The EU Circular Economy Act: What It Means for Forwarders and Global Trade

On 1 August 2025, the European Commission (EC) launched a public consultation and call for evidence to inform the development of its upcoming Circular Economy Act—legislation positioned to reshape how goods are produced, traded, and reused across the EU.

This Act is designed to enhance the EU’s economic resilience and competitive edge while reinforcing its environmental commitments. By promoting sustainable production practices and circular business models, the legislation aims to support the region’s broader decarbonisation goals and long-term growth.

At its core, the Circular Economy Act will facilitate the free movement of circular products, support more efficient management of waste and secondary raw materials, and lay the groundwork for a unified internal market for high-quality recycled inputs. For logistics providers, manufacturers, and global supply chain stakeholders, this could significantly affect sourcing, packaging, reverse logistics, and regulatory compliance across the bloc.

Set for adoption in 2026, the Act will build on existing frameworks such as the Eco-design for Sustainable Products Regulation and the Critical Raw Materials Act. It aligns with key strategic documents and declarations including the Competitiveness Compass, Clean Industrial Deal, the Letta and Draghi reports, the Antwerp Declaration, and directives from both the European Council (Budapest Declaration) and the European Parliament.

The consultation—open via the Commission’s Have Your Say portal until 6 November 2025—marks a pivotal step in the impact assessment phase. The EC is seeking input from all sectors to ensure the final legislation reflects on-the-ground realities and fosters practical, scalable change.

With a target to double the EU’s circularity rate by 2030, this initiative could redefine the future of industrial trade and materials flow in Europe. For companies with cross-border operations, like Future Forwarding, engaging with these changes early is not just proactive—it’s essential to staying aligned with the next generation of European trade policy.

What the New US–EU Tariff Deal Means for Global Trade and Supply Chains

The recent agreement between the United States and the European Union to impose a 15% tariff on most EU goods has avoided what could have become one of the most consequential trade conflicts in recent history. While the new framework represents a significant compromise, halving the 30% tariff previously threatened, it still reshapes the global trade environment and leaves many questions open for logistics professionals and the businesses they support.

Announced at a high-profile meeting in Scotland between U.S. President Donald Trump and European Commission President Ursula von der Leyen, the deal includes sweeping commitments: roughly $600 billion in EU investment into the U.S. economy and substantial increases in purchases of American energy and defense products. In many ways, this mirrors the structure of the recently signed U.S.-Japan trade agreement, providing a blueprint for how the U.S. is reshaping its trade relationships.

For companies with transatlantic operations, the 15% tariff represents both relief and risk. Relief, because it is far lower than the threatened 30% rate; risk, because the deal is being described as a “high-level political agreement,” rather than a fully defined trade treaty. This lack of detail creates potential uncertainty for sectors ranging from automotive to pharmaceuticals.

Notably, tariffs on U.S. steel and aluminum imports remain at 50%, a point of tension that EU leaders hope to address in future negotiations, potentially through a quota system. At the same time, several categories, including aircraft, aircraft parts, certain chemicals, and some agricultural products, will remain tariff-free, softening the impact for select industries.

The implications for supply chains are significant. The EU’s commitment to purchase $750 billion in U.S. energy over the coming years could drive changes in freight flows, while the open questions around products like spirits and specialty goods will demand close monitoring by shippers and forwarders. Companies will need to prepare for evolving customs requirements and possible tariff revisions, as the agreement grants the U.S. the right to raise tariffs again if investment targets are not met.

Future Forwarding’s clients and partners can expect shifts in demand, routing, and compliance considerations as the deal’s terms take shape. Proactive planning and flexible logistics strategies will be essential in a global environment where trade agreements are increasingly negotiated under tight timelines and with political leverage.

While this framework provides short-term stability, it also highlights a broader trend: trade policy is being used as a real-time tool for economic restructuring. Questions on how tariffs might affect you? Reach out to our team today. 

FDA Tightens Section 321 De Minimis Exemptions: What Importers Need to Know

Importers and shippers who rely on the Section 321 de minimis exemption for low-value shipments should take note: the U.S. Food and Drug Administration (FDA) has officially rescinded previous guidance that allowed certain FDA-regulated products to bypass full review.

What’s Changing
Under 19 U.S.C. § 1321(a)(2)(C), importers can claim a duty exemption for shipments valued at $800 or less. Previously, some FDA-regulated items could clear Customs and Border Protection (CBP) without full FDA screening. According to the new Cargo Systems Messaging Service (CSMS # 65581188), “All shipments of FDA-regulated products, regardless of quantity and value, are subject to the same regulatory requirements and may pose risks to health, safety, and security.”

This means that “Effective immediately, all FDA-regulated products must be submitted to the FDA for review.” Prior CSMS messages (#94-001260, #17-000388, #52257745, and #53697179) that allowed certain low-value items to move without FDA review are now rescinded. The agency explains that technological advances now allow them to review “all electronically transmitted FDA-regulated products offered for import, regardless of shipment quantity and value, to facilitate legitimate trade and prevent the importation of violative products.”

Who’s Impacted
These updates affect any importer moving FDA-regulated goods — food, beverages, dietary supplements, cosmetics, medical devices, biological samples, and more. Small parcel express shipments that previously cleared under de minimis without FDA review now require the same level of compliance as larger shipments.

Prior Notice Requirements Remain
The FDA reminds importers that Prior Notice (PN) rules for food and feed products remain unchanged. “Prior Notice (PN) requirements must still be met on all food and feed shipments, regardless of value or quantity; unless otherwise exempt from PN requirements under 21 CFR 1.277(b).” Failing to submit an accurate PN can result in costly holds or refused entry.

What Importers Should Do Now
Future Forwarding recommends that clients take immediate steps to stay compliant:

  • Review your processes for Section 321 shipments. Confirm that your customs broker and technology providers can submit full FDA data for every low-value shipment.
  • Revisit Prior Notice procedures. Ensure your team knows which food or feed items require PN and that your filings are accurate and timely.
  • Communicate with suppliers and shippers. Make sure your partners understand the updated requirements to avoid delays.
  • Use the FDA’s resources. Familiarize yourself with the FDA Supplemental Guide for ACE, de minimis FAQs, and the official CSMS.

Stay Informed with Future Forwarding
Compliance changes like this show how quickly trade rules can evolve. Future Forwarding stays up to date on the latest regulatory shifts so our clients don’t have to worry about unexpected holds or penalties. If you have questions about how the updated Section 321 policy affects your supply chain, our team is ready to help you review your processes and keep your shipments moving smoothly.

APHIS Dashboard for WPM Compliance


New Tool Offers Centralized Oversight for Wood Packaging Material

The USDA’s Animal and Plant Health Inspection Service (APHIS) has released a new digital dashboard to improve oversight of wood packaging material (WPM) used in global trade. This interactive tool provides a centralized view of compliance trends, inspection outcomes, treatment facility certifications, and import patterns across U.S. entry points.

Why the Dashboard Matters for Trade Compliance
WPM—including pallets, crates, and dunnage—must meet the International Standards for Phytosanitary Measures No. 15 (ISPM 15) requirements to prevent the spread of wood-boring pests. Noncompliance can result in cargo delays, rejections, and regulatory penalties. The new APHIS wood packing material dashboard gives logistics providers, customs brokers, and importers access to actionable data that can inform procurement strategies and ensure shipments meet U.S. and international phytosanitary regulations.

What the Dashboard Delivers
Drawing from multiple APHIS data sources, the dashboard displays up-to-date metrics on treatment status, compliance rates, and inspection findings. Users can also see which treatment providers and entry points are performing well, allowing them to make more informed sourcing decisions and identify potential areas of risk in their supply chains.

Webinar Scheduled to Support User Adoption
To help users get the most out of the new tool, APHIS will host a live instructional webinar on Thursday, July 10 at 1:00 p.m. EDT. The session will cover navigating the dashboard, customizing data views, and applying the information to operational planning and reporting. Subject matter experts will be on hand to answer questions.

CEU Credit Available for Licensed Brokers
Licensed customs brokers who attend the webinar will be eligible for Continuing Education Credit (CEU), offering added value for professionals maintaining their accreditation. The session is designed to be practical and directly applicable to day-to-day compliance responsibilities.

Strategic Benefits for Shippers and Brokers
Increased regulatory pressure and pest risk management make tools like the APHIS dashboard a vital asset for any organization involved in international freight. With greater visibility into compliance performance, businesses can strengthen their risk management efforts, ensure smoother cargo movement, and build stronger relationships with certified WPM providers.

The dashboard and webinar registration are now available through the APHIS Wood Packing Material portal.

European Port Congestion

22 July 2025

European Port Congestion Update

Northern Europe’s key ports; Hamburg, Bremerhaven, Rotterdam, and Antwerp, have seen some short-term improvement in recent weeks. Container dwell times are beginning to ease, vessel backlogs have reduced slightly, and overall port flow is more stable than earlier this year.

However, congestion has not fully cleared, and underlying issues remain: inland rail disruption, low river levels, and labour-related delays continue to affect operations. Antwerp, in particular, remains a pressure point, with some containers still sitting in terminal for over 8 days.

This situation is directly affecting Ocean services to the US, where consolidated cargo shipments are experiencing extended dwell times before departure. LCL containers often rely on tighter schedules and multiple touchpoints, so even small delays at origin can lead to knock-on effects for delivery timelines in the US.

As we enter the summer peak season, the risk of renewed delays is increasing, especially as volumes rise and infrastructure stays strained.

Carrier routing changes and terminal slot availability may lead to last-minute adjustments or longer transits.

LCL shipments to the US may face additional wait times before departure due to delayed container consolidation and terminal congestion.

Vessel delays remain in the 3–4 day range at several ports.

Rail and barge limitations are causing slower cargo movement inland, particularly for freight coming from or through central Europe.


13 June 2025

European Port Congestion Eases, But Long-Term Pressures Remain

European port congestion has shown signs of easing in early June, bringing temporary relief to shippers and logistics providers. However, systemic pressures suggest the situation remains fragile, with the potential for renewed disruption as the summer peak season approaches.

According to Flexport, ports such as Hamburg, Antwerp, and Bremerhaven have begun clearing long-dwelling containers, and vessel delays have temporarily declined. This marks a notable shift from earlier in the year, when widespread congestion across Northern Europe caused ripple effects throughout the supply chain.

The recent improvement can be attributed to several short-term factors, including faster container movement, adjustments in carrier rotations, and slightly improved terminal efficiency. However, underlying issues, including constrained barge capacity, inland rail bottlenecks, and continued labor disruptions, still threaten operational stability.

Carrier alliances have also contributed to shifting dynamics. As networks are reshuffled and some services diverted or consolidated, ports like Rotterdam remain at risk of renewed pressure. Ongoing labor negotiations in Germany and other regions introduce additional uncertainty for port operators and logistics planners.

Shippers are advised to remain vigilant. While European port congestion may be easing now, the industry is heading into the high-volume summer season. As more cargo moves through constrained infrastructure, the potential for delays will increase. Proactive planning, close coordination with logistics providers, and ongoing visibility into inland transport networks will be essential for mitigating risk in the months ahead.

COURT RULING REDEFINES TRADE LANDSCAPE: WHAT IMPORTERS NEED TO KNOW ABOUT IEEPA TARIFFS

UPDATE – May 29, 2025 16:45 EST

Appeals Court Temporarily Reinstates Trump Tariffs

Moments ago, a federal appeals court temporarily reinstated President Donald Trump’s tariffs, which had been invalidated a day earlier by the U.S. Court of International Trade. The lower court ruled that Trump’s tariffs exceeded his authority under the International Emergency Economic Powers Act (IEEPA), following a lawsuit filed by five owner-run businesses. The Trump administration quickly appealed the decision and warned that, without a stay, it would seek emergency relief from the Supreme Court. The appeals court’s brief order places the trade court’s judgment on hold while considering the full motion.

A pivotal legal decision is reshaping U.S. trade policy and creating a window of opportunity for importers. On May 28, the Court of International Trade (CIT) ruled that the Trump administration’s tariffs imposed under the International Emergency Economic Powers Act (IEEPA) were unlawful. The court ordered that the executive actions be vacated, directing U.S. Customs and Border Protection (CBP) to stop collecting the affected duties. While the administration has filed an appeal and may seek a stay, this ruling sets the stage for a significant shift in how tariffs can be levied—and what importers should do next.

For now, duties tied to the vacated tariffs may still be collected until a final decision is issued, but importers shouldn’t wait to act. The CIT decision opens the door to potential refunds for duties already paid. However, these refunds will not be automatic. Importers must monitor the liquidation status of affected entries and file formal protests to preserve their rights. Post Summary Corrections remain unavailable for these entries due to system constraints within ACE.

The timeline matters: duties were first collected under these tariffs on February 4, 2025. With liquidation expected around mid-December and a protest deadline extending into June 2026, businesses have time—but not unlimited time—to protect their financial interests.

It’s important to note that this ruling is narrow in scope. It affects only tariffs enacted under IEEPA; other tariffs, such as those under Sections 301, 232, and 122, remain fully intact. As a result, the administration may explore alternate statutory pathways to reinstate similar trade measures.

In the meantime, Future Forwarding advises all importers to closely evaluate their tariff exposure and review their entry data. Staying informed, monitoring liquidation, and preparing to file protests if warranted are critical next steps. If you have questions about how this decision could impact your supply chain or need help assessing your options, our compliance team is here to support you.

Beyond the Headlines: What the Latest Houthi Sanctions Mean for Global Supply Chains

As the Red Sea crisis enters another turbulent chapter, recent announcements by the Houthi militia signal an escalation not just in rhetoric but in perceived threat levels to global trade. For B2B decision-makers, logistics leaders, and risk managers, it’s a critical moment to look beyond the headlines and understand the broader implications for global shipping strategy, supply chain resilience, and geopolitical risk assessment.

From Symbolism to Strategy: Parsing the Houthi “Blacklist”

Over the weekend, the Houthis issued a new list of 15 companies they’ve declared as legitimate targets—including U.S. aerospace giant Boeing—and extended secondary sanctions to any entity transacting with them. While this announcement has attracted global media attention, industry insiders are treating it more as a symbolic maneuver than an operational threat.

Why? Because major shipping lines like Maersk and CMA CGM, reportedly linked to some of these sanctioned companies, are already avoiding Red Sea routes. These diversions are not new. They’ve been part of a broader strategic pivot since late 2023, when risk exposure in the Bab al-Mandab Strait and the Gulf of Aden spiked due to recurring maritime attacks.

In this context, the Houthis’ latest statement may be more about maintaining political relevance than exercising new military capability.

Supply Chain Implications: Operational Disruption or Strategic Noise?

While the practical impact on container flows may be minimal today, the long-term implications of such declarations are far from negligible. Every publicized threat introduces layers of uncertainty that ripple across supply chains—from insurance premiums and carrier route planning to procurement timelines and inventory positioning.

For companies with exposure in sensitive geopolitical corridors, this means that geopolitical intelligence is no longer a “nice to have”—it’s mission-critical. It also underscores the need for adaptive logistics planning and agile partnerships that can respond quickly to evolving risk.

Shifting Tides: A Fragile Suez and the Global Trade Reroute

The conversation surrounding the Red Sea and Suez Canal also intersects with a broader geopolitical recalibration. U.S. leadership has been increasingly vocal about securing passage through key waterways, with former President Trump’s recent social media directive calling for free U.S. passage through both the Panama and Suez Canals.

While this may be more political theater than policy shift, the fact remains: Egypt’s Suez Canal has suffered a 60% drop in revenue and $7 billion in losses year-over-year. Rerouted cargo to longer, more expensive paths around the Cape of Good Hope has downstream effects on freight rates, capacity planning, and emissions targets—particularly for companies aiming to meet strict ESG goals.

Explosion in Iran: A Reminder of Port Vulnerabilities

Saturday’s explosion at Iran’s Shahid Rajaei container terminal is another stark reminder of the fragility of port infrastructure. Whether accidental or deliberate, such incidents highlight the operational and reputational risks ports face in volatile regions. Industrial safety, emergency response readiness, and cyber-physical security must now be core components of any serious logistics or maritime risk management plan.

What Should Logistics and Supply Chain Leaders Do Now?

For businesses reliant on predictable global trade lanes, the call to action is clear:

  • Reevaluate Routing Strategy: Ensure current shipping routes avoid high-risk zones—even symbolic threats can trigger insurance complications or sudden rerouting.
  • Build Supplier Agility: Double down on nearshoring, multi-sourcing, and supplier diversity to create fallback plans.
  • Invest in Intelligence: Subscribe to real-time maritime risk updates and leverage predictive analytics to proactively manage disruption.
  • Review Force Majeure Clauses: Reassess contracts with logistics providers and carriers to understand exposure and recourse in volatile regions.
  • Engage in Scenario Planning: Model the impact of Suez or Red Sea closures on inventory lead times, transport budgets, and customer SLAs.

The Global Freight Gameboard Is Shifting—Are You Ready?

While the immediate fallout from the Houthi sanctions may seem limited, the larger narrative is one of increasing unpredictability in the maritime shipping landscape. From political posturing to real security threats, today’s headlines are tomorrow’s bottlenecks—or worse.

For those in the freight, logistics, and supply chain space, staying informed is no longer sufficient. Strategic adaptation, resilient planning, and a proactive mindset are now the new cornerstones of competitive advantage. To learn more, get in touch with us today. 

Navigating Changing Trade Regulations: What Importers Need to Know Now

As the global trade environment continues to shift, staying informed and compliant is more important than ever. At Future Forwarding, we are closely monitoring evolving U.S. Customs and Border Protection (CBP) regulations, new tariff implications, and enforcement trends to help our customers navigate the complexities of international shipping, and maintain compliance. Below are several key updates and best practices to help your business stay prepared and protected.

1. Upcoming Tariffs on Annex II Goods

While some goods were previously excluded from reciprocal tariffs under IEEPA (International Emergency Economic Powers Act)—including pharmaceuticals, lumber, and semiconductors—these items are under renewed scrutiny. New tariffs are being discussed, although no formal announcements have been made.

What this means for you:
Stay alert but don’t panic. These changes are developing quickly. We will provide clear, actionable guidance as soon as official information is released.

2. Customs Bond Sufficiency & Tariff Impacts

CBP has started issuing bond insufficiency notices as they account for increased duties under new tariff regimes. Importers may be advised to increase their bond amounts to avoid costly issues like bond saturation or stacking.

Our recommendation:
Proactively review your import projections over the next 12 months. Overestimating bond coverage may result in a higher premium but can help you avoid significant disruptions. Our team is here to assist with these evaluations.

3. Trade Agreement Claims & Documentation

As tariffs increase, programs like USMCA are expected to be claimed more frequently—especially for goods with normally duty-free classifications. However, claiming these benefits without adequate documentation can raise red flags with CBP.

What you should do:
Even if not required at the time of entry, obtain and retain certificates of origin and supporting documents. CBP may request proof of claims at any time, including for items subject to the new IEEPA-related tariffs or aluminum and steel derivatives.

4. Compliance Is Critical: AI & CBP Enforcement

CBP is leveraging artificial intelligence to identify patterns of non-compliance and possible tariff evasion. Brokers are expected to exercise “reasonable care” in supervising imports and ensuring accuracy in all documentation and declarations.

Your action items:
Ensure your records are thorough and accurate. Be ready to substantiate any certifications or claims. We’re committed to advising you responsibly and in writing when concerns arise.

5. Understanding “First Sale” Eligibility

There’s growing interest in using the “first sale” rule to reduce declared values and save on duties. However, this method requires strict qualification to be used appropriately.

Our advice:
If you’re exploring ways to optimize import costs, speak with a qualified trade advisor or attorney. We can connect you with trusted professionals to assess your transaction values and pricing strategies, such as isolating non-dutiable charges like certain commissions or engineering costs.

6. Importer Vetting & Risk Mitigation

CBP is increasingly focused on new Importers of Record (IORs), especially due to a rise in short-lived shell companies used to evade duties. This has led to tighter scrutiny in setting up new accounts.

How Future Forwarding protects you:
We vet all new importers thoroughly and recommend verifying business addresses and operational legitimacy before engagement.

7. The Role of Official Communication

We want to emphasize that social media posts are not law. No matter how widely circulated, guidance only becomes official through Executive Orders and, more importantly, CBP’s Cargo Systems Messaging Service (CSMS).

What this means for you:
Rely on Future Forwarding and CBP’s CSMS alerts—not online chatter—for accurate, enforceable guidance. We will always inform you of updates as soon as they are confirmed by official channels.

Partnering With You Through Change

We understand this is a challenging time for importers, and you may have questions as policies shift. Our team is dedicated to working closely with you, asking the right questions, and providing thoughtful recommendations to ensure continued compliance and peace of mind.

For more personalized support or if you’d like to discuss how these updates may affect your operations, please don’t hesitate to reach out. We’re here to help.

CBP Issues Guidance on Reciprocal Tariffs

On April 2, 2025, a new Executive Order titled “Regulating Imports with a Reciprocal Tariff to Rectify Trade Practices that Contribute to Large and Persistent Annual United States Goods Trade Deficits” was issued. In response, U.S. Customs and Border Protection (CBP) has provided official guidance for actions effective as of April 5, 2025. Importers must act quickly to ensure compliance with the new requirements.

Key Highlights of the Reciprocal Tariff Guidance

New Tariff Classification Requirement

Beginning April 5, 2025, all imports must include a secondary Harmonized Tariff Schedule of the United States (HTSUS) Chapter 99 classification. This applies whether the product is subject to the reciprocal tariff or qualifies for an exemption. This additional classification ensures CBP can track and apply the new duty structure properly.

Core Duty Rate: HTSUS 9903.01.25

The baseline reciprocal tariff imposes a 10 percent additional ad valorem duty on most imported goods. This applies to all items entered for consumption or withdrawn from the warehouse for consumption on or after 1201 a.m. EDT, April 5, 2025.

This 10 percent duty is in addition to all other applicable duties, taxes, and fees.

Exceptions to the Tariff

There are several key exceptions. If the tariff under 9903.01.25 does not apply, importers must declare an alternative HTSUS code to indicate the exemption. These include:

  • 9903.01.26 for articles originating in Canada
  • 9903.01.27 for articles originating in Mexico
  • 9903.01.28 for goods already in transit before April 5, 2025 (valid only through May 26, 2025)
  • 9903.01.29 for products from Column 2 countries such as Belarus, Cuba, North Korea, and Russia
  • 9903.01.30 for humanitarian donations
  • 9903.01.31 for informational materials
  • 9903.01.32 for products specifically identified in Annex II
  • 9903.01.33 for certain iron, steel, aluminum, and automotive articles under Section 232
  • 9903.01.34 for goods with at least 20 percent U.S. content (duty applies only to non-U.S. portion)

Need Help?

Reach out to your Future Forwarding representative or traderemedy@cbp.dhs.gov.

The Impact of Reciprocal Tariffs on Foreign-Trade Zones

As reciprocal tariffs are set to take effect on or around April 2, 2025, businesses relying on Foreign-Trade Zones (FTZs) must prepare for potential disruptions and compliance challenges. The application of these tariffs, targeted at trading partners imposing substantial trade barriers to U.S. goods, will have far-reaching implications for businesses involved in manufacturing, distribution, and logistics.

What Are Reciprocal Tariffs?

Reciprocal tariffs are a trade remedy mechanism intended to balance the playing field by imposing tariffs on imported goods from countries that have levied significant trade barriers against U.S. goods. Starting on April 2, 2025, certain trading partners will face blanket tariff rates on all imported goods originating from their countries, potentially impacting the cost structures and operations of U.S.-based businesses, including those operating within FTZs.

The Uncertainty Surrounding FTZ Admission Requirements

One of the primary questions surrounding the introduction of reciprocal tariffs is whether merchandise originating from countries subject to the new tariffs will be required to enter FTZs under “Privileged Foreign” (PF) status. This status restricts certain merchandise, which could result in changes to how businesses manage inventory and imported goods.

The Potential Effects on Manufacturers

If FTZ merchandise from reciprocal tariff countries is required to be admitted under PF status, the effective date of the tariffs will lock in the tariff rates at the time of admission. For manufacturers who rely on parts, components, or raw materials from these countries, the elimination of benefits like the inverted Most-Favored-Nation (MFN) duty rate could result in increased costs. This means that manufacturers might face higher duties when withdrawing goods from the FTZ for U.S. consumption, including any additional trade remedy tariffs in place.

On the other hand, if PF status admission is not required, manufacturers could face two distinct risks:

  1. Risk of Overpayment: Goods made from parts or components that don’t enter under PF status might end up being subject to reciprocal tariffs on the total value of the finished goods when they are withdrawn.
  2. Risk of Inconsistent Application: If the PF status rule is not applied, manufacturers may inadvertently avoid tariffs on certain materials, creating compliance risks and complications when reporting and calculating duties.

At this stage, it’s unclear which route will be taken, and businesses must stay alert to official guidance as new policies unfold. This uncertainty underscores the need for proactive monitoring of developments and a readiness to adapt operational processes quickly.

Managing On-Hand FTZ Inventory

Another critical area of concern for FTZ operators and businesses utilizing FTZ services is how on-hand inventory will be affected by the reciprocal tariffs. Specifically, businesses will need to determine whether goods admitted before the tariff’s effective date can still avoid the new tariff rates when they are withdrawn from the FTZ after April 2, 2025.

Just as with other trade remedy actions (e.g., Section 301 or Section 232 tariffs), past inventory might be grandfathered in under the previous tariff structures. However, there is still a possibility that the new tariffs will apply retroactively, similar to the treatment of steel under Section 232 tariffs. This potential change could require businesses to reassess their inventory strategy and consider actions like filing Zone Status Change admissions or paying duties on inventory before the tariff implementation date.

The Role of FTZ Operators

FTZ operators, especially third-party logistics (3PL) providers, will have a significant role to play in helping businesses navigate these changes. While the ultimate responsibility for tariff compliance typically rests with the business using the FTZ, operators should be ready to assist with tasks such as filing customs entries, helping with inventory adjustments, and ensuring that the correct tariff classifications are applied.

3PL providers may also need to review their contracts with FTZ customers to clarify roles and responsibilities when it comes to compliance with new tariffs. Ensuring that customers are aware of their obligations and deadlines will be crucial to maintaining smooth operations in the face of regulatory shifts.

Increased CBP/ICE Enforcement and Compliance

In addition to the changes related to tariffs, businesses should also be aware of increased enforcement activities by U.S. Customs and Border Protection (CBP) and Immigration and Customs Enforcement (ICE). Recent inspections at bonded warehouses have led to heightened scrutiny, and FTZ operators are being reminded of their responsibilities to ensure employment eligibility verification for all personnel working within CBP-supervised facilities. Ensuring compliance with these regulations will be critical to avoiding potential penalties.

Preparing for the Future

In light of the uncertainty surrounding the implementation of reciprocal tariffs, FTZ operators and businesses should:

  • Monitor Regulatory Changes: Stay informed on updates regarding the application of reciprocal tariffs to understand whether PF status will be required for merchandise from impacted countries.
  • Review FTZ Inventory: Consider filing necessary Zone Status Change admissions to align with potential new tariff classifications before the effective date.
  • Prepare for Compliance: Ensure that all required customs transactions are in place to mitigate potential disruptions to business operations.
  • Collaborate with FTZ Operators: Engage FTZ operators early to clarify roles and responsibilities under the new tariff structures.

By taking these proactive steps, businesses can minimize the impact of reciprocal tariffs and continue to operate efficiently within FTZs, maintaining compliance and avoiding costly errors. Have questions? Reach out to your Future Forwarding representative for further guidance. 

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