(Not So) Fun Fact: The current average price for a gallon of gas in the United States is $3.88, a roughly 30-percent increase from the beginning of the Iran conflict and a nearly 8-percent rise from last week.

Rebuilding the IEEPA Regime Brick by Brick

What’s Happening: The United States Trade Representative (USTR) has launched two Section 301 investigations in the aftermath of the International Emergency Economic Powers Act (IEEPA) tariff regime. Section 301 of the Trade Act of 1974 is a tested avenue for imposing tariffs on countries that engage in unfair trade practices that discriminate against U.S. goods or services. Examples might include promoting non-market policies, restricting U.S. market access, and stealing intellectual property. Of the two new investigations, the first is on “Structural Excess Capacity and Production in Manufacturing Sectors” and the second is “Relating to Failures to Take Action on Forced Labor.” In addition to Section 301, the Trump Administration maintains a baseline 10-percent Section 122 tariff on most U.S. imports as well as multiple Section 232 national security tariffs.

Why It Matters: As many trade analysts predicted, the Trump trade team is going full steam ahead with replacing the IEEPA tariff regime by pursuing legally tested executive tariff authorities. The new Section 301 investigations cover 86 separate countries – of which 16 are double targeted – representing just over 99 percent of the total U.S. import value in 2025. This marks an unprecedented use of Section 301 as there have never been this many simultaneous investigations on this many countries. Notably, many of the countries being investigated are those that have struck trade deals or pledged investments in the United States in order to mitigate the impact of previous IEEPA tariffs. Now that the Supreme Court has struck down the president’s use of IEEPA, the administration is likely attempting to rebuild the leverage it once had so that these countries follow through on at least some of their commitments. Indeed, fears that these deals could be abandoned are justified, as none has been ratified by Congress and the majority have no official approval from foreign legislatures. In the past few days, the Malaysian Trade and Industry Minister said that the trade agreement signed with the United States is “null and void,” a comment that was later walked back. This may be the first warning shot of disagreements surrounding the future of U.S. tariff policy that cause a restructuring of deals.

In addition to current and future Section 301 investigations, there are also eight ongoing Section 232 investigations that will cover a wide swath of U.S. imports in the name of national security. It is highly likely that some of these 232s will wrap up by the end of 2026, resulting in tariffs that could be as high as 50 percent on certain imports. The combination of Section 232 and Section 301 activity will slowly create a patchwork of tariffs that somewhat replace the IEEPA regime. Section 122 will not be a reliable long-term replacement as it expires in late July and already faces legal challenges. By contrast, Sections 232 and 301 are far more reliable and are unlikely to be struck down by U.S. courts unless the administration fails to follow the formal investigation processes.

Looking Ahead: The Shipment expects that more Section 301 investigations will be announced in the coming weeks. These may include investigations into fishing, digital services barriers, and agricultural practices to name a few of the topics the Trump Administration has zeroed in on when negotiating trade deals.

In Other News

The United States Calls for Aid: As the conflict with Iran continues, President Trump has called on other countries to join a coalition to escort ships through the Strait of Hormuz. So far, the U.S. call to action has fallen on deaf ears. No other countries have committed to sending ships to help escort tankers and cargo ships. It is estimated that between March 1 and March 15 just 89 ships – including 16 oil tankers – crossed the Strait, which is around 5 percent of the normal traffic volume. As of March 19, a joint statement from France, Germany, Italy, Japan, the Netherlands, and the United Kingdom expresses readiness to contribute to ensuring safe passage through the Strait, however, no real world action has been taken.

The European Union Trade Deal: The European Parliament has voted to remove EU tariffs on U.S. industrial products and improve market access for U.S. agricultural products, paving the way for the bloc to uphold its end of the U.S.-EU trade deal. A final vote will be held on March 26 so that EU member governments can vote on these measures. Given the parliamentary vote passed 29 to 9 with only one abstention, it is likely that the trade deal proposals will be finalized next week.

The Global Energy Reaction: Last week, the International Energy Agency announced the largest strategic oil reserve release in history at 400 million barrels with the United States planning to release 172 million barrels over the next 120 days. While these moves temporarily eased rising oil prices, U.S. crude oil is once again approaching $100 a barrel and brent crude is over $110 due to recent military strikes on oil and gas infrastructure in the Middle East. The continued oil supply shock has hit Asian countries particularly hard as Thailand, the Philippines, Vietnam, Sri Lanka, and India have begun efforts to reduce the impact by encouraging work from home, less use of air conditioning, and 4-day work weeks.

Newly Announced Section 301 Investigations and Percentage of U.S. Imports

Implemented and Ongoing Section 232 Investigations