This article analyzes the February 2026 U.S. tariff policy adjustments: IEEPA tariffs stopped but 122 clause import surcharge imposed; China Commerce Ministry response; legal and business impact analysis; global supply chain restructuring trends; key issues for 6th round China-U.S. consultations; enterprise recommendations.
Overview of Latest US Tariff Policy Adjustments
In the early morning of February 24, 2026, U.S. Customs, according to relevant U.S. government announcements, stopped collecting tariffs imposed under the International Emergency Economic Powers Act (IEEPA) and began imposing import surcharges on all trading partners under Section 122 of the Trade Act of 1974. This policy adjustment marks a new phase in tariff policy during Trump’s second term. According to U.S. Supreme Court tariff litigation rulings and relevant executive orders, the U.S. has stopped collecting the 10% so-called fentanyl tariffs and 34% reciprocal tariffs imposed on Chinese goods in early February and April 2025, with the actual tariff level on China being 20%.
However, the U.S. simultaneously imposed a 10% import surcharge under Section 122 and indicated in multiple occasions that it would use Section 301 and 232 investigations to impose tariffs. This policy volatility not only increases global trade uncertainty but also forces enterprises worldwide to reassess supply chain layout and risk management strategies.
China Commerce Ministry’s Official Response
In response to U.S. tariff adjustments, China Commerce Ministry spokesperson clearly stated: China is closely monitoring and will comprehensively evaluate relevant U.S. measures, and will decide on adjustments to countermeasures against original U.S. fentanyl tariffs and reciprocal tariffs at an appropriate time based on circumstances. China will reserve the right to take all necessary measures to firmly defend its legitimate rights and interests. This response reflects China’s strategic composure in trade disputes—neither proactively escalating conflicts nor abandoning countermeasure rights.
The Commerce Ministry emphasized that China has always opposed all forms of unilateral tariff measures and urged the U.S. to cancel and not impose relevant unilateral tariffs. Practice has repeatedly proven that cooperation benefits both China and the U.S., while confrontation hurts both. China is willing to conduct frank consultations with the U.S. in the upcoming 6th round of China-U.S. economic and trade consultations.
Legal and Business Impact of Section 122 Tariffs
Section 122 of the Trade Act of 1974 authorizes the President to impose import surcharges when there is a serious deficit in international payments, with tariff rates up to 15% and a maximum duration of 150 days. Unlike Section 301, Section 122 does not require lengthy investigation procedures, allowing the President to implement quickly. The activation of this clause reflects the U.S. government’s attempt to maintain tariff pressure on trading partners while avoiding WTO rule constraints.
From a business impact perspective, the 10% import surcharge will directly increase costs for U.S. importers. For consumer goods importers with already thin profit margins, this cost may be difficult to fully pass on to consumers, leading to further compressed profit margins. More critically, policy uncertainty makes it difficult for enterprises to conduct long-term supply chain planning.
Global Supply Chain Response and Restructuring Trends
Facing repeated U.S. tariff policy adjustments, global supply chains are accelerating restructuring. First is market diversification: enterprises no longer overly rely on single markets but actively explore emerging markets such as ASEAN, Middle East, and Latin America. In 2025, China’s exports to ASEAN grew 12.8%, and exports to Latin America grew 9.3%. Second is production localization: to avoid tariff barriers, more Chinese enterprises are building production bases overseas. Third is supply chain digitalization: enterprises enhance supply chain visibility and agility through digital means to quickly respond to policy changes.
Key Issues for 2026 China-U.S. Economic and Trade Consultations
The upcoming 6th round of China-U.S. economic and trade consultations is expected to focus on: tariff mutual exemption scope, supply chain security, digital trade rules, and green trade. The success or failure of consultations will directly affect global supply chain stability in 2026.
Enterprise Action Recommendations
Facing continuous tariff policy volatility, enterprises should: strengthen policy monitoring; optimize supply chain layout using “China+1” or regionalization strategies; enhance product value-added through technological innovation and brand building; and make good use of trade remedy tools. Ultimately, tariff policy is only an external environmental variable—true enterprise competitiveness comes from internal capabilities: technological innovation, supply chain management, brand influence, and talent attraction.
Source: mofcom.gov.cn
