During the first Trade Talks Open Office Hours of 2026, APPA’s trade experts discussed the rapidly – and recently -- evolving tariff landscape as well as what we might expect from the long-awaited Supreme Court decision on the IEEPA tariffs when it is announced. Some seemingly positive signals of a more moderate and predictable tariff system going forward was also discussed. Our panel further provided some proactive steps that pet businesses can start taking now to accelerate and maximize the opportunity for tariff refunds should the Court strike down the IEEPA tariffs.
Here are the key takeaways APPA members should keep front and center as they move further into 2026:
Shortly before office hours was underway, the news broke that President Trump was backing off his threat to impose additional tariffs on eight European countries opposing his plans for United States control of Greenland. These tariffs were to be levied against Denmark, Norway, Sweden, France, Germany, the United Kingdom, the Netherlands and Finland, and were scheduled as follows:
February 1: 10%
June 1: 25%
Rafe explained that although details were still scarce, it appeared that the Administration reversed course due to an agreement with NATO that addressed its concerns over Greenland. He and Craig agreed that this rapid turnaround demonstrates that at any moment the trade picture can dramatically change. Rafe pointed out that tariff policies previously had taken months to work themselves out and this last pivot on the Greenland tariffs happened in just a few days.
Rebecca shared that she continues to monitor and report each tariff announcement to clients while at the same time recognizing that some might be getting somewhat desensitized to all the threats that don’t materialize. Examples include tariffs threatened against countries like China and India that purchase oil from Iran, as well as one announced against Venezuela. The challenge is how best to react to these threatened disruptions to both sourcing and supply chain sides.
- Weekly tariff conversations are key:
Rebecca advised businesses to hold weekly conversations regarding tariffs, even when an update is just to report that there has been no major changes that week. Regular and frequent communication will help alleviate the discomfort of both constant media coverage as well as the unknown.
- Evaluate current practices with every new tariff announcement
Each time a new tariff is announced, businesses should take the time to evaluate what they currently have in progress, and whether it makes sense to change shipping or ordering plans based on it. Rebecca noted that a lot of the announcements are made on Truth Social or media reports, rather than through the proper channels such as an executive order or the Federal Register. Feedback from Rebecca’s clients lately is more of a wait and see attitude: to watch what actually plays out before taking responsive action.
And while most of the threatened sanctions are aimed at materials such as oil and gas, the noise still creates much chaos for businesses in other industries as well, as they must evaluate whether the latest tariff will affect their costs. Ultimately, according to Rebecca, it’s unfortunately a risk because the tariffs are not being validated through the proper channels.
Rebecca advises waiting to see if the Supreme Court rules the IEEPA tariffs illegal before pursuing any kind of refund as it would be rejected, as evidence by the Court of International Trade’s rejection on ripeness grounds of Costco’s action in advance of the Supreme Court’s decision. Rachel noted that the Court’s ruling will address any IEEPA tariff in effect, not just those levied on China, Canada and Mexico.
What to do now:
The panel agreed that should the Supreme Court strike down the IEEPA tariffs, the Administration clearly intends to move forward with an alternative tariff regime. Whether the backup plan is imposing tariffs under Section 232 or another statutory or legislative authority, the consensus was that tariffs are not simply going away.
Importantly, should Section 232 tariffs replace the IEEPA ones, not only would there not be any warning, but turnaround time would be very quick (most likely a matter of 3-5 days) with little opportunity to alter ordering or shipping dates or otherwise take action to avoid. Rebecca noted that any such new tariffs would go into effect just as soon as the executive order is released and customs can announce it on their board.
The sheer enormity of the current IEEPA tariff scheme was discussed, as well as the scope and scale of what the Court of International Trade and Customs and Border Protection would face should the tariffs be struck down. The sweeping nature of the current tariffs might have to be replaced by a more case by case system.
Moreover, recent comments by Secretary Bessent could signal that the Administration is advancing a new justification for IEEPA tariffs: rather than reactionary and in response to a present (and seen) national emergency, these tariffs instead could be preventative and aimed at potential (and unseen) future emergency. Whether this argument is meant for a possibly still undecided Supreme Court or for other audiences, the implication – although speculative -- is that tariffs are indispensable executive branch tools for furthering national security and foreign policy goals and therefore should not be removed.
China appears to be fulfilling some trade commitments
Rafe stated that recent reporting indicates that China had met its commitments under the trade deal at least with regard to the initial purchase of soybean products. This is in sharp contrast to phase 1 of the trade deal brokered in the first Trump administration, which consequently led to the ongoing investigation into China’s compliance.
China’s apparent compliance may be viewed positively as there is much riding on the deal’s successful implementation. Rafe commented that as the United States’ most significant trade relationship, the China deal could have important effects on limiting the inflationary elements of tariff policy and helping to reach the economic stability the Trump Administration has promised as a policy goal.
Recent tariff reductions for Taiwan could signal a less extreme tariff regime
Rafe noted that the reduced Taiwan tariff could indicate a more modest trend of more moderate tariffs that provide a predictable but still workable revenue source for the Administration. According to Rebecca, while the Taiwan agreement is still only a framework, the message is that while tariff exclusions might be a thing of the past, there is room for more favorable rates under a 232 scheme if trade deals can be reached. Rafe added that we might be heading into a period of more mitigated tariffs with opportunity for dialogue with the Administration that might advance its goals of reducing consumer prices.
As we head further into 2026, we hope you will continue to make our community stronger by sharing your questions and concerns during our next office hours. In the meantime, if you have any immediate questions or concerns, please do not hesitate to reach out so we can schedule a complimentary individual call with our team of experts who are here to help you.
Please also feel free to reach out to our legal department for a referral for assistance with any Court of International Trade claims or submissions.
Disclaimer: APPA does not make any representations about the completeness, suitability, or adequacy of the information provided in this blog. Any information provided are intended for general informational purposes only, they do not constitute a recommendation or solicitation to do or omit to do any action and should not be interpreted as legal, regulatory, or compliance advice. You should seek independent advice from qualified professionals before acting on any information provided and/or to evaluate specific regulatory obligations and operational decisions.