Atlantic Council this week released a new analysis arguing the Trump administration can reconstruct much of the IEEPA tariff wall through an expanded Section 301 architecture, potentially generating up to $169–170 billion in annual tariff revenue based on 2025 import levels.
The analysis states that while the Section 301 regime could broadly match IEEPA revenues, it depends on a patchwork of investigations and agreements that is more complex and potentially more fragile than its predecessor, and remains vulnerable to negotiations, retaliation, and judicial constraints.
Atlantic Council stated:
Based on 2025 import levels, our model of a Section 301 regime could theoretically generate nearly $170 billion in additional annual tariff revenue by raising tariffs on China and all partners involved in both Section 301 investigations. This would broadly match, and even exceed, the estimated $166 billion collected under IEEPA in 2025. Our scenario, however, depends on a number of assumptions that may not hold. Ongoing negotiations could yield exemptions, trading partners could retaliate or secure carveouts, and courts could narrow executive authority.
Read the full analysis: Can Section 301 Effectively Replace IEEPA? That Is the $166 Billion Question