Mid‑market urged: audit tariffs

Mid-sized companies are being told to audit every tariff exposure now, after the Trump administration’s February 2026 import surcharge reset landed on top of an already crowded duty map. (whitehouse.gov) President Donald Trump invoked Section 122 of the Trade Act of 1974 on February 20, 2026, and the White House said the measure imposed a 10% ad valorem import duty for 150 days starting February 24. Section 122 lets a president go as high as 15% for no more than 150 days unless Congress extends it. (whitehouse.gov) (federalregister.gov) A tariff audit is a line-by-line check of what a company imports, which tariff code each product uses, which country it comes from, and which extra duties stack on top. Customs and Border Protection said on February 25 it was enforcing new trade-remedy measures and updating guidance for the trade community after the Supreme Court’s ruling on the International Emergency Economic Powers Act. (cbp.gov) That work has moved from customs teams to finance offices because tariff costs now hit cost of goods sold, margins, transfer pricing, and customer contracts at the same time. KPMG said 78% of organizations reported higher cost of goods sold in their most recent fiscal quarter, and 51% reported current margin declines. (kpmg.com) The same survey said 55% of executives plan additional price increases of up to 15% within the next six months, while 68% said they had postponed major investments. That leaves mid-market importers with less room to absorb classification mistakes, missed exemptions, or outdated supplier terms. (kpmg.com) Consultants now describe Section 122 as a bridge to other trade actions later in 2026, including Section 232 and Section 301 cases. Grant Thornton said on April 1 that the 10% Section 122 duties “appear to be a runway” to other duties expected later this year, and it noted lawsuits from 24 states and two businesses challenging the move. (grantthornton.com) Software vendors are selling planning tools into that uncertainty. Coupa says its Tariff Impact Planning product lets companies model input-cost changes, supplier and production-location shifts, duty-drawback options, and repricing scenarios before they change a network. (coupa.com) Coupa also warns that tariffs can compound as duties on raw materials flow into semi-finished goods and then into finished products. That is the core audit problem for a mid-market importer with contract manufacturers in more than one country and multiple tariff regimes hitting the same bill of materials. (coupa.com) Outside estimates show how high the broader tariff backdrop has become. The Budget Lab at Yale said on April 8 that the pre-substitution average effective United States tariff rate stood at 11.8%, and it modeled the Section 122 tariffs as expiring after 150 days in its baseline case. (budgetlab.yale.edu) For finance chiefs, the immediate question is less whether tariffs are temporary than whether the company knows its exact exposure before the next shipment clears customs. The firms that can map products, codes, origins, suppliers, and contract pass-through terms fastest will know first whether a 10% duty stays 10% or turns into a margin hit they did not price. (federalregister.gov) (coupa.com)