the time to build it.
5. Map your overcapacity exposure.
If you import semiconductors, electronics, industrial machinery, steel, aluminum, or batteries from any of the 16 countries under investigation, model the cost impact of an additional tariff now — before a determination is announced. The forced-labor investigation didn’t give importers much runway. Don’t wait for the Federal Register notice to start the conversation with your sourcing team.
6. Watch October 2.
The administration’s response to the states’ Section 301 lawsuit is due that day. It won’t resolve the litigation, but it will signal how aggressively the government intends to defend the legal basis for these tariffs — and whether any modifications or exemptions might be forthcoming.
The Bottom Line
This is a lot to manage. But the importers who come through Q4 in the best shape will be the ones who treated these tariffs as a permanent operating reality — not a temporary disruption to wait out.
At Coppersmith Global Logistics, we help clients navigate exactly this kind of environment: understanding what applies, what’s exempt, and how to keep cargo moving when the rules keep changing.
If you want to talk through how Q4 looks for your supply chain, reach out to our team.
