According to a memorandum issued July 23, the new 10% duty applies to economies that adopted, or committed to adopt, an effective forced-labor import prohibition, such as Canada, Mexico, and the U.K. The 12.5% is placed on economies that haven’t done so, including China, the EU, and Japan.  

In a Fox News interview on June 28, Trump said it was “a shame that I have to go a harder way for the tariffs because the Supreme Court, in a very close decision, ruled against me.” He added that he has “other ways of doing the same thing,” though he noted they were more cumbersome. 

“But the tariffs have made this country a fortune,” he told Fox News. “It made the country rich.” 

The tariffs don’t directly target HVAC-related equipment, refrigerants, or other components, but that doesn’t mean the industry won’t feel their effects. 

The Air-Conditioning Contractors of America lists China as a major source of compressors, motors, control boards, and copper components. Many of these items face additional Section 301 duties on top of any base duties or other measures, like Section 232, which affect steel, aluminum, and copper. 

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In a blog post, Joey James, a senior research analyst with Heating, Air Conditioning & Refrigeration Distributors International, said the important point is that goods already subject to Section 232 are exempt from the new tariffs. In June 2026, Trump issued a proclamation that temporarily lowered tariffs on HVAC-related derivative products from 25% to 15%. 

“Since most HVACR equipment and components run through Section 232's steel/aluminum/copper derivative provisions, a large share of the sector's imports doesn't touch this new tariff at all, regardless of country of origin,” James wrote. “The 10%/12.5% split only matters for whatever isn't already captured under Section 232.” 

HARDI advised companies to confirm whether certain components, electronics, or finished goods not included on the derivative list have USMCA-qualifying status claimed for Canada and Mexico goods, as it keeps these imports exempt from the new tariffs.  

It has yet to be clarified whether the Section 301 tariffs will stack with Section 338 tariffs on Canadian goods, which is set to take effect Aug. 19. 

James said these new tariffs are rooted in firmer legal grounding than previous tariffs, noting Section 301 has a stronger track record than the International Emergency Economic Powers Act. In June 2026, the Supreme Court declined to take up a bid by multiple businesses to overturn tariffs on Chinese products levied under Section 301. 

It is difficult to determine how much the new tariffs will affect pricing, as the policy creates the potential for higher costs but also depends on how much each manufacturer’s supply chains pull from those 60 countries.