Iran secondary tariffs announced
Date of publication: February 10, 2026
Summary
On February 6, 2026, President Trump signed an executive order establishing a framework for imposing secondary tariffs on countries that trade with Iran. This represents a significant expansion of U.S. sanctions enforcement mechanisms and will require careful attention from trade compliance teams worldwide.
The executive order creates a system allowing the United States to impose additional ad valorem tariffs—the order cites 25% as an example rate—on imports from any country that "directly or indirectly purchases, imports, or otherwise acquires any goods or services from Iran." This goes beyond traditional tariffs by penalizing third-country trade with Iran rather than just direct U.S.-Iran commerce.
How the process is intended to work
The implementation would follow a multi-step interagency process:
- Determination phase: The Secretary of Commerce, consulting with the Secretary of State, determines whether a foreign country is acquiring goods or services from Iran after the order's effective date (February 7, 2026, at 12:01 a.m. EST).
- Recommendation phase: Once Commerce makes an affirmative finding, the Secretary of State—in consultation with Treasury, Commerce, Homeland Security, and the U.S. Trade Representative—determines whether tariffs should be imposed and at what rate.
- Presidential decision: The President makes the final decision on whether and to what extent to impose the additional duties based on these recommendations.
Scope and definitions
Several key definitions shape the order's application:
- "Goods or services from Iran"is construed consistently with existing sanctions regulations (31 C.F.R. 560.306) and includes only items that U.S. persons are already prohibited from trading with Iran.
- "Indirectly"encompasses acquisitions through intermediaries or third countries where the origin can reasonably be traced to Iran, as determined by the Secretary of Commerce.
- "Government of Iran"is defined broadly to include political subdivisions, agencies, instrumentalities (including the Central Bank and IRGC), and entities owned, controlled by, or acting on behalf of the Iranian government.
Modification and flexibility
The order includes several provisions allowing for adjustments:
- The President may modify the order based on changed circumstances, in response to foreign retaliation, or if Iran or an affected country takes significant steps to address U.S. national security concerns and align with U.S. policy.
- The Secretary of State is tasked with ongoing monitoring and must recommend additional action if the current measures prove ineffective.
- The Secretary of Commerce will continue monitoring countries even after they've been found to trade with Iran.
Strategic context
The fact sheet frames this action within a broader "maximum pressure" campaign against Iran, citing concerns about nuclear capabilities, terrorism support, ballistic missile development, and regional destabilization. The administration references its June 2026 "Operation Midnight Hammer" and recent deployment of military assets to the region as part of this escalating pressure campaign.
Notably, the administration draws parallels to recent actions against Venezuela and Cuba, suggesting this secondary tariff approach may become a template for addressing other countries deemed hostile to U.S. interests.
Compliance implications
For trade compliance professionals, this order creates several immediate challenges:
Supply chain visibility
: Companies will need enhanced visibility into whether their foreign suppliers or manufacturing locations have any Iranian-origin inputs, even indirect ones.Country-of-origin tracking
: The "indirectly" provision means tracing goods through intermediary countries becomes critical, particularly for complex supply chains.Monitoring requirements
: The Commerce Department's ongoing monitoring suggests that tariff exposure could change over time as new trading relationships are discovered.Tariff classification uncertainty
: Unlike traditional tariffs tied to specific HS codes or products, these duties would apply broadly to imports from designated countries, potentially affecting entire sourcing strategies.Implementation timeline
: With the order effective February 7, 2026, companies should prepare for potential rapid designations, though the multi-step process may provide some lead time.What's next
The executive order authorizes the Secretary of State, Secretary of Commerce, and U.S. Trade Representative to issue rules, regulations, and guidance for implementation. Trade compliance teams should monitor the Federal Register for:
- Specific methodologies for determining "indirect" Iranian origin.
- Lists of designated countries subject to additional tariffs
- Actual tariff rates (the 25% figure is cited as an example, not a fixed rate)
- Exemption or waiver procedures if any
- Reporting or certification requirements for importers
This executive order represents a novel use of tariff policy as a sanctions enforcement tool and signals the administration's willingness to leverage trade measures aggressively in pursuit of foreign policy objectives. Companies with global supply chains should begin assessing their exposure to potential Iranian-origin inputs and consider contingency sourcing strategies for markets that maintain significant trade with Iran.
For more information on how ONESOURCE Global Trade solutions can assist you in managing supply chain risk and regulatory compliance as we move into 2026, contact your Account Manager or Client Success Manager.