Looking Ahead: Key Tariff Updates For 2026
Jan. 12, 2026
As we enter 2026, HIDA continues to lead efforts to navigate tariff policies that impact our members. Here’s a look at the critical developments we're monitoring this year.
Supreme Court Decision: Pending
The Supreme Court will issue a decision in the case of Learning Resources, Inc. v. Trump, which challenges the legality of tariffs imposed under the International Emergency Economic Powers Act (IEEPA). Oral arguments were heard in November , and a decision is expected in early 2026. Read More.
Tariff Refund Cases: Paused Until SCOTUS Ruling
A December 23, 2025 order from the U.S. Court of International Trade (CIT) pauses all lawsuits seeking IEEPA tariff refunds until the Supreme Court rules on the legality of IEEPA tariffs. Multiple businesses, including Costco, filed lawsuits to preserve their ability to claim tariff refunds before the tariffs were finalized. Read More.
232 Tariff Investigation: Ongoing
Last fall, the Department of Commerce launched a Section 232 national security investigation on most medical products, which could result in additional tariffs. HIDA submitted public comments to inform the investigation, encouraging the administration to consider positive incentives to bolster domestic manufacturing instead of levying additional tariffs on medical products. Commerce is required to complete its investigation by May 30, 2026.
China Section 301 Tariffs: Increased
Tariffs on certain Chinese medical products increased on January 1, 2026. Below are the new rates for face masks and medical gloves.
- Face Masks
- HTS Number: 6307.90.9842; 6307.90.9844; 6307.90.9850; 6307.90.9870; 6307.90.9875
- Tariff Increase from 25 to 50%
- Medical Gloves
- HTS Number: 4015.12.10
- Tariff Increase from 50 to 100%
USMCA Review: Pending
The United States–Mexico–Canada Agreement (USMCA) will undergo a formal review starting in July 2026. The Administration has indicated they are not inclined to "rubberstamp" the existing agreement and are willing to let the current USMCA expire if another trade agreement cannot be negotiated. Read More.
HIDA Resources
The HIDA Tariff Policy Clearinghouse continues to provide a variety of resources on trade, including:
- A new interactive map tracking reciprocal tariff rates for selected countries around the world, including key parts of the medical supply chain.
- A one-pager outlining rules of origin — the specific criteria, laws, and regulations that determine a product's country of origin for the assessment of tariffs.
- An infographic on medical product tariffs, which explains how multiple tariffs under differing legal authorities cumulatively stack together.
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