Author: Scott Case

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

  1. Confirm your ACE Portal account is active and that you have the Importer sub-account assigned correctly.
  2. Verify ACH refund banking is current. Refunds will not be issued by paper check.
  3. Identify which of your entries were filed by Future Forwarding. Those are the ones we can file CAPE on directly.
  4. 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.
  5. Decide your filing approach. Test-submit a small set of unliquidated entries before bulk-uploading large batches.
  6. 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.

Understanding the India-US Cotton-Linked Textile Trade Arrangement: Mechanics and Market Implications

The proposed India-US trade agreement, expected to be finalized in March, introduces a conditional tariff structure for textile exports that warrants careful examination. Commerce Minister Piyush Goyal has confirmed that Indian textile manufacturers using American cotton in production will access the US market with significantly reduced duties—reciprocal tariffs dropping to 18%, with effective rates estimated at approximately 3% when combined with existing MFN (Most Favored Nation) provisions.

This arrangement follows a similar structure to the recent US-Bangladesh trade agreement, which reduced reciprocal tariffs to 19% and granted duty-free access for select textiles contingent on Bangladeshi manufacturers sourcing American cotton and man-made fibers. The parallel framework raises questions about emerging patterns in US trade policy and the conditions under which developing economies can access American consumer markets.

The Mechanics of the Conditional Access

Under the proposed structure, Indian manufacturers importing US cotton for processing will face zero duty on those imports. The reciprocal tariff reduction to 18%—combined with the continued application of MFN tariffs—creates the estimated 3% effective rate. This differs from unconditional market access in that benefits are explicitly tied to supply chain integration with American raw material producers.

The arrangement preserves most of India’s agricultural sector from liberalization, with 90-95% of farm products excluded from the agreement. This reflects ongoing sensitivities in India’s domestic political economy, where agricultural policy remains contentious and farmer welfare is a significant electoral consideration.

Market Context and Competitive Dynamics

Indian exporters had expressed concern following the US-Bangladesh agreement, which appeared to offer Bangladeshi manufacturers preferential terms in the American market. Bangladesh’s garment sector accounts for over 80% of that country’s export earnings and employs approximately four million workers, making textile access to the US market economically critical.

The India-US arrangement attempts to address this competitive asymmetry while acknowledging fundamental differences in the two economies. Goyal noted that US cotton production remains smaller than India’s domestic output, suggesting the arrangement is designed to supplement rather than replace Indian cotton in manufacturing.

Trade Policy Implications

This model of conditional market access represents a specific approach to trade liberalization—one that prioritizes supply chain integration over traditional tariff elimination. From the US perspective, it creates guaranteed demand for American agricultural products while maintaining some domestic production advantages. From India’s perspective, it offers enhanced market access without requiring comprehensive agricultural liberalization.

The structure also raises questions about trade policy effectiveness. Does conditioning market access on specific input sourcing create sustainable competitive advantages, or does it introduce supply chain rigidities that may prove problematic during commodity price fluctuations or supply disruptions?

Broader Negotiation Context

Goyal indicated that India is simultaneously pursuing trade negotiations with the European Union and United Kingdom, suggesting New Delhi is exploring multiple pathways to expand export markets. The extent to which this cotton-linkage model becomes a template for other negotiations—or remains specific to the US relationship—will likely depend on how the arrangement performs once implemented.

The agricultural exclusions also signal India’s negotiating boundaries. While willing to integrate with partner supply chains in manufacturing sectors, India appears less willing to liberalize agricultural trade, reflecting domestic political realities and food security considerations.

Implementation Questions

Several practical questions remain about implementation: How will compliance be verified? What happens to manufacturers who use blended cotton sources? How will fluctuations in US cotton prices affect the competitiveness of this arrangement? These operational details will significantly influence whether the agreement delivers the market access benefits both sides anticipate.

The March timeline suggests negotiations are well advanced, though the actual text and final terms have not been publicly released. As with any trade agreement, the difference between announced intentions and implemented realities often emerges in implementation details and dispute resolution mechanisms.

The New CBP Forced Labor Portal: What Importers Need to Know Right Now

If you’re importing goods into the United States, there’s a new system you need to know about—and it’s not optional.

As of January 21, 2026, U.S. Customs and Border Protection requires all importers to use the newly launched Forced Labor Portal for specific review requests. If your shipment gets detained or excluded under forced labor enforcement, you’ll need to navigate this system to resolve the issue.

Here’s what changed, what it means for your operations, and how to prepare.

What Is the Forced Labor Portal?

The Forced Labor Portal is CBP’s centralized platform for submitting review requests when shipments are detained or excluded due to forced labor concerns. Before this portal, the process was more fragmented. Now, everything goes through one system.

The portal directs your submission to the appropriate CBP personnel—whether that’s the Forced Labor Division, your Port of Entry, or a Center of Excellence and Expertise—depending on the type of review you’re requesting.

What’s Now Mandatory

Starting January 21, 2026, you must use the Forced Labor Portal to submit these four types of reviews:

1. Withhold Release Order/Finding Admissibility Reviews If your goods are subject to a Withhold Release Order (WRO) or a finding that prohibits their entry, you’ll submit your admissibility review through the portal.

2. UFLPA Applicability Reviews The Uyghur Forced Labor Prevention Act (UFLPA) creates a presumption that goods from Xinjiang or made with Xinjiang materials were produced with forced labor. If your shipment is detained under this presumption, your review request goes through the portal.

3. UFLPA Exception Requests In limited circumstances, importers can request an exception to UFLPA enforcement. These requests now require portal submission.

4. CAATSA Exception Requests The Countering America’s Adversaries Through Sanctions Act can affect certain shipments. Exception requests for CAATSA-related detentions also go through the new system.

Why This Matters for Your Supply Chain

If you source from regions or industries flagged for forced labor concerns—textiles, agricultural products, electronics, solar materials, certain minerals—you need to understand this system before you need it.

Detention isn’t just inconvenient. It means your goods sit at the port while you scramble to prove compliance. Storage fees accumulate. Production schedules slip. Customer commitments become harder to meet.

Having a plan before detention happens makes all the difference. That means knowing:

  • How to access the portal
  • What documentation CBP expects
  • How to structure your review request
  • What your response timeline looks like

Getting Started with the Portal

CBP has made the portal available at https://flportal.cbp.gov/s/login/

They’ve also released supporting resources:

  • A quick reference guide walking you through the submission process
  • An instructional video demonstrating how to submit requests
  • A recorded webinar (available soon) for more detailed guidance

All of these resources are available on CBP’s forced labor webpage at www.cbp.gov/trade/forced-labor.

If you have questions about the portal itself, CBP has set up a dedicated email: ForcedLabor@cbp.dhs.gov.

What You Should Do Now

Even if you’ve never had a shipment detained, understanding this system is smart risk management. Consider these steps:

Review your supply chain exposure. Do you source from regions or industries with heightened forced labor scrutiny? Understanding your risk profile helps you prepare.

Familiarize yourself with the portal. Don’t wait until you’re under pressure from a detention to learn the system. Review the quick reference guide and watch the instructional video now.

Document your due diligence. If you do face a detention, your ability to demonstrate supply chain transparency and compliance efforts will be critical. Make sure your documentation is organized and accessible.

Talk to your customs broker. Your broker should understand this new requirement and be prepared to help if a detention occurs. Make sure they’re informed and ready.

The Bigger Picture

This portal launch is part of CBP’s broader forced labor enforcement effort. The agency isn’t backing away from these requirements—they’re building infrastructure to manage them more efficiently.

For importers, that means forced labor compliance isn’t a one-time checkbox. It’s an ongoing operational consideration that requires visibility into your supply chain, strong documentation practices, and the ability to respond quickly when issues arise.

The companies that handle this well are the ones who treat it as a supply chain management issue, not just a compliance problem. They know their suppliers. They verify their sources. They maintain documentation that demonstrates due diligence.

Questions to Consider

As you think about how this affects your operations, here are a few questions worth discussing with your team:

  • Do we have complete visibility into our supply chain, including subcontractors and raw material sources?
  • Have we conducted forced labor risk assessments for our key suppliers?
  • Do we have documentation that demonstrates our due diligence efforts?
  • Does our team know how to access and use the new portal if needed?
  • Have we briefed our customs broker on this new requirement?

Moving Forward

The launch of the Forced Labor Portal represents CBP’s commitment to more structured, centralized enforcement. For importers, it’s a reminder that forced labor compliance requires proactive attention.

If you’re navigating these requirements and need guidance on supply chain compliance, documentation, or customs procedures, that’s exactly the kind of challenge Future Forwarding helps clients solve. We stay current on regulatory changes so you can focus on running your business.

Why the AGOA and HOPE/HELP Extensions Matter More Than You Think

If your supply chain touches textiles, apparel, or critical minerals, the House vote just bought you three more years of stability—and a window to make some strategic decisions.

The US House of Representatives approved the renewal of two significant trade programs: the African Growth and Opportunity Act (AGOA) and the HOPE/HELP initiatives for Haiti. Both programs had already expired, creating uncertainty for businesses that depend on stable sourcing partnerships. The three-year extension, if signed into law, will be retroactive.

For companies navigating an increasingly complex global trade environment, this isn’t just legislative housekeeping. It’s a signal about where American trade policy is headed—and what that means for your procurement strategy.

What Just Happened?

AGOA, first enacted in 2000, provides qualifying sub-Saharan African countries with duty-free access to the US market. We’re talking about more than 1,800 products that can enter without tariffs, plus over 5,000 additional goods covered under the Generalised System of Preferences. In 2024, 32 countries met the strict eligibility requirements related to governance, anti-corruption measures, human rights, and market access.

The program expired on September 30, 2025. Congress last extended it in 2015, setting that expiration date a decade in advance.

The HOPE/HELP program offers similar trade preferences specifically for textile and apparel products from Haiti, a country located less than 700 miles from the US coast.

Both programs lapsed before the House vote, creating a period of uncertainty that had trade organizations sounding the alarm. The American Apparel & Footwear Association, along with other industry groups, pushed Congress to act quickly due to the disruption caused by expired preferences.

Why This Matters for Your Business

The textile and apparel connection is direct. If you’re sourcing garments, fabrics, or related products, these programs directly impact your duty structure and landed costs. The AAFA noted that these measures support 3.6 million American workers by opening markets for US cotton and textile exports while enabling diversified sourcing.

The HOPE/HELP extension is particularly significant for companies focused on nearshoring. Haiti offers geographic proximity to the United States—a major advantage when you’re trying to reduce lead times and transportation costs. The program’s renewal provides stability for Haiti’s apparel sector despite ongoing political challenges in the country, which supporters argue is important both economically and from a regional security perspective.

The strategic importance goes beyond textiles. AGOA is widely viewed as central to US efforts to counter economic activities by China and Russia in Africa. China has invested an estimated $8 billion to $10 billion in Africa, largely focused on securing access to critical mineral resources. These minerals—which include materials essential for batteries, electronics, and defense applications—account for approximately 30% of the global supply.

The renewal of AGOA signals that the United States intends to maintain economic relationships with African nations that can provide access to these strategic resources. For businesses in manufacturing, technology, or any industry dependent on critical minerals, this has long-term implications for supply chain resilience.

The Three-Year Timeline: Opportunity or Warning?

Here’s what stands out: Congress extended these programs for three years. That’s not much runway if you’re making major capital investments or long-term sourcing commitments based on duty-free access.

Think of this as a probationary period. The eligibility requirements for AGOA—particularly around governance, anti-corruption, and human rights—aren’t just paperwork. They’re conditions that can change. Countries can lose eligibility if they don’t maintain standards. Your suppliers’ duty-free status isn’t guaranteed just because they have it today.

This is also Congress signaling that it wants flexibility. Trade policy is increasingly viewed through the lens of strategic competition, workforce impact, and supply chain security. A three-year extension allows lawmakers to reassess priorities relatively quickly.

What Smart Companies Are Doing Now

Diversifying duty exposure. If you’re heavily dependent on products that enter duty-free under AGOA or HOPE/HELP, now is the time to model what happens if those preferences change or expire. What’s your landed cost if you’re suddenly paying standard tariff rates? How does that change your pricing or margins?

Evaluating alternative sourcing. Three years gives you time to identify backup suppliers in other regions or explore domestic options for critical inputs. This doesn’t mean abandoning current partnerships—it means having a Plan B that’s more than theoretical.

Strengthening supplier relationships in qualifying countries. If you have good partnerships with suppliers in AGOA-eligible countries, this extension is an opportunity to deepen those relationships while the benefits are locked in. The programs promote stable, transparent supply chains, which is exactly what most procurement teams are trying to build.

Watching the nearshoring trend. The HOPE/HELP extension aligns with broader American trade priorities focused on nearshoring and onshoring. If you’re in textiles or apparel, Haiti’s geographic advantage—combined with trade preferences—makes it worth evaluating as part of a Western Hemisphere sourcing strategy.

The Bigger Picture

These extensions are part of a larger recalibration of US trade policy. Whether it’s tariff discussions with the EU, tensions with China, or strategic partnerships in Africa, the common thread is that trade is no longer just about cost optimization. It’s about resilience, strategic positioning, and managing geopolitical risk.

For businesses, that means trade policy monitoring can’t be something you review quarterly anymore. When programmes expire and get renewed on short timelines, when tariff rates can shift based on diplomatic negotiations, and when supplier eligibility can change based on governance standards, staying informed becomes a competitive advantage.

What Happens Next

The House has voted. The bill now moves to the Senate, where the AAFA is urging swift action given the bipartisan support and the fact that these programs have already expired. Once enacted, the three-year extension will be retroactive, which provides some relief for shipments that entered during the lapsed period.

Beth Hughes, vice president of trade and customs policy at the AAFA, put it clearly: “Yesterday’s vote reflects bipartisan recognition that protecting the African and Haitian apparel and footwear industries strengthens the US apparel and footwear industry, and its 3.6 million American workers, by opening markets for US cotton and textile exports and advancing diversified sourcing goals.”

That’s the framework to understand here. These programs aren’t charity—they’re strategic tools that connect American economic interests with international partnerships. When they work, everyone benefits: African and Haitian suppliers get market access, American companies get duty-free imports, and US exporters of cotton and textiles get customers.

The Bottom Line

If your business touches textiles, apparel, footwear, or critical minerals sourced from sub-Saharan Africa or Haiti, the renewal of AGOA and HOPE/HELP gives you three years of clarity. Use that time wisely.

Model your exposure. Diversify your sourcing. Strengthen your partnerships. And keep watching the Senate, because until this becomes law, uncertainty remains.

Trade policy is moving faster than it used to. The companies that treat these changes as opportunities to reassess and adapt will be better positioned than those who simply hope for stability and do nothing.

For a call back get in touch:

Contact Us

Ⓒ Future Forwarding 2026. All rights reserved.
Terms of use | Privacy policy | Sitemap | Web Design by Cocoonfx