Understanding the Current Tariff Landscape: Key Developments for Middle-Market Companies

Navigating the modern tariff environment

For many middle-market companies, tariffs have moved from a customs compliance concern to a critical, everyday, strategic business issue. Today’s environment is built around navigating a complex mix of product-specific tariffs, country-specific actions, temporary surcharges, exclusions, and proposed new duties that can materially affect costs, sourcing decisions, pricing strategies, and profitability.

Leadership teams need a practical understanding of the major tariff developments shaping the import landscape and how those changes may affect their organizations.

Multiple tariffs remain in effect

One of the most significant developments continues to be the use of Section 232 tariffs on products deemed important to national security. Steel, aluminum, and copper products remain key areas of focus. Recent modifications have expanded or clarified coverage for certain derivative products, including agricultural equipment, residential HVAC systems and components (at a reduced 15% rate), mobile industrial equipment, aluminum lithographic plates, and steel racks.

For companies importing products that contain metal components, tariff exposure is levied on finished product itself, and the materials incorporated into it. As a result, accurate product classification and supply chain visibility have become increasingly important, particularly for manufacturers, distributors, equipment suppliers, and companies that rely on imported components.

Section 122 temporary import surcharge July 24 deadline approaching

In addition to Section 232 duties, many imported goods are currently subject to a temporary 10% import surcharge under Section 122. This surcharge applies separately from other tariff programs and is scheduled to remain in effect until July 24, 2026, unless suspended, terminated, or extended by Congress.

With such uncertainty around the future of tariffs, companies should closely monitor developments and evaluate how potential expirations or extensions could affect pricing, inventory planning, sourcing strategies, and customer commitments. There have been no updates regarding an extension, and if Section 122 expires with the given deadline, cost assumptions may change quickly. If it is extended or modified, companies may need to reassess margins, supplier terms, purchase timing, and pass-through pricing, as tariffs will begin to layer and could become more complex.

Section 301 developments extend beyond China, include 60 key trading partners

While Section 301 tariffs are often associated with China, the authority has become a broader trade policy tool that continues to shape the global sourcing environment. China-related Section 301 tariffs remain in effect for many products, and certain exclusions have been extended through November 2026, providing potential cost relief for qualifying importers.

At the same time, the Office of the United States Trade Representative has expanded its use of Section 301 investigations. Recent investigations and trade actions have involved more than 60 countries, reflecting a wider focus on foreign trade practices, market access concerns, digital trade policies, and other issues that may result in future tariff actions.

For middle-market companies, the key takeaway is that Section 301 exposure is no longer limited to imports from a single country. Businesses should monitor developments across their supplier base and sourcing footprint, particularly if they rely on imports from countries that could become subject to future trade actions.

Companies should also review product classifications, supplier records, and country-of-origin information to understand where potential exposure exists. Proposed Section 301 actions may influence supplier negotiations, purchasing decisions, inventory strategies, and customer pricing well before any tariffs are formally implemented.

What you should do now

The current tariff environment requires ongoing monitoring and active planning. Companies should work with their advisors, customs brokers, and supply chain teams to identify products affected by existing tariffs, evaluate eligibility for exclusions, and assess exposure to proposed trade actions.

Leadership teams should consider whether their organizations have recently reviewed product classifications, country-of-origin exposure, supplier documentation, and tariff exclusion eligibility. They should also model multiple cost scenarios to understand how expiration, extension, modification, or new duties could affect margins, pricing, and cash flow.

Tariff planning should involve finance, procurement, supply chain, tax, legal, and operations teams so potential cost changes are reflected in broader business decisions.

Tariffs require a strategic approach

Tariffs have become dynamic variables that influence sourcing, procurement, pricing, inventory management, customer negotiations, and long-term planning. They are one of the most influential external forces on businesses today.

For middle-market companies, the risk is not only paying higher duties. It is making business decisions based on incomplete or outdated tariff assumptions. Companies that proactively evaluate tariff exposure are often better positioned to respond quickly when policies change.

UHY works with middle-market companies to help evaluate tariff exposure, assess planning opportunities, and connect trade developments to broader business strategy. In a rapidly changing environment, informed planning can help companies move from reacting to tariff changes to making more confident, forward-looking decisions.

Assess Your Evolving Tariff Exposure