Section 122
Compliance Record
Reconstruct the tariff treatment of entries made during the 2026 temporary Section 122 surcharge: entry date, HTS classification, Chapter 99 reporting, exception status, Section 232 interaction, amount paid, broker treatment, and commercial closeout.
Do not treat Section 122 as a current tariff.
This guide is for entries associated with the February 24–July 24, 2026 temporary surcharge period. Current tariff treatment should be checked separately.
Reconstruct the entry as it existed on the entry date.
Historical tariff review should not apply today's tariff environment backward.
For each affected transaction, establish the classification, origin, entry or withdrawal date, applicable Chapter 99 provisions, exclusions, Section 232 status, amount paid, and contemporaneous broker or CBP treatment.
Eight questions for each historical entry.
When was it entered?
Establish the entry-for-consumption or warehouse-withdrawal date.
What was the HTS classification?
Preserve the tariff classification actually reported for the goods.
What was the country of origin?
Confirm the origin used for customs and trade-program treatment.
Was an exception available?
Match the product and entry to the proclamation and annexes.
Did Section 232 apply?
Determine whether the article or part was subject to Section 232 restrictions.
What Chapter 99 line was used?
Preserve the temporary-surcharge or exception reporting treatment.
What amount was paid?
Tie the surcharge to entry-level government payment records.
How was it closed commercially?
Reconcile inventory, landed cost, customer pass-through, credits, and accounting.
Keep the historical calculation auditable.
Never infer an exception from a product nickname.
The proclamation listed categories, but implementation depended on the detailed tariff provisions and annexes.
Customs treatment was only one part of the cost record.
Duty Payment
Tie the surcharge to government payment and customs-entry records.
Landed Cost
Determine how the surcharge entered inventory or cost-of-goods calculations.
Customer Pass-Through
Identify whether the charge was absorbed, billed, credited, or disputed.
Expiration Controls
Verify that pricing, broker instructions, and surcharge mechanics were removed or changed after the temporary period ended.
Historical Section 122 is not the current tariff map.
Use the current Section 301 guide and Current Updates for present-entry treatment.
This guide is intended for reconstruction and public education concerning historical 2026 entries. It is not a statement that the Section 122 surcharge remains in effect. Classification, origin, tariff-program interaction, correction procedures, accounting, and legal rights depend on the specific entry and contemporaneous governing record.
