Recent Trade & Tariff Perspectives

May 25, 2022  |  Monica DeMars  Senior Manager Compliance

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A Compliance Week in Review

In a week, things can change quickly within the customs compliance field. Currently, there are key changes happening within the industry you need to be aware of so you can manage and mitigate risk in your supply chain.

Section 301 China Tariffs

Can you believe we are four years into this “trade war” with China? This is significant to the U.S. industry since one third of U.S. customs transactions originate in China and two-thirds of product by value are covered by these same tariffs. Importers in the United States have paid an additional 7.5 to 25% on additional tariffs for longer than we anticipated. The United States is battling competing industry motives, dueling legislation (USICA and The Competes Act), and now growing concerns over inflation.

Currently, the U. S. Trade Representative (USTR) is working through a statutory review of the effectiveness of these tariffs against the goals that we originally outlined. The comment period for the statutory review is now open. You will want to follow closely as this story develops between Congress and the White House (USTR) this summer. Will the tariffs remain? Will the scope change? What will happen with the exclusions?

Forced labor

U. S. Customs and Border Protection (CBP) recently issued more than 2,000 letters to importers who import merchandise from the Xinjiang Uyghur Autonomous Region (XUAR) that may be subject to the Uyghur Forced Labor Prevention Act (UFLPA). These letters urge importers to be proactive and closely review their supply chains to ensure that any goods or material are not sourced from the XUAR in violation of the UFLPA. It is incumbent upon importers to “apply due diligence, effective supply chain tracing, and supply chain management measures,” the letters state, “to ensure that such imports are free from any goods mined, produced or manufactured wholly, or in part with forced labor.”

The enforcement deadline is drawing near on June 21st. When UFLPA takes effect the law will presume that goods from the XUAR are made with forced labor and are therefore prohibited from import.

On Friday May 20th, CBP released a comparison document on enforcement between Uyghur Forced Labor Prevention Act and Current Forced Labor Withhold Release Order Enforcement | U.S. Customs and Border Protection Preview (

CBP has provided opportunities for importers and the industry to participate in upcoming webinars on an overview of UFLPA on June 1, June 7, and June 16, 2022. CBP is expected to provide written guidance to importers on the requirements related to substantiating that their goods were not made with forced labor.

Importers should not only focus on their supply chain tracing for finished goods shipping out of XUAR, but also on inputs manufactured in XUAR but shipped to other locations for the final assembly of the goods.

The following products represent the XUAR’s top exported goods in 2019.

Product Export Value % of Total Exports
Apparel $4.49B 25.4%
Footwear $1.81B 10.2%
Electrical machinery and equipment $1.6B 9.1%
Other machines (i.e., mechanical appliances) $1.15B 6.6%
Toys and sports equipment $971M 5.5%
Plastics $747M 4.2%
Vehicles (excluding railway) $712M 4.0%

Source: “Xinjiang Uygur Autonomous Region,” Observatory of Economic Complexity, 2019.

Aluminum and steel imports

CBP issued a reminder to importers regarding the Aluminum Import Monitoring (AIM) license requirements. Both the “country of largest smelt” and “country of second largest smelt” will need to be declared on the customs entry on or after June 29, 2022. Declaring “unknown” will no longer be acceptable. To avoid delays importers should ensure this information is available prior to export of the goods from origin and proactively communicate with your customs broker.

Food imports

As of July 24, 2022, the U.S. Food and Drug Administration (FDA) will require all food importers to declare their Data Universal Numbering System (DUNS) number for food entries subject to the Food Supplier Verification Program (FSVP). Ensure your entries are not delayed in processing, by supplying your customs broker with the proper DUNS number if you are currently declaring “UNK” for unknown.

APHIS Veterinary Services

Effective May 31, 2022, Animal and Plant Health Inspection Service (APHIS) Veterinary Services will require submission of all new and renewal permit applications for live animals and animal products, organisms, and vectors—via the APHIS e-file system. CBP has provided additional guidance from the agency with a Cargo Systems Messaging Service, which describes the requirements for Renewal Permit Applications in more detail.

While these trade topics seem unrelated, CBP and the Partner Government Agencies bring the theme of continued enforcement, and more data element requirements, in order to import into the United States.

Subscribe to our Client Advisories and Trade and Tariff Insights to be notified when changes on these and other important topics take place. Connect with one of our trade policy experts to learn even more. 


Our information is compiled from a number of sources that to the best of our knowledge are accurate and correct. It is always the intent of our company to present accurate information. C.H. Robinson accepts no liability or responsibility for the information published herein.

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