July 2026 U.S. Tariff Actions: What it Means for the Cold Chain

July 24, 2026

Background

The United States Trade Representative (USTR) finalized Section 301 tariffs of 10% or 12.5% on 60 trading partners (about 99% of U.S. import volume) yesterday, citing failure to enforce forced-labor import bans. This is the third iteration of the broad tariff push this year: first the “Liberation Day” International Emergency Economic Powers Act (IEEPA) tariffs (struck down by the Supreme Court in February), then the flat 10% Section 122 surcharge, which was always capped at 150 days by statute and expired at 12:01 a.m. today, July 24.

This forced-labor action (so-called Section 301 tariffs) was announced back in June specifically to have something “ready to slot in” once Section 122 lapsed.

The rates are structured on two tiers:

• Countries with a forced-labor import ban (or a commitment to one) get 10% — UK, Canada, Mexico, India, Indonesia, the EU, among others.
• Everyone else gets 12.5% — Australia, NZ, China, Brazil, Vietnam, Thailand. USMCA-qualifying goods and a broad list of ag products are exempt outright. For high-MFN countries (EU, Japan, Korea) the new tariff is capped so the combined duty doesn’t exceed 10% to 12.5%.

By main cold chain categories

• Beef — Exempt across the board, bovine is named specifically in the exemption annex. No real change here; it was already sheltered under the prior regime too.
• Pork — Not exempt. I went through the actual USTR annex line by line — only bovine tariff codes appear in the meat section, nothing for pork. EU (mainly Denmark/Spain/Netherlands, our #2 supplier behind Canada) picks up the 10% with no carve-out. Canadian/Mexican pork stays protected via USMCA.
• Chicken — Not exempt. Thailand, the main source of cooked/prepared chicken given the U.S. ban on raw poultry imports, sits at 12.5%. Same for Brazil, though volume into the US is smaller.
• Lamb/mutton/goat — Not exempt. Australia and NZ, who supply the large majority of U.S. lamb, are both at 12.5%. It’s a 2.5-point bump rather than a new tax (they were already at 10% under Section 122) — but there’s a separate U.S. lamb safeguard investigation running in parallel that’s a bigger medium-term risk than this bump.
• Seafood — The most unresolved. No confirmed exemption for shrimp/salmon/pangasius. There’s a separate, still-open Section 301 probe specifically on seafood and forced labor (targeting Vietnam among others), decision expected Q3–Q4.
• Frozen veg/fruit — The exemption list names specific fresh tropical items (banana, mango, pineapple, papaya) but standard frozen vegetables and fruit — things the U.S. grows domestically — aren’t named. This means most other products imported from outside North America will continue to be tariffed. Mexican/Canadian frozen product are still covered via USMCA regardless of the general ag list.

What Happens Now and the Legal Risk

Worth flagging: this is the administration’s third attempt at broad tariff authority this year, and the first two didn’t survive intact — IEEPA tariffs struck down by the Supreme Court in February, Section 122 only lived out its term because it had a hard 150-day statutory clock rather than getting struck down outright. Trade lawyers are already calling this one legally exposed too: it’s the first time Section 301 — a statute built for action against individual countries over specific practices — has been used as a blanket two-tier tariff on 60 countries covering roughly 90% of world trade, with no real differentiation matching the severity of each country’s conduct.

Importers have standing to challenge this at the U.S. Court of International Trade, and given the CIT already ruled against the administration’s justification for Section 122, it will be unlikely these rates will hold for the full year. No lawsuit filed yet as of this morning.

Canada

Worth noting: President Trump signed proclamations on July 20 imposing 50% tariffs on select Canadian goods — wine, hockey sticks, cement, among others — using Section 338 of the 1930 Tariff Act, a rarely-invoked and untested authority.

This is telling. Given IEEPA and Section 122 have both been struck down or expired this year; the administration seems to be reaching for whatever legal lever is still standing. The stated trigger is Canada’s “discriminatory treatment” of U.S. goods, pointing specifically to an 81% collapse in Canadian imports of U.S. alcohol since the consumer boycott took hold last year, plus the usual grievances over dairy and auto market access. Carney’s pushed back hard, calling it “a breach of CUSMA” and noting Canada has already presented comprehensive proposals to modernize the agreement.

GCCA believe this to be a negotiating tactic, not settled policy. Trump and Carney agreed on July 21 to accelerate trade talks specifically to head off the 50% rate before it fully bites, and Carney’s line since has been “everything is on the table” — tough public posture, but clearly buying time for a comprehensive deal rather than letting this escalate. Canada is also caught in today’s forced-labor tariff (10% tier, CUSMA-qualifying goods still exempt), so Ottawa is now negotiating against two separate tariff clocks at once.

The assumption?  ‘Accelerated talks’ will produce something before the 50% deadline.