Cosmetics industry tariff strategy. HTS Chapter 33, ingredient origin, FDA cosmetics regulation, Section 122 EU exposure.
Food industry tariff strategy. HTS Chapter 16-22, USDA/FDA regulation, USMCA agricultural rules, country-specific origins.
Agricultural products tariff strategy. USMCA wholly grown rule, USDA APHIS, country-specific patterns, FTA preferences.
Industrial machinery tariff strategy. HTS 84-85, USMCA qualification, Section 232 derivatives, Mexican production.
Executive Overview: Classification Accuracy as Enforcement Priority US Customs and Border Protection has adopted a zero-tolerance approach to Harmonized System (HS) code compliance, demanding that every manifest entry contain valid six-digit HS codes and precise cargo descriptions accurately reflecting imported products. This enforcement priority reflects CBP’s interpretation that tariff classification accuracy is fundamental to trade…
The CIT Ruling: A Fundamental Invalidation of IEEPA Tariff Authority The Court of International Trade’s decision striking down IEEPA tariffs represents a watershed moment in US trade policy and administrative law. The court concluded that the International Emergency Economic Powers Act does not grant the President authority to impose broad-based tariffs as a trade policy…
Understanding De Minimis and Its Suspension De minimis treatment is a CBP procedure that waives duty collection on shipments below a specified value threshold, historically $800 for most shipments and higher thresholds for goods from designated developing countries. The de minimis exemption recognizes that collection costs for duties on low-value shipments may exceed the duty…
Executive Overview: The Data-Driven Enforcement Shift The US Customs and Border Protection agency’s enforcement activity in 2025 demonstrated a measurable shift toward analytics-driven targeting and fact-intensive verification. CBP issued increasing volumes of CF-28 forms (Customs Form 28, used for fact-finding requests seeking additional information about shipments) and CF-29 forms (Customs Form 29, used for claim…

IEEPA Tariffs: The Foundation and What Importers Paid The International Emergency Economic Powers Act (IEEPA) grants the President authority to impose tariffs and trade restrictions during periods of national emergency. In recent years, IEEPA has been invoked multiple times to implement tariffs on goods from various countries, affecting billions of dollars in imports and impacting…
Executive Overview: A Turning Point in Global Trade Architecture January 1, 2026 marked a significant inflection point in global trade policy. Rather than converging toward common tariff standards or liberalization, major trading jurisdictions simultaneously pursued divergent policy approaches that fragment the global trading system. China reduced tariffs on 935 industrial inputs while Mexico implemented new…