On 20 February 2026, hours after the Supreme Court held in Learning Resources, Inc. v. Trump (No. 24-1287), consolidated with Trump v. V.O.S. Selections, Inc. (No. 25-250), that the International Emergency Economic Powers Act does not authorise the President to impose tariffs, the White House issued Executive Order 14389, “Ending Certain Tariff Actions,” terminating the additional ad valorem duties imposed under the IEEPA tariff arc.¹² The order is a framework instrument; U.S. Customs and Border Protection halts collection at 12:00 a.m. eastern standard time on 24 February 2026 for entries on or after that moment under CBP Cargo Systems Messaging Service Bulletin CSMS

67834313.³ The order terminates the

additional duties imposed under Executive Orders 14193 (Canada fentanyl), 14194 (Mexico fentanyl), 14195 (China fentanyl), 14245 (Venezuela secondary), 14257 (reciprocal), 14323 (Brazil), 14329 (Russia secondary), 14380 (Cuba secondary) and 14382 (Iran secondary); it expressly leaves unaffected the same-day executive order “Continuing the Suspension of Duty-Free De Minimis Treatment for All Countries” and the same-day § 122 surcharge proclamation.⁴

1. Goods entered for consumption between the Supreme Court ruling and the 24 February 2026 collection-stop time clear at the prior IEEPA rates; importer refunds for duties already collected proceed under 19 U.S.C. § 1514 (protests against decisions of the Customs Service), § 1520 (refunds and errors) and § 1505(c) (interest on refunds), with the CBP CSMS bulletin specifying the administrative reliquidation mechanism.⁵ HTSUS Chapter 99 subchapter III subheadings 9903.01.01 (Mexico fentanyl), 9903.01.10 (Canada fentanyl), 9903.01.20 (China fentanyl), and the 9903.01.25 reciprocal-baseline series are deactivated in the Automated Commercial Environment for entries on or after the collection-stop time.⁶

2. The order does not invoke the National Emergencies Act § 1622 termination procedure, 50 U.S.C. § 1622; the § 1701 national-emergency declarations underlying the affected orders therefore remain in force notwithstanding the tariff revocation, and non-tariff IEEPA actions (sanctions designations under § 1702(a)(1)(B) blocking authority, export-control measures) are unaffected.⁷

3. Section 232 duties on steel, aluminum and autos (Proclamations 10895, 10896, 10908 and successors) and Section 301 duties on Chinese goods (USTR’s 2018-2024 list actions) are outside the order’s scope and continue to be collected at their current HTSUS Chapter 99 subchapter III subheadings.⁸ A parallel proclamation invoking § 122 of the Trade Act of 1974 imposes a 10 percent ad valorem balance-of-payments surcharge effective 24 February 2026 (see Section 122 10% surcharge replaces IEEPA tariffs).