New CBP Mail Shipment Requirements Take Effect July 24

New CBP mail shipment requirements are coming — and if your business imports goods through international mail, the July 24 effective date is closer than it may seem.

CBP has published an interim final rule requiring additional data for mail shipments valued at $2,500 or less that enter through the agency’s informal entry process. Starting July 24, importers or their brokers must provide a description of the merchandise, all 10-digit Harmonized Tariff Schedule (HTS) codes, and quantity and weight where those figures affect applicable duties. This information must be submitted by the seventh day of the month following the shipment’s arrival.

Why This Is Happening

The new rule is part of a broader push by the U.S. Administration to bring mail imports under the same scrutiny as other goods entering the United States. The de minimis exemption — which previously allowed low-value shipments to enter with minimal documentation — was eliminated last year. Postal shipments now face duties equal to the current 10% global tariff, and these new data requirements are designed to ensure those duties are actually collected.

CBP estimates the change will generate more than $100 million in additional annual duty revenue.

Who Needs to File — and Who Can

The party submitting the required data must be an owner, purchaser, or a licensed customs broker. Currently, about half of qualified filers are brokers. If you or your foreign postal operator does not already have a broker relationship, you will need to establish one before the rule takes effect. CBP has acknowledged this will take time and has noted it as a compliance burden for affected parties.

An Electronic Entry Test Is Also Coming

Separately, CBP will launch a voluntary test program called Entry Type 13, available from September 22. Open to shipments valued at $2,500 or less, the test allows importers and brokers to submit additional data — including postal tracking numbers and recipient information — electronically. CBP has described it as part of a phased approach to bring mail imports into full parity with all other imported goods.

What This Means for Your Business

If you import through international mail channels and do not currently work with a licensed customs broker, now is the time to act. The new CBP mail shipment requirements leave limited time to identify a broker, establish a relationship, and ensure your data submission process is in place.

Future Forwarding is here to help you navigate these changes. If you have questions about how the new requirements apply to your shipments, reach out to your Future Forwarding representative today.

DOJ Appeals IEEPA Tariff Refund Order

What the DOJ’s Appeal Means for IEEPA Tariff Refunds

If your business has been tracking IEEPA tariff refunds, a new legal development adds a layer of uncertainty to an already complex process — and importers should understand what it means for them.

The Department of Justice has filed a formal appeal challenging part of the Court of International Trade’s order directing U.S. Customs and Border Protection (CBP) to issue universal IEEPA tariff refunds. The appeal does not halt the refund process entirely, but it does narrow the legal ground the government believes it must stand on — and that distinction matters.

What’s Being Appealed — and What Isn’t

The Court of International Trade originally ordered CBP to return funds paid on tariffs enacted under the International Emergency Economic Powers Act (IEEPA), following a Supreme Court decision invalidating those levies. The court’s initial directive covered unprocessed or unfinalized entries, but was later expanded to include finally liquidated entries.

It is this expansion — the universal refund order covering all finalized entries — that the DOJ is contesting. The agency argues that the court does not have jurisdiction to issue a blanket order covering every importer. In its view, the court may only mandate refunds for parties that have filed individual lawsuits.

This is a procedural and jurisdictional argument, not a challenge to the underlying principle that IEEPA tariffs were unlawful.

The Refund Portal Is Still Operating

CBP’s dedicated refund system, known as CAPE (Consolidated Administration and Processing of Entries), continues to process returns. As of late May, the portal had delivered approximately $20.6 billion in refunds and was on track to issue $85 billion in total.

However, CAPE does not yet have the technical capability to process finally liquidated entries — the very category at the center of the DOJ’s appeal. CBP is developing this functionality, and the Court of International Trade has issued a temporary stay on its universal order while that work continues.

Court Scrutiny Is Intensifying

The court is clearly monitoring progress closely. It has ordered CBP Commissioner Rodney Scott to appear at a July 9 hearing to account for the agency’s compliance with the refund directive. The DOJ has pushed back on this as well, filing an emergency motion to block or delay Scott’s appearance, arguing that compelling testimony from a senior agency head sets a problematic precedent under separation-of-powers principles.

Whether or not Scott ultimately appears, the hearing itself signals that the court expects timely, demonstrable progress — not open-ended delays.

What This Means for Importers

For most businesses already receiving refunds through CAPE, day-to-day operations are unlikely to be immediately affected. The appeal primarily concerns how broadly the refund obligation extends to finalized entries — not whether refunds are owed at all.

That said, importers with finally liquidated entries should be aware that their path to a refund may depend on the outcome of this appeal, or on whether they have — or need to — file individual legal claims.

Future Forwarding is continuing to monitor these developments closely. As always, we will not alter how we clear your shipments until formally authorized to do so in writing by U.S. Customs. If you have questions about how these developments affect your specific entries, please reach out to your Future Forwarding representative.

The EU-US Trade Deal Is Moving Forward — Here’s What Importers Need to Know

After months of political back-and-forth, the EU-US trade deal is finally moving toward implementation — and for importers and exporters on both sides of the Atlantic, the window to prepare is now.

The agreement, originally struck last July, caps U.S. tariffs on most European goods at 15%. In return, the EU committed to removing levies on the majority of American imports. Following formal approval by all 27 EU member states, the deal now awaits a final sign-off from the European Parliament, expected when lawmakers convene in Strasbourg in mid-June.

How We Got Here

The road to ratification has been anything but smooth. The European Parliament suspended the process on multiple occasions, citing concerns that the terms favored the U.S. side. Lawmakers pushed hard for stronger protections — including a “sunrise” clause that would have made EU tariff reductions conditional on the U.S. first meeting its own commitments, as well as more robust safeguards against the deal being abandoned.

The compromise that finally moved things forward was negotiated carefully to balance Parliament’s concerns without reigniting tensions across the Atlantic. The sunrise clause was ultimately dropped. A sunset clause — setting an expiry date for the agreement — was retained but pushed to the end of 2029. Safeguards protecting the EU’s position if the U.S. fails to follow through were included, though scaled back from Parliament’s original demands.

Notably, the U.S. has been given until the end of 2025 to eliminate additional taxes above 15% on steel components, rather than requiring this as a precondition for the deal to take effect.

What This Means for Your Supply Chain

For businesses moving goods between the EU and the U.S., the EU-US trade deal brings both opportunity and complexity. On the opportunity side, reduced tariff exposure on most goods categories could meaningfully lower landed costs — particularly for European exporters shipping into the American market, and for U.S. businesses sourcing from Europe.

The complexity lies in the details. The deal contains conditional mechanisms, phased timelines, and built-in safeguards that could affect how and when tariff reductions apply to specific product categories. Steel and steel-adjacent products, for instance, operate on a separate timeline. And the overall framework remains contingent on both parties holding to their commitments — something the safeguard clauses are designed to address, but cannot fully guarantee.

What You Should Be Doing Now

With mid-June ratification on the horizon and a July 4 implementation deadline in play, now is the time to act — not wait.

Review your current tariff exposure across EU-US trade lanes and identify which product categories stand to benefit most from reduced levies.
Audit your country of origin documentation to ensure your goods will qualify under the agreement’s terms.
Model your new landed costs to understand the pricing and margin implications on both sides of the Atlantic.
Stay alert to conditional provisions — particularly around steel components and the deal’s built-in safeguards — that may affect your specific supply chain.

Trade agreements of this scale rarely deliver a clean, simple outcome. The benefit is real, but it requires preparation to capture.

Future Forwarding’s teams in the U.S. and UK are monitoring this closely. If you have questions about how this agreement affects your imports or exports, we’re here to help you navigate it with confidence.

The Squeeze Is Real: What Rising Costs Mean for UK Retail Supply Chains

The British Retail Consortium (BRC) made headlines recently when it called on the UK government to intervene on mounting cost pressures facing retailers. A poll commissioned by the BRC found that four in five consumers are concerned that ongoing instability in the Middle East will push food prices higher — and retailers say that concern is well-founded. Energy costs, freight rates, and logistics expenses are already straining supply chains before those pressures have fully worked their way through to the shelf.

At Future Forwarding, we work with importers and retailers on both sides of the Atlantic. What we are seeing on the ground tracks closely with what the BRC is describing.

A Squeeze From Two Directions

What makes the current environment particularly challenging is that it is not one problem — it is two converging at the same time.

The first is global. Continued instability in the Middle East has kept shipping lanes under pressure, with elevated insurance premiums and longer routing times on certain trade corridors. When freight costs rise, those increases do not stay with the carrier. They move through the supply chain and ultimately reach the importer, the retailer, and the consumer.

The second pressure is domestic. As BRC Chief Executive Helen Dickinson noted, not every challenge facing UK retailers originates overseas. Higher employer national insurance contributions, new packaging levies, revised business energy charges, and a growing regulatory burden are all policy decisions made in Westminster — and they land on top of the global headwinds, not instead of them.

The compounding effect of both simultaneously is what makes this moment particularly difficult to navigate.

Why This Matters for Importers

For businesses that source goods internationally — whether finished products, components, or raw materials — the cost picture has become increasingly complex. Freight rates fluctuate based on geopolitical conditions that can shift with little warning. Customs and compliance requirements add another layer of planning. And on the UK side, the evolving domestic regulatory landscape means that landed costs need to be recalculated more frequently than many businesses are accustomed to.

For our US-based clients with UK operations or sourcing relationships, it is worth noting that these pressures are not confined to one market. Global freight dynamics affect transatlantic shipments as well, and cost management strategies need to reflect that reality.

What You Can Do Now

While no business can fully insulate itself from geopolitical or macroeconomic forces, there are practical steps importers can take to manage exposure:

Review your total landed cost calculations. If your freight, insurance, and logistics assumptions have not been updated recently, they may no longer reflect current market conditions. Accurate landed cost data is the foundation of sound pricing and procurement decisions.

Audit your supply chain routing. Some trade corridors are more affected than others by current conditions. Working with your freight forwarder to evaluate routing options — including transit times, carrier options, and cost tradeoffs — can surface savings that are not immediately obvious.

Stay ahead of regulatory changes. In the UK specifically, packaging regulations and energy-related charges are evolving. Understanding the timeline and cost implications of upcoming changes allows for better planning rather than reactive adjustments.

Build contingency into your planning horizon. The environment is unlikely to stabilise quickly. Budgets and procurement plans that incorporate a range of scenarios, rather than a single forecast, will be more resilient.

The Broader Picture

The BRC’s call to action is directed at government ministers, and rightly so — there are levers within domestic policy that can ease pressure on businesses and households alike. But the supply chain challenge is broader than any single policy decision. It is the cumulative effect of global instability, rising input costs, and a more complex compliance environment landing simultaneously on businesses that are already working hard to hold prices steady.

Future Forwarding’s role in that environment is to help our clients move goods efficiently, compliantly, and with as much cost visibility as possible. Whether you are importing into the UK, the US, or both, we are here to help you understand what the current landscape means for your shipments — and what options you have.

If you would like to talk through how current conditions are affecting your supply chain, reach out to our team.

CAPE Is Live — and the Clock Is Now Running

An update on the IEEPA refund process, what CBP told the Court of International Trade on April 28, and what importers need to do now.

On April 20, 2026, U.S. Customs and Border Protection opened the front door on what may be the largest duty refund process in modern U.S. trade history. The Consolidated Administration and Processing of Entries — CAPE — went live at 8:00 a.m. ET that morning inside the ACE Portal, giving importers and licensed customs brokers a direct electronic mechanism to request refunds of duties paid under the International Emergency Economic Powers Act. (CBP CSMS #68340863)

Eight days later, on April 28, CBP filed its first court-ordered status report on the Phase 1 rollout with the U.S. Court of International Trade. The numbers tell a story worth paying attention to. (Sourcing Journal)

What the April 28 Status Report Said

Brandon Lord, CBP’s Executive Director of Trade Programs, is required to report directly to the CIT on Phase 1 progress. His April 28 declaration in Euro-Notions Florida, Inc. v. United States (Court No. 25-00595, before Senior Judge Richard K. Eaton) showed:

75,306 CAPE Declarations filed as of 8:00 p.m. on Sunday, April 26 — with 47,315 designated as properly filed.
11.2 million entries submitted through the system in under a week.
Approximately 21% accepted at the file-validation stage; about
3% — roughly 1.74 million entries — had reached the refund stage of the process.
The system experienced a single 18-minute pause on launch day to reconfigure resources, and has been continuously available since.
First refunds are expected to land in importer accounts by May 11, 2026.

In the filing, Lord stated that “the CAPE functionality is working successfully.” Judge Eaton, however, raised lingering concerns at a closed-door conference held the same day — including ACE login problems following forced password resets, oversubscribed CAPE training sessions, and confusion among trade members about which party should actually file a CAPE Declaration. The Judge has ordered CBP to file a follow-up progress report on May 12. (Sourcing Journal)

What Phase 1 Actually Covers — and What It Doesn’t

CAPE is being rolled out in phases. Phase 1 is intentionally narrow. It accepts only:

Certain unliquidated entries, and
Certain entries within 80 days of liquidation (to align with the 90-day voluntary reliquidation window).

CBP estimates Phase 1 captures roughly 63% of entries that had IEEPA duties imposed. Excluded from Phase 1 — and pushed to later phases or alternative remedies — are reconciliation entries, entries flagged for AD/CVD, suspended entries, and entries for which liquidation is final. (CBP Trade Information Notice)

In aggregate, the universe is enormous. Court filings put the total at approximately 330,000 importers, around $166 billion in IEEPA duties, and more than 53 million entries. (Abasto)

Who Can Actually File a CAPE Declaration

This is the part that is generating the most confusion in the trade community right now, and it is the most important operational point in this entire piece.

Only the Importer of Record (IOR) — or the licensed customs broker who actually filed the original entry — can file a CAPE Declaration on those entries.There is no third-party workaround. A different broker cannot file CAPE on entries they did not transmit. A consultant or service provider cannot file on an importer’s behalf without being the original filer or operating directly through the IOR’s ACE sub-account. (CBP IEEPA Duty Refunds page)

In practical terms: if Future Forwarding filed your entries, we file your CAPE Declaration. If a different broker filed them, that broker has to file. And if you are the IOR filing direct, the work falls to your team and your ACE Portal access.

The 60–90 Day Refund Window — and the One Thing That Will Stop It

Once a CAPE Declaration is validated and accepted, CBP expects valid IEEPA refunds (including statutory interest) to be issued within 60 to 90 days, unless a compliance concern requires further review. ACE strips the IEEPA Chapter 99 HTS provisions and corresponding duties from the entry, recalculates the duty owed without those codes, and CBP liquidates or reliquidates accordingly. (CBP IEEPA Duty Refunds page)

There is one operational issue that can stop the entire flow before it starts: refund banking setup.

CBP refunds under CAPE are issued by ACH, tied to bank account information stored in the IOR’s ACE Portal account. If your ACE account is not active, or if your ACH refund details are not properly registered, even a fully accepted CAPE Declaration can stall at the payment stage. We covered this in detail in our earlier piece —

IEEPA Refunds: What Importers Need to Know — and Do — Right Now — and that guidance is now more urgent, not less. If you have not confirmed that your ACE Portal Importer sub-account is set up and that your ACH refund banking is current, that is the single most important thing on your desk this week.

What This Looks Like From Where We Sit

The April 28 numbers are encouraging in one direction and sobering in another. Encouraging: the system held up under enormous early-week volume, and refunds are beginning to move. Sobering: only about 3% of submitted entries have reached the refund stage so far, and 19% of entries that passed file validation were ultimately rejected at the entry-validation stage. (Sourcing Journal)

This is not a “file and forget” process. CBP has made clear that CAPE is the front end of a review and validation pipeline — not a passive payout system. Submissions with classification errors, valuation inconsistencies, country-of-origin issues, or tariff-stacking complications (Section 232, Section 301) are precisely the ones that get caught at validation or flagged for post-refund audit. The importers moving cleanly through CAPE are the ones who audited their entry data before they uploaded a single CSV. (Baker Tilly)

There are also strategic considerations worth flagging. CAPE-processed refunds remain available to offset other duties owed, which means importers with disputed liabilities elsewhere on their ACE record need to think carefully about sequencing. CBP will not process CAPE entries that are also under protest. And the broader litigation question is far from settled: the government has until approximately June 7 to appeal Judge Eaton’s underlying refund order, and is widely expected to do so. (Snell & Wilmer)

What to Do This Week

Confirm your ACE Portal account is active and that you have the Importer sub-account assigned correctly.
Verify ACH refund banking is current. Refunds will not be issued by paper check.
Identify which of your entries were filed by Future Forwarding. Those are the ones we can file CAPE on directly.
Pull your IEEPA exposure. Filter ACE’s Entry Summary Details Report (ES-003) on HTSUS Chapter 99 provisions 9903.01.XX and 9903.02.XX.
Decide your filing approach. Test-submit a small set of unliquidated entries before bulk-uploading large batches.
Track the May 12 progress report. That filing will tell us how the system is holding up at scale and whether Phase 2 timelines start to come into focus.

Talk to Future Forwarding About Your CAPE Filings

If Future Forwarding filed your entries, we are already positioned to prepare and submit your CAPE Declaration on your behalf. If you’re unsure which of your entries qualify for Phase 1, or you want a second set of eyes on your refund exposure before you file, contact your Future Forwarding representative to learn more about filing a CAPE Declaration and what we can do to make sure your refunds move cleanly through the system.

New Federal Tools Offer a Stronger Starting Point for Labor Risk Due Diligence

Supply chain due diligence has never been a simple checkbox exercise, and the regulatory environment over the past few years has made that clearer than ever. For U.S. importers, understanding labor risk across global supplier networks — especially beyond the first tier — remains one of the more difficult operational challenges to get right.

The U.S. Department of Labor’s Bureau of International Labor Affairs recently made that work a little easier, launching four free self-assessment tools designed to help businesses map risk, evaluate supplier practices, and build more resilient due diligence programs.

The tools are worth understanding individually:

LaborShield is a mobile app providing country-level data on labor violations across more than 145 countries — useful for sourcing teams that need quick, reliable reference points when evaluating new markets or suppliers.

ImportWatch brings together ILAB’s labor abuse research and U.S. Census Bureau import data into a consolidated view of high-risk goods. For compliance teams, it’s a strong early-warning resource that doesn’t require building the analysis from scratch.

SourcingStrong provides a structured framework for developing or strengthening a labor due diligence program. Whether a company is formalizing an existing process or starting to build one, it offers a practical foundation.

The Supply Chain Traceability Portal addresses one of the field’s most persistent gaps — visibility past Tier 1. The portal helps organizations map deeper into their supply chains, identifying where exploitation risk is most likely to exist in layers that traditional audits rarely reach.

Taken together, these tools won’t replace a mature compliance program, but they meaningfully lower the barrier to entry for teams looking to strengthen their approach. As enforcement under the Uyghur Forced Labor Prevention Act continues to evolve and sub-tier visibility becomes an increasing expectation, having better information earlier in the process is a genuine advantage.

For teams looking to strengthen their due diligence approach, these tools are a solid place to start — and the conversation doesn’t have to stop there. If you’re unsure how new regulatory developments fit into your current compliance strategy, reach out to your Future Forwarding representative. We’re here to help you stay ahead of what’s coming.

When Trade Tensions Stay at the Table

The United States and China are once again experiencing trade tensions: investigating each other’s trade practices. But unlike the headline-grabbing tariff battles of recent years, this round is quieter — and in some ways, more complex.

In late March 2026, China’s commerce ministry launched two formal counter-probes into U.S. trade practices, responding directly to Section 301 investigations the U.S. initiated earlier this month across 16 trading partners. Beijing describes its probes as reciprocal — a measured word choice that tells you a great deal about where this relationship currently stands.

The two Chinese investigations cover distinct ground. The first examines U.S. measures that restrict Chinese goods from entering American markets while also limiting U.S. exports of high-tech products to China — barriers that, Beijing argues, cut both ways. The second focuses on U.S. policies that China says slow the deployment of new energy projects and limit green product trade, to the detriment of Chinese companies operating in that space.

What’s notable is what’s not happening. There are no immediate retaliatory tariffs. No sweeping new restrictions announced overnight. Both sides are raising concerns through formal investigations and bilateral talks — most recently in Paris and on the sidelines of a WTO meeting in Cameroon. A planned U.S. presidential visit to Beijing in mid-May signals that both governments are invested in keeping the dialogue open.

This is trade friction being managed at the table, not escalated through executive action. Both probes carry a six-month timeline, with the possibility of extension. Whether they result in concrete measures depends heavily on how diplomacy unfolds in the months ahead.

For businesses with exposure to technology products, industrial components, or green energy goods, this is a moment to pay attention — not to panic, but to plan. The frameworks being built now could shape trade conditions well into 2027.

Future Forwarding tracks trade developments and their impact on global supply chains. Subscribe to our updates to stay informed.

IEEPA Refunds: What Importers Need to Know — and Do — Right Now

On February 20, 2026, the U.S. Supreme Court issued a landmark 6-3 ruling striking down tariffs imposed under the International Emergency Economic Powers Act (IEEPA), holding that the law does not grant authority to levy tariffs — a power that belongs exclusively to Congress. It was a consequential decision, and one that has prompted a wave of questions from importers navigating what comes next.

Our colleagues at BDO USA published an excellent breakdown of the ruling and its practical implications. We wanted to add an operational perspective — because understanding the law is only half the battle. Acting on it is the other half.

Yes, Refunds Are on the Table — But Not Yet in Your Pocket

If your business paid IEEPA tariffs, you are likely eligible for refunds. The revoked executive orders cover tariffs paid as far back as February 4, 2025 for the “fentanyl” tariffs and April 2, 2025 for the “reciprocal” tariffs, with additional refunds potentially available related to Venezuela, Brazil, and Russia. That’s a meaningful window — potentially over a year’s worth of duties collected without legal authority.

However, the refund process itself is still being built. CBP recently informed the Court of International Trade that it cannot yet comply with a court order to begin issuing refunds, citing the sheer scale of the undertaking — an estimated 53 million entries totaling roughly $166 billion in deposits. CBP has proposed a 45-day timeline to develop a streamlined process through the Automated Commercial Environment (ACE) system, but as of now, the operational mechanics are still being worked out. As one international trade attorney noted publicly, “the refund process is likely coming, but not immediately.”

What Importers Should Be Doing Now

Waiting on CBP to finalize its process doesn’t mean waiting to prepare. There are concrete steps importers should be taking today:

1. Get into ACE — and set up electronic refunds. This is critical on two levels. First, ACE is the system through which refunds will be processed and validated. Second, CBP transitioned to electronic-only refunds in February, meaning refunds can no longer be issued by paper check. Importers who have not yet registered for electronic refunds in ACE will not be able to receive payments when the process goes live. CBP estimates that thousands of refunds are already being held up for this reason.

2. Start calculating. Pull the Entry Summary Details Report (ES-003) from your ACE account and filter by HTSUS codes 9903.01.XX and 9903.02.XX to isolate IEEPA tariff payments. Build out refund calculations by entry, by country, and by tariff rate. Interest on overpaid duties accrues at IRS-published quarterly rates, so having accurate figures ready now will be a significant advantage.

3. Understand the Protest deadline. CBP’s Centers of Excellence and Expertise are currently holding IEEPA-related PSC requests pending headquarters guidance, and filings are being denied. The more practical path is to wait for entries to liquidate and then file a Protest — but timing matters. Once an entry liquidates, importers have 180 days to file a Protest, and that deadline is firm. Missing it forfeits the right to a refund on that entry. Note that CBP’s ACE system is currently auto-liquidating entries each Friday — including those subject to IEEPA duties — because isolating those entries for a manual hold is not yet technically feasible. Monitoring your liquidation dates closely and having your Protest strategy ready is essential.

Other Tariffs Remain in Effect

The ruling applies only to IEEPA-based tariffs. Section 232 tariffs covering steel, aluminum, autos, semiconductors, and more remain fully in place, as do China Section 301 tariffs ranging from 7.5% to 100%. A new 10% temporary surcharge under Section 122 of the Trade Act of 1974 took effect on February 24, 2026 and is set to expire July 24, 2026 — unless Congress acts to extend it.

The broader tariff landscape remains fluid. Additional Section 232 investigations are pending, Section 301 actions are expected to expand, and there is discussion of potential duties under Section 338 of the Tariff Act of 1930, which could allow tariffs of up to 50% on imports from countries deemed to discriminate against U.S. commerce.

We’ll continue to update you as we learn more.

The Rules Just Changed: What China’s Trade Reset Means

Last week, the US Supreme Court struck down broad-based tariffs imposed under the International Emergency Economic Powers Act (IEEPA), invalidating both the 10 percent ‘fentanyl tariff’ and the 34 percent ‘reciprocal tariff’ on Chinese goods. It was a significant legal moment — and one that has moved fast.

Within days, the US pivoted to Section 122 of the Trade Act of 1974, imposing a fresh 10 percent import surcharge across all trading partners. That measure is set to expire in 150 days. Meanwhile, a sixth round of US-China trade talks is now expected shortly, building on five rounds held last year, the last of which took place in Malaysia in October.

The message from Beijing has been measured but deliberate. China’s Ministry of Commerce signaled that any adjustments to its countermeasures will come “at an appropriate time” — language that tells you everything about how carefully both sides are managing their next move.

So what does this mean for businesses on both sides of the Atlantic?

The short answer: uncertainty is not going away, but the shape of it is changing.

For years, businesses have had to navigate a tariff environment defined by executive action and geopolitical friction. The Supreme Court ruling introduces a new variable — judicial constraint on how far US trade policy can stretch under emergency powers. That is not a small shift. It signals that the legal architecture underpinning US trade action is being tested and, in some cases, redrawn.

At the same time, the move to Section 122 shows that Washington’s intent to apply trade pressure has not softened — only its legal instrument has changed. The 150-day clock on the new surcharge means businesses should expect continued flux well into the second half of 2025.

For UK-based businesses with transatlantic supply chains or exposure to US-China trade flows, this is a moment to stress-test your assumptions. Where are your dependencies? Where are your buffers? What does your sourcing strategy look like if the sixth round of talks produces meaningful concessions — or breaks down entirely?

The businesses that will navigate this best are those treating it as a strategic inflection point, not a compliance exercise.

What has changed is the pace and the unpredictability. Trade policy has always shifted — but when the legal foundations underpinning it are being challenged in the Supreme Court and new measures are being introduced with 150-day expiry dates, the window for strategic adaptation is shrinking. Boards can no longer afford to treat this as something to monitor quarterly.

The rules just changed. The question is whether your strategy has.

Author: Scott Case

Supply Chain Mapping Is Now a Legal Minefield — And Importers Are Caught in the Middle