Recent Trade & Tariff Perspectives

December 21, 2022  |  Anahi Czeszewski  Product Development Manager

Here’s a friendly reminder to do what you can now to prevent compliance program chaos and supply chain kinks in the coming year. To help you get a head start, below is a list of key items to review, so your compliance program is prepared and equipped for emerging customs and trade updates that could impact your business next year.

Watch this week’s Trade & Tariff perspective:

Use C.H. Robinson’s comprehensive 20-point Customs Clearance Checklist to prepare your organization to implement necessary changes ahead of customs and trade developments, while maintaining standard customs requirements. Key steps outlined include:

Revisit your customs Powers of Attorney (POAs): Every year, or when you make organizational changes, validate your active customs POAs extended to your U.S. customs brokers—be sure to revoke POAs for broker relationships you’ve ended.

Revisit your customs bond sufficiency: Take a look at your import activity over the past 12-month period to determine what your bond amount should be. Also, consider if you have forecasted an increase in customs duties in the upcoming year—including any additional trade remedy duties imposed affecting your business.

Review customs broker instructions: Provide clear instructions to your customs brokers so they have a comprehensive understanding of any import compliance requirements specific to your organization. Examples of important topics to cover include:

• Related party verification instructions
• Partner government agency (PGA) applicability
• Application and eligibility of free trade agreements (FTAs) for your products
• Your Harmonized Tariff Schedule (HTS) classification database, or how you will provide your HTS codes to your broker

Request updated certificates of origin: Get updated annual blanket certificates of origin (COO) from your foreign suppliers for any program in which you plan to claim preference. Delays in obtaining your COOs may impact your potential overall duty savings.

Review your U.S. Harmonized Tariff Schedule (HTSUS) classifications: As trade developments emerge U.S. Customs and Border Protection (CBP) makes updates to the HTSUS. HTS classification modifications could impact your business in many ways, including:

• Increase or decrease your duty spend due to the addition or removal of punitive tariffs, such as the China, steel, and aluminum tariffs.
• Change your eligibility for participation in preferential trade agreements.
• Flag products previously not flagged, as measures for antidumping and countervailing duty cases.
• Give you reason to consider frontloading or delaying imports of certain products as a cost-savings measure where duty rates have changed.

After you have completed the customs and trade compliance resiliency review, consider taking advantage of other trade compliance strategies to mitigate risk, streamline processes, and control costs. Topics worth reviewing include:

• Periodic Monthly Statement (PMS): Consider leveraging Automated Clearing House (ACH) PMS as a cashflow management strategy. With ACH PMS, duties and fees can be paid on an interest-free monthly basis. Furthermore, with ACH PMS, importers can pay duties and fees for goods that are released during a given month as late as the 15th working day of the following month. Learn more about ACH payment types to CBP.
• ACE Portal: The ACE Portal enables importers and exporters to actively monitor the information being submitted to the U.S. Government to ensure accuracy, take action when corrections are required, and exercise reasonable care. Discover more about the ACE Portal.
• Customs Trade Partnership Against Terrorism (CTPAT): CTPAT is a voluntary supply chain security program based on trust, which recognizes that CBP can provide the highest level of cargo security only through close cooperation with the principal stakeholders of the international supply chain. When an entity joins CTPAT, an agreement is made to work with CBP to protect the supply chain, identify security gaps, and implement specific security measures and best practices. CTPAT partners enjoy a variety of benefits.

Numerous customs and trade developments have emerged over the past year, impacting many of our global shippers. In addition to subscribing to C.H. Robinson’s Trade and Tariff Insights, C.H. Robinson offers a variety of additional resources to help you stay in informed in today’s fast-paced and particularly challenging policy and enforcement environment:

• Subscribe to our Client Advisories to be alerted in real-time any time a new development occurs.
• Get the latest market updates delivered to your inbox with our Global Freight Market Insights.
• Gain deep expertise in an hour or less and discover our on-demand webinar discussions.

Navigating through this unpredictable customs and trade climate can seem overwhelming—but fortunately, you’re not alone. C.H. Robinson continues to closely monitor all the latest developments. Connect with one of our Trusted Advisor® experts to learn more.

• Recent Trade & Tariff Perspectives | The Latest Developments on the Customs and Trade Front (chrobinson.com)
• Recent Trade & Tariff Perspectives | Customs Bond Sufficiency: Is Your Bond Sufficient? (chrobinson.com)
• Recent Trade & Tariff Perspectives | Customs Trade Partnership Against Terrorism (CTPAT) Program (chrobinson.com)

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.