Peacock Tariff Consulting is the North American tariff specialist for Germany exporters selling into the U.S. and Canada. We work across autos (BMW, Audi, Porsche, VW), Mittelstand machinery, pharma, chemicals, precision instruments and focus on Section 122, Section 232 sectoral exposure, and country-specific FTA opportunities. Independent of any customs brokerage; structured for SMB and mid-market exporters.
Germany exporters selling into the U.S. and Canadian markets face a specific set of tariff challenges in 2026 – the Section 122 surcharge on most non-USMCA goods, sectoral Section 232 measures (steel, aluminum, copper, pharma effective July 31), and the question of whether and how to route through Canada or Mexico to access USMCA exemptions.
Peacock Tariff Consulting works with Germany exporters across autos (BMW, Audi, Porsche, VW), Mittelstand machinery, pharma, chemicals, precision instruments. Our practice runs through tariff exposure modeling, classification optimization, FTA qualification reviews, and IEEPA refund recovery on the prior year of imports.
Section 232 auto for German Tier 1/2
Background and structure of this issue. Germany exporters routinely face this question; the answer typically depends on HS classification, country of origin documentation, and the specific U.S. trade preference framework that applies.
For Germany exporters new to the U.S. market, our first deliverable is typically a tariff exposure assessment – modeling annual duty under current and forward scenarios, identifying classification opportunities, and screening for FTA preference where available.
Mittelstand machinery HTS
The exposure pattern is consistent: Section 232 and similar sectoral measures apply at the U.S. import level on covered finished goods or derivative products. For Germany exporters in the affected sectors, scope analysis at the HS subheading level is the first step.
For active U.S.-bound shippers, scope analysis is fixed-fee and runs $4,500-$8,500 depending on SKU complexity. Component-level review identifies where finished products do or do not fall within sectoral measure scope.
Routing via Canada – Mittelstand math
Routing decisions interact with origin and substantial transformation rules. A goods that is Germany-origin remains so unless substantial transformation occurs in another country. Documentation must support whatever origin claim is made on the U.S. entry.
For Germany exporters running staged distribution through North America (Canada or Mexico into the U.S.), routing analysis confirms whether the math supports the additional logistics cost. Some configurations work; many do not.
Section 122 German exposure
Section 122 (15% surcharge until July 24, 2026) applies to most non-USMCA, non-Section-232 imports from Germany. Forward-pricing decisions through expiration require scenario modeling under several plausible successor regimes.
Successor scenarios after Section 122 expiration include Congressional extension, Section 232 sectoral expansion, or a tariff vacuum. We model client exposure under each.
Working with VDA-aligned compliance
Operational and documentation considerations matter alongside the legal analysis. Tariff treatment depends on entry summary accuracy, classification choice, and origin documentation. We coordinate with the importer’s customs broker to ensure consistency.
Documentation review covers Certificate of Origin practices, manufacturer affidavits, BOM analysis, and supplier certifications. Most engagements include a pass on the existing documentation.
Frequently asked questions
Are you a Germany-side customs broker?
No. We are not a Germany-side broker. We are the North American tariff specialist your existing broker calls when your U.S. or Canadian customer raises tariff questions.
Can Germany goods qualify under any U.S. FTA?
Generally no – Germany-origin goods are not preferential under any current U.S. FTA. Some routing-via-Canada or Mexico configurations can produce CUSMA-qualifying products in narrow cases.
How does Section 122 affect Germany exporters?
Section 122 (15% surcharge until July 24, 2026) applies to most Germany goods entering the U.S. unless covered by a sectoral exemption (Section 232 stacking rules) or USMCA-qualifying. Forward-pricing decisions require scenario modeling.
Can you handle IEEPA refund filings for Germany importers?
Yes. IEEPA refunds for U.S. importers of Germany goods who paid IEEPA duty between April 2025 and February 2026 are available through CBP’s CAPE portal. We file claims on contingency for filings above $50k.
What does a typical engagement cost?
Initial tariff exposure assessment: $4,500-$8,500. Ongoing retainer: $3,000-$6,000/month. Refund filings on contingency where claim size justifies.
Get started
Book a North American tariff review tailored to Germany exporters.