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

Supply chain mapping has long been a legal obligation for companies sourcing from China — but a new conflict between US and Chinese law has made it one of the most complicated compliance challenges in international trade today.

The core problem is a direct conflict between US and Chinese law. On one side, the US Uyghur Forced Labor Prevention Act (UFLPA) requires importers to prove that goods originating from China’s Xinjiang Uyghur Autonomous Region are not made with forced labor. The only way to do that is through thorough, multi-tier supply chain mapping and documentation. On the other side, China has passed two new regulations — known as Regulations 834 and 835 — that restrict foreign companies, governments, and individuals from investigating the origins of raw materials, components, and finished goods produced in China. In other words: US law demands transparency, and Chinese law prevents it.

What the UFLPA Actually Requires

Under the UFLPA, any goods or materials originating from Xinjiang are presumed to be made with forced labor unless the importer can prove otherwise with clear and convincing evidence. That presumption applies regardless of whether the importer is aware of the connection — which is why supply chain mapping across every production tier is now a compliance necessity rather than a risk management exercise.

The industries most exposed are those with significant sourcing from China: apparel, textiles, cotton products, electronics, solar components, and agricultural goods such as tomatoes. For apparel importers specifically, the documentation requirement extends from cotton fields through processing, textile production, and manufacturing — every step of the way.

Importers who cannot provide sufficient evidence risk having their shipments detained, denied entry, returned to the country of origin, or destroyed under US Customs supervision.

China’s Response

China’s Regulations 834 and 835 were introduced in direct response to what Beijing views as extraterritorial overreach — the application of US law onto Chinese domestic industry. These regulations create an opaque legal shield around Chinese supply chains, making it difficult or impossible for foreign parties to conduct the kind of investigation that US compliance now requires.

China has also taken additional countermeasures, placing 10 US companies on an export control list and barring Chinese government agencies from purchasing products from 46 other US companies. The regulatory environment is becoming increasingly adversarial, and importers are caught squarely in the middle.

The Practical Reality for Importers

The conflict creates a situation with no clean solution. Companies that source from China — particularly from regions with known ties to Xinjiang supply chains — face a binary outcome: either they can document their supply chain sufficiently to satisfy US Customs, or they cannot. If they cannot, their goods will not enter the United States.

For many businesses, this is accelerating decisions around supplier diversification, nearshoring, and regional sourcing. Reducing dependence on Chinese supply chains for high-risk product categories is no longer just a resilience strategy — it is increasingly a compliance strategy as well.

What Companies Should Be Doing Now

Regardless of where your supply chain currently sits, there are steps every importer should be taking:

Invest in supply chain mapping and traceability tools that can document supplier networks across multiple tiers. Conduct regular compliance audits and strengthen supplier due diligence, particularly for goods with any potential connection to Xinjiang. Work with a licensed customs broker who understands UFLPA requirements and can help ensure your documentation meets the standard required by US Customs.

The regulatory environment between the US and China is not improving in the near term. Supply chain mapping is no longer optional — and for many importers, the time to act is now, before a shipment is detained rather than after.

Future Forwarding is closely monitoring developments in forced labor compliance and trade policy. If you have questions about how these regulations affect your imports, reach out to your Future Forwarding representative today.

ATA Carnets Have Gone Digital:

What the 2026 Changes Mean for Your Business

If your business regularly sends goods overseas for exhibitions, trade shows, product demonstrations or temporary projects, you’ll probably already be familiar with ATA Carnets. For years, they have simplified temporary exports by removing the need to pay import duties and taxes in every country you visit.

Now, the system has undergone its biggest change in decades.

From 1 June 2026, the UK joined the first phase of the international eATA Carnet programme. This introduced digital processing for ATA Carnets alongside the European Union, Norway and Switzerland. While the purpose of an ATA Carnet remains exactly the same, the way it is presented and processed at customs has changed significantly.

If you’re planning temporary exports, here’s what you need to know.

What is an ATA Carnet?

An ATA Carnet is an international customs document that allows goods to be temporarily exported and imported without paying customs duties or import VAT. However, this applies only if the goods are returned within the carnet’s validity period.

It acts as a passport for goods. As a result, it makes temporary international movements much simpler than completing full customs declarations every time a shipment crosses a border.

ATA Carnets are commonly used for:

  • Exhibition and trade show equipment
  • Professional equipment used overseas
  • Commercial samples
  • Demonstration products
  • Sporting equipment
  • Musical instruments
  • Film and television production equipment

Rather than paying import charges in every country you visit, the carnet guarantees those duties while the goods remain temporarily abroad. Once the goods return home, the carnet is discharged. Therefore, no import duties become payable, provided all customs procedures have been correctly completed.

For businesses attending multiple exhibitions or visiting several countries with the same equipment, an ATA Carnet can save both time and considerable expense.

Who typically needs an ATA Carnet?

Many industries rely on ATA Carnets without realising just how often they use them.

Typical users include:

What’s changed?

Until recently, ATA Carnets were entirely paper-based.

Every movement required customs officers to stamp the carnet booklet and remove the relevant voucher as goods entered or left each country. Additionally, losing the booklet or missing a customs endorsement could lead to lengthy investigations. In some cases, this resulted in unexpected customs claims.

That process is now changing.

From 1 June 2026, the UK became one of the first countries to adopt the new eATA Carnet system. Together with the European Union, Norway and Switzerland, customs authorities can now process carnet movements digitally.

Instead of relying solely on a paper booklet, carnet holders use the official ATA Carnet app to present a secure QR code at customs. Therefore, customs officers scan the code, allowing each import, export and re-export movement to be recorded electronically.

This creates a digital record of the journey while reducing paperwork and improving visibility throughout the temporary export process.

The International Chamber of Commerce intends to extend the digital system worldwide over the coming years. Furthermore, global implementation is expected by 2028.

What does this mean for your business?

The good news is that the purpose of an ATA Carnet hasn’t changed.

If your goods qualify today, they’ll continue to qualify under the new digital system. The temporary admission rules, eligibility requirements and responsibility for returning the goods all remain exactly the same.

The difference is how those movements are managed.

Businesses should now expect to:

  • Use the official ATA Carnet app when travelling between participating countries
  • Present a QR code to customs instead of relying solely on paper documentation
  • Ensure the person accompanying the goods understands the digital customs process
  • Confirm that every customs crossing is correctly recorded electronically

As more countries adopt the eATA system, digital processing will gradually become the standard method for temporary exports.

How does this affect freight forwarders?

While the process becomes more digital, planning remains just as important.

As experienced freight forwarders, we now help clients prepare for both the customs requirements and the digital procedures before goods leave the UK.

This includes confirming whether the destination country supports eATA processing and ensuring the correct documentation has been arranged. It also involves advising who should present the carnet at customs. In addition, we help businesses understand how the digital process works before they travel.

For companies attending overseas exhibitions or sending valuable equipment abroad, a little preparation can prevent costly delays at the border.

What should you do now?

If your business uses ATA Carnets, there is no need to worry, but there are a few practical steps worth taking.

  • Ensure the employee or representative travelling with the goods is familiar with the ATA Carnet app. In addition, they should understand what will happen at customs.
  • Review any upcoming temporary exports and check whether your destination is participating in the eATA programme.

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.

HMRC TRE Reporting

What Importers Need to Know About the New Customs Data System

HMRC has introduced a new reporting platform called Trade Reporting & Extracting (TRE), replacing the older Management Support System (MSS). For many importers and exporters, this is a quiet but important shift in how customs data is accessed, reviewed, and used for compliance checks.

While TRE is still being developed and refined, it is already becoming a key tool for businesses that want better visibility over their customs declarations.

So what exactly is it, and why should it be part of your monthly checks?

What is HMRC TRE?

Trade Reporting & Extracting (TRE) is a free HMRC service that allows traders to access customs declaration data submitted in their name.

This includes import and export declarations made through both CHIEF and CDS systems. In practical terms, it gives businesses a structured way to view what has been declared to HMRC by freight forwarders, customs brokers, or internal teams.

Previously, this information was accessed through the Management Support System (MSS), which was a paid service and often required separate setup and access arrangements. TRE replaces that system and brings reporting into a more standardised digital format.

Reports are typically available to download in spreadsheet format, which makes it easier for finance teams, compliance managers, and logistics departments to review the data.

Why HMRC introduced TRE

The move to TRE is part of HMRC’s wider shift towards digital customs processes under the CDS framework.

The goal is simple: improve transparency and give businesses better access to their own trade data.

Instead of relying solely on agents or monthly summaries, importers can now directly review the declarations that affect:

  • Duty payments
  • Import VAT
  • Commodity classification
  • Customs valuation
  • Origin and preference claims

This matters because responsibility for accuracy sits with the importer, even when declarations are submitted by a third party.

What information TRE reports contain

TRE reports can include a wide range of customs data, such as:

  • Import and export entries
  • Commodity codes used on declarations
  • Customs values and currencies
  • Duty and VAT calculations
  • Country of origin and preferential claims
  • Declaration references linked to shipments

This level of detail allows businesses to compare what was expected against what was actually submitted, and that comparison is where most issues are found.

Why monthly TRE checks matter

Even though the system is new and still being improved, monthly checks should already be part of standard due diligence.

Here’s why it matters in real terms.

1. Catch classification errors early

A wrong commodity code can affect duty rates, VAT, and compliance exposure. TRE helps identify these issues before they build up over time.

2. Verify duty and VAT accuracy

Small errors repeated across multiple entries can quickly become costly. Regular reviews help ensure financial accuracy.

3. Monitor broker activity

Many importers use multiple agents. TRE gives a single view of all declarations, so nothing slips through the cracks.

4. Support audit readiness

If HMRC reviews your records, having a clear monthly reconciliation of declarations strengthens your position.

5. Improve internal controls

Finance and logistics teams can align declared values with purchase records and landed cost models.

What businesses should do

Importers should treat TRE as part of their standard monthly compliance routine.

A simple process works best:

  • Download monthly TRE reports
  • Match declarations to invoices and shipping records
  • Check commodity codes and values
  • Review duty and VAT outcomes
  • Flag inconsistencies early

This does not need to be complex, but it does need to be consistent.


TRE is more than just a reporting upgrade. It represents a shift towards full transparency in UK customs data.

For importers, this means greater control, but also greater responsibility.

Businesses that build TRE checks into their monthly process will be better positioned to avoid duty errors, reduce compliance risk, and maintain cleaner customs records.

As the system evolves, those who adapt early will have a clear advantage in both operational control and HMRC readiness.

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.

SEA-AIR SERVICE: Alternative Routing: China & Vietnam to UK via Los Angeles

A practical alternative route for time-sensitive cargo moving from Asia to the UK

Moving freight from China and Vietnam to the UK has become more challenging for many importers. Delays, shifting schedules and pressure on traditional routing can make it harder to plan with confidence.

For time-sensitive cargo, that creates a real problem.

If your goods are too urgent for standard ocean freight, but full air freight feels too expensive, Future Forwarding’s Sea-Air freight service via Los Angeles gives you another option. It is designed to sit neatly between ocean and air freight, offering a more balanced route for cost, speed and reliability.

This alternative routing moves cargo from China and Vietnam into Los Angeles by ocean freight. From Los Angeles, shipments are then moved by air into the UK.

It is not about overcomplicating the journey. It is about using a route that gives businesses more control when standard options are under pressure.

What is the China and Vietnam to UK Sea-Air service?

This Sea-Air service combines two modes of transport within one managed freight solution.

The first leg moves by ocean freight from Asia to Los Angeles. Once the cargo arrives in Los Angeles, it is transferred to air freight for the final leg into the UK.

This gives importers a flexible alternative to two common choices:

  • Standard sea freight, which may be too slow for urgent stock
  • Full air freight, which may be too costly for the whole journey

Sea-Air freight gives you a middle ground. You keep some of the cost benefits of ocean freight, while using air freight where it matters most: the final leg into the UK.

Why route Sea-Air freight via Los Angeles?

The main benefit of routing via Los Angeles is stability.

When routes through traditional hubs become less predictable, a different handover point can help reduce exposure to delay. Los Angeles provides an alternative route into the UK, helping businesses keep cargo moving without relying on one route or one region.

For many importers, this matters because predictability is just as important as speed. A shipment does not always need the fastest possible route. It often needs a route that can be planned, priced and managed properly.

That is where Sea-Air freight via Los Angeles works well.

It gives you:

  • A practical alternative to disrupted routes
  • Faster transit than standard ocean freight
  • Lower cost than full air freight
  • A clear route from Asia to the UK
  • Greater flexibility for time-sensitive cargo
  • A managed freight solution from origin to destination

Who is this service suitable for?

Sea-Air freight from China and Vietnam to the UK is best suited to shipments where timing matters, but where full air freight is not commercially viable.

It can be a useful option for businesses importing:

  • Retail stock
  • Consumer goods
  • Fashion and seasonal products
  • Electronics
  • Components and spare parts
  • Promotional stock
  • Ecommerce inventory
  • Goods affected by production or shipping delays

It is also useful when a shipment has missed its original window and needs to recover time without moving everything by air.

In simple terms, if your goods cannot wait for standard ocean freight, but you need to protect margin, Sea-Air freight is worth considering.

China to UK Sea-Air freight

For businesses importing from China to the UK, Sea-Air freight can help bridge the gap between ocean and air freight.

Many China-to-UK supply chains are built around planned ocean freight movements. That works well when there is enough time in the schedule. But when production delays, port congestion, demand spikes or customer deadlines create pressure, importers may need a faster option.

Routing via Los Angeles gives businesses another way to move cargo into the UK without automatically jumping to full air freight.

Future Forwarding can review the shipment profile, cargo details, timescale and budget, then advise whether this Sea-Air option is suitable.

Vietnam to UK Sea-Air freight

Vietnam continues to be an important sourcing market for UK importers, particularly for retail, consumer goods, fashion, furniture and manufacturing supply chains.

When Vietnam-to-UK ocean freight is too slow, Sea-Air freight via Los Angeles can provide a more flexible route. It allows importers to improve transit time while avoiding the full cost of air freight from origin to destination.

This can be particularly useful for seasonal goods, replenishment stock and products linked to launch dates or customer commitments.

How the Sea-Air freight process works

Future Forwarding manages the Sea-Air movement as one coordinated freight solution.

A typical process may include:

  1. Cargo collection or receipt at origin
  2. Ocean freight movement from China or Vietnam to Los Angeles
  3. Arrival and handling in Los Angeles
  4. Transfer from ocean freight to air freight
  5. Air freight movement from Los Angeles to the UK
  6. UK customs coordination
  7. Final delivery or onward distribution

The key point is that the shipment is planned as one route, not as disconnected transport legs.

That joined-up approach helps reduce confusion, improve communication and keep the cargo moving.

Why choose Sea-Air instead of full air freight?

Full air freight is the right choice when speed is the only priority. But for many importers, cost still matters.

Sea-Air freight gives businesses a more balanced option. By using ocean freight for the first part of the journey and air freight for the final leg, it can help reduce costs while still improving transit times compared with standard sea freight.

This makes it especially useful when:

  • The shipment is urgent, but not critical
  • The cost of full air freight is too high
  • Stock needs to arrive sooner than ocean freight allows
  • There is pressure to protect margin
  • You want to avoid a last-minute emergency air freight upgrade

Planning a Sea-Air movement early can often be more cost-effective than reacting late when delays have already caused a problem.

Why choose Sea-Air instead of standard ocean freight?

Ocean freight remains the most cost-effective option for many international shipments. But it only works when the delivery schedule allows enough time.

When stock is needed sooner, standard sea freight may not be practical.

Sea-Air freight helps reduce the risk of missed deadlines by shortening the overall transit time. It gives importers a faster route into the UK while still avoiding the full cost of moving the entire shipment by air.

For businesses managing tight supply chains, that balance can make a real difference.

A flexible route for changing market conditions

Freight routes are rarely fixed forever. Market conditions change. Capacity changes. Schedules change. Disruption in one region can make another route more attractive.

That is why flexibility matters.

The China and Vietnam to UK Sea-Air service via Los Angeles gives importers another option while certain lanes remain unsettled. It allows businesses to avoid relying on a single route and gives supply chains more room to adapt.

This is not a one-size-fits-all service. It will not be the right solution for every shipment. But for the right cargo, timing and budget, it can offer a very useful alternative.

Talk to Future Forwarding about Sea-Air freight

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.

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