Effective date: July 31, 2026 | Analysis prepared: July 31, 2026

Three material U.S. legal and trade developments take effect on July 31, 2026. The developments span pharmaceutical trade policy, Iran-related sanctions enforcement, and countervailing-duty proceedings — each carrying distinct compliance obligations for Turkish and Turkish-American businesses, importers, financial institutions, and legal practitioners.

Effective 12:01 a.m. ET on July 31, 2026, the company-specific tariff treatment established under the presidential proclamation on patented pharmaceuticals and pharmaceutical ingredients applies to 17 named companies. Covered companies include:

AbbVie, Amgen, AstraZeneca, Bristol Myers Squibb, Eli Lilly, Johnson & Johnson, Merck, Novartis, Novo Nordisk, Pfizer, Regeneron, and Sanofi, among others.

The regime establishes differentiated treatment based on company status, product origin, and pricing agreements:

The lowest applicable rate generally governs. The annex creates new Chapter 99 HTSUS headings and identifies the covered pharmaceutical and ingredient classifications.

The regime is structured around three independent variables that must be assessed for each entry:

1. Product classification: Whether the article is a patented pharmaceutical article by reference to its HTS classification, patent status, and Orange Book or Purple Book listing.
2. Company status: Whether the importer or manufacturer has an approved onshoring plan and/or an MFN pharmaceutical-pricing agreement in effect.
3. Country of origin: Whether the product qualifies for the EU/Japan/South Korea/Switzerland/Liechtenstein 15% rate or the UK 10% rate.

Entries must use the correct Chapter 99 heading and reflect the company's specific status at the time of entry. Covered goods entering a foreign-trade zone generally require privileged-foreign status.

The Section 232 pharmaceutical tariff is the most significant structural change to U.S. pharmaceutical import costs in decades. The 0% rate available through January 20, 2029 for companies combining an approved onshoring plan with an MFN pricing agreement creates a powerful incentive for major pharmaceutical manufacturers to commit to U.S. production investment and pricing concessions simultaneously.

For Turkish pharmaceutical manufacturers, distributors, and importers with U.S. market exposure, the immediate question is whether their products fall within the covered patented pharmaceutical article classifications and, if so, which rate applies. Turkey is not among the countries qualifying for the 15% preferential rate (EU, Japan, South Korea, Switzerland, Liechtenstein) or the 10% UK rate, meaning Turkish-origin covered products would be subject to the 20% or 100% rates absent a company-specific onshoring or pricing agreement.

Turkish pharmaceutical companies supplying active pharmaceutical ingredients (APIs) or finished dosage forms to U.S.-based manufacturers should assess whether their products are classified as covered pharmaceutical ingredients under the new Chapter 99 headings and whether their U.S. customers' company-specific status affects the applicable rate.

Pharmaceutical manufacturers and importers: Conduct a product-by-product classification analysis against the new Chapter 99 HTSUS headings. Verify patent status and Orange Book or Purple Book listing for each covered article. Confirm the company's current status with respect to onshoring plans and MFN pricing agreements, and ensure that customs entries reflect the correct Chapter 99 heading and company-specific status.

Customs brokers and compliance teams: Update entry procedures to capture the new Chapter 99 headings. Implement controls to prevent misclassification between covered patented articles and excluded generics or biosimilars. Document the basis for each classification determination.

Contract drafting: Supply agreements, distribution agreements, and manufacturing contracts should allocate: (i) tariff classification responsibility; (ii) onshoring-status and pricing-agreement representations; (iii) drawback rights; (iv) retroactive tariff risk if classification or status is subsequently challenged; and (v) price-adjustment mechanisms triggered by changes in applicable rates.

Foreign-trade zone operators: Assess whether covered pharmaceutical goods entering FTZs require privileged-foreign status elections and update admission procedures accordingly.

The Office of Foreign Assets Control (OFAC) designated six persons and entities in China, India, Russia, and Iran for providing material support to sanctioned Iranian carrier Mahan Air and the Islamic Revolutionary Guard Corps (IRGC). Designated parties include:

The designations carry blocking consequences — all property and interests in property of the designated parties that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. OFAC's 50-percent ownership rule applies: entities owned 50% or more by a designated party are also blocked, even if not separately listed.

Secondary-sanctions risks are identified for non-U.S. persons who:

• Facilitate prohibited transactions involving designated parties
• Cause U.S.-person violations
• Conduct significant transactions for or on behalf of designated parties

The designation of logistics, freight, and travel entities in China, India, and Russia — rather than Iranian entities alone — reflects OFAC's continued focus on the third-country networks that enable sanctioned Iranian carriers to operate internationally. The inclusion of Chinese freight and logistics companies is particularly significant for global supply chains that route through Chinese intermediaries.

For Turkish airlines, freight forwarders, travel agencies, banks, and logistics operators, the immediate compliance obligation is rescreening of general sales agents, cargo consolidators, beneficial owners, and payment intermediaries against the updated SDN list. Turkish entities that have commercial relationships with any of the designated parties — or with entities owned 50% or more by them — must immediately suspend those relationships and seek OFAC guidance on any blocked property.

The secondary-sanctions risk is particularly relevant for Turkish financial institutions and logistics companies that process payments or shipments involving Mahan Air's network. Conducting significant transactions for designated parties — even without direct knowledge of the sanctions nexus — can trigger secondary-sanctions exposure.

Airlines and travel agencies: Immediately rescreen all general sales agents, interline partners, and codeshare arrangements against the updated SDN list. Screening should cover aliases, registration numbers, and beneficial ownership — not only exact company names. Suspend any relationships with designated parties pending OFAC guidance.

Freight forwarders and logistics operators: Rescreen cargo consolidators, sub-contractors, and payment intermediaries. Implement cargo-routing controls that prevent covered goods from transiting through designated parties' networks. Update contracts to include sanctions warranties, routing restrictions, suspension rights, and procedures for blocked shipments.

Banks and financial institutions: Rescreen correspondent banking relationships, trade finance counterparties, and payment intermediaries. Implement procedures for blocking and reporting any property of designated parties that comes into the institution's possession or control.

Contract provisions: All commercial agreements with parties in the logistics, freight, travel, and airline sectors should include: (i) sanctions representations and warranties; (ii) ongoing screening obligations; (iii) suspension and termination rights triggered by designation; (iv) procedures for blocked payments; and (v) indemnification for sanctions-related losses.

The U.S. Department of Commerce issued a preliminary affirmative countervailing-duty (CVD) determination covering truck-bed covers from China. CBP will suspend liquidation and require cash deposits for covered entries made on or after July 31, 2026.

Covered products are currently classified under HTSUS 8708.29.5160, although the written scope description controls over the tariff classification for purposes of determining coverage. Importers should not rely solely on the HTS heading to determine whether a specific product is within scope.

This is a preliminary determination. The proceeding will continue to a final CVD determination, and the USITC must separately determine whether the subsidized imports cause or threaten material injury to the U.S. domestic industry. Cash deposits collected at the preliminary rate are subject to adjustment — upward or downward — at the final determination and at annual administrative review.

The 100.95% rate for non-cooperating exporters creates an immediate and severe cost impact for importers sourcing from Chinese producers that did not participate in the Commerce investigation. The 20.25% "all others" rate applies to producers and exporters not individually investigated, including new shippers.

For U.S. automotive-accessory importers, online retailers, and distributors, the preliminary determination requires immediate action: verifying producer-exporter combinations for all pending and future entries, updating customs bonds to cover the new deposit requirements, and recalculating landed costs to reflect the applicable preliminary rate.

Turkish automotive-accessory distributors and retailers that source truck-bed covers through Chinese supply chains — including through intermediary countries — should assess whether their products fall within the written scope of the CVD order and whether their supply chain documentation supports the applicable rate.

U.S. importers: Verify the producer-exporter combination for each covered entry before filing. Do not rely on the HTS heading alone — confirm scope coverage against the written scope description. Update customs bonds to reflect the new deposit requirements. Recalculate landed costs and adjust pricing accordingly.

Purchase agreement drafting: Agreements for Chinese-origin truck-bed covers should address: (i) cash deposit responsibility and allocation between buyer and seller; (ii) final-assessment exposure if final duties exceed preliminary deposits; (iii) classification cooperation and scope-determination obligations; (iv) indemnification provisions; and (v) price-adjustment mechanisms triggered by changes in CVD rates.

Supply chain review: Importers sourcing through intermediary countries should assess whether transshipment or processing in a third country affects scope coverage. Commerce's scope-ruling process is available for products where coverage is genuinely uncertain.