Ryan Last, an associate in Troutman Pepper Locke’s Insurance Transactional + Regulatory Industry Group, was quoted in the May 12, 2026, Barron’s article, “Appeals Court Temporarily Pauses Order Declaring Trump’s Global Tariffs Unlawful.”

  • Even as importers continue to collect the tariffs, they should also prepare for the possibility that the administration allows the current Section 122 tariffs to expire and pivots to new Section 301 tariffs before the July 24 statutory deadline, says Ryan Last, an associate at Troutman Pepper Locke law firm.
  • Section 301 of the Trade Act of 1974 gives the U.S. Trade Representative the authority to investigate and respond to certain “unfair” foreign trade practices. Unlike Section 122, there’s no time limit or size cap on Section 301 “so any replacement measures could be more open-ended,” Last added.
  • “The key takeaway is uncertainty, not reversal. Companies should treat this as a stay of execution, not a clean bill of health for the policy, and use this window to model different outcomes, revisit sourcing strategies, and make sure they’re preserving their rights if the legal landscape shifts again,” Last added.
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