Section 122 Revives Tariff Risk as Policy Uncertainty Deepens

ING’s latest note assesses President Trump’s move to impose up to 15% temporary tariffs under Section 122 of the 1974 Trade Act, highlighting renewed legal and macro uncertainty 

• The administration is using a rarely invoked provision allowing tariffs for 150 days, potentially resettable, creating a de facto rolling trade instrument amid fresh legal challenges.

• Realised tariff rates have averaged just above 10%, below headline announcements, reflecting exemptions, trade rerouting and substitution effects.

• ING leaves growth and inflation forecasts unchanged, maintaining expectations for two 25bp Fed cuts in June and September.

Are tariffs becoming a structural policy lever rather than a negotiating tactic? The full note examines the implications.