Section 122’s temporary 10% tariffs expire July 24, 2026.

The replacement is a country-specific Section 301 map — costs rise or fall by material origin.

The construction-materials PPI hit 354.9 in March 2026 — a record, up 6.0% year-over-year.

Steel, aluminum, and copper carry 50% duties; derivatives 25%; softwood lumber 10%.

Development pipelines are thinning; activity is concentrating in well-capitalized sponsors.

July 24 is a hard underwriting date, not a headline.

The replacement regime rewards sponsors who know their supply chain’s country of origin.

The construction-cost story stopped being about “inflation” months ago. It is now about policy timing. Section 122’s blanket 10% duty expires July 24 and hands off to a Section 301 structure that prices by country — meaning two identical projects can diverge on cost purely by where the steel was poured.

That turns procurement into an underwriting variable. Sponsors who have mapped their material origins can hedge or re-source ahead of the switch. Those who haven’t are guessing at a hard-cost line inside three weeks.

Base inputs give no cushion. A materials PPI at a record 354.9 means there is no slack to absorb a bad tariff draw. Contingency lines written a year ago are already thin.

The market response is consolidation, not paralysis. Deals with clear demand drivers and deep-pocketed sponsors proceed; marginal, thinly-capitalized projects stall.

Re-price hard-cost contingencies now and confirm country-of-origin on every metals-heavy line item before July 24. The escalation clause you negotiate this month is cheaper than the change order you eat next quarter.

After July 24, your construction budget depends less on what you build than on where your steel came from.

Source: Cushman & Wakefield · AGC · Tax Credit Advisor — Q2 2026