Implementation of Section 232 Tariffs on Steel and Aluminum Derivative Articles

As of March 11, 2025, the U.S. government has enforced Section 232 tariffs on certain derivative articles of steel and aluminum, expanding the scope of duties beyond primary metal imports. These measures aim to protect national security interests by mitigating circumvention risks associated with modified steel and aluminum products.

Understanding Derivative Articles and Their Impact

Derivative articles refer to goods that incorporate steel or aluminum as a primary component and have undergone limited processing or modification to evade direct tariff application. Common examples include:

Steel nails, tacks, and fasteners
Aluminum stranded wire, cables, and conductors
Certain types of tubing, piping, and mechanical components

The extension of tariffs to these products ensures that manufacturers and importers cannot sidestep Section 232 duties by making minor modifications to raw materials.

Compliance Challenges for Importers

The expansion of Section 232 tariffs presents challenges for importers, particularly in properly declaring derivative value for customs entry. Many derivative articles involve multi-component goods, where steel and aluminum may account for only a portion of the overall product value.

Customs valuation for these products must align with reasonable allocation of dutiable value while ensuring compliance with CBP regulations. Failure to declare accurate values may result in penalties, audits, or import delays.

Reconciliation Entry as a Temporary Reporting Mechanism

To address the complexity of derivative value reporting, importers may consider using reconciliation entry as a temporary solution. The CBP Reconciliation Program allows importers to file estimated values at the time of entry and later submit a final value adjustment. This approach provides:

Flexibility in determining the steel/aluminum proportion of a derivative article
Compliance assurance while adjusting declared values post-import
Reduced risk of penalties due to inadvertent undervaluation

Steps for Importers to Implement Reconciliation

Flag Entries for Reconciliation – When filing an entry, importers should flag it for value reconciliation in ACE (Automated Commercial Environment).
Estimate Dutiable Value – Report a preliminary steel/aluminum content value, subject to later verification.
Monitor Adjustments – Gather supporting data post-import to determine accurate derivative value.
File the Reconciliation Entry – Submit the final reconciled value within the allowed CBP timeframe to adjust Section 232 tariff obligations accordingly.

Looking Ahead

With the Section 232 tariff enforcement on derivative articles now in effect, importers should ensure proper classification of derivative articles, assess their supply chains, and utilize reconciliation entry as a strategic compliance tool.

Future regulatory developments may further refine the valuation process, but in the interim, proactive planning will help mitigate risk and ensure uninterrupted trade operations.

For more guidance on Section 232 tariff compliance and reconciliation strategies, reach out to Future Forwarding today.

Shipping Alliances Reshape Trade Routes: Delays, Blank Sailings, and Vessel Diversions Expected to Continue

March 2025

The global shipping industry is undergoing a significant transformation as major alliances restructure their operations, leading to widespread disruptions on key trade routes. This restructuring is causing delays, blank sailings, and vessel diversions, leaving both shippers and consumers grappling with uncertainty.

The most notable shift has been the dissolution of the long-standing 2M alliance between MSC Mediterranean Shipping Company (MSC) and A.P. Moller-Maersk, which is set to end in 2025. In its place, new alliances such as the Gemini Cooperation, formed between Maersk and Hapag-Lloyd, are taking center stage. While these changes are intended to streamline operations, they have resulted in a slew of scheduling adjustments, causing confusion and congestion.

Scheduling Chaos and Port Congestion

As shipping alliances realign their schedules, shippers have reported discrepancies in arrival times, leading to confusion across the industry. Some carriers, even within the same alliance, are listing different transit times for the same vessel, contributing to widespread scheduling confusion. Ports, especially in Asia, are experiencing severe congestion, with ships waiting up to three days for a berth, exacerbating the backlog of containers.

The result? Delayed shipments, longer waiting times at major ports like Shanghai, and disrupted schedules that have left many vessels stranded at terminals.

Blank Sailings and Diversions

Another side effect of the alliance shifts has been the rise in blank sailings and diversions. Blank sailings, where a scheduled voyage is canceled due to insufficient cargo or other operational reasons, have increased across the Asia-Europe route, further straining supply chains.

The geopolitical instability in the Red Sea has also prompted several shipping companies to divert vessels around the Cape of Good Hope instead of passing through the Suez Canal, resulting in longer transit times and increased freight rates. Attacks in the region, particularly by Iran-backed Houthi rebels, have heightened concerns over vessel safety, prompting carriers to adopt this detour as a precautionary measure.

Declining Service Reliability

As a result of these scheduling changes, the shipping industry has seen a significant decline in service reliability. On-time performance, which was once a benchmark for efficiency, has plummeted for many carriers. Some are reporting on-time rates as low as 55%, a far cry from the 90% reliability target that many had been able to achieve in the past.

To combat this, the Gemini Cooperation aims to improve on-time reliability by reducing port calls and utilizing larger vessels on key trade routes. The new alliance is targeting a return to 90% on-time performance by optimizing operations and adapting to current market conditions.

The Road Ahead

With these ongoing disruptions, stakeholders across the shipping industry are bracing for continued challenges. While the restructuring of alliances is seen as a necessary step to adapt to evolving market demands, businesses and consumers must prepare for fluctuating schedules and unpredictable freight rates.

As shipping companies continue to adapt to these changes, flexibility and vigilance will be key for those relying on global trade networks. With ongoing geopolitical uncertainties and shifting market strategies, the next few months will likely be marked by further disruptions, and companies must remain agile to navigate the changing landscape.

USTR Seeks Public Input on Trade Measures Against China’s Maritime Dominance

The Office of the United States Trade Representative (USTR) is requesting public comments on proposed trade actions in response to China’s growing control over the global maritime, logistics, and shipbuilding industries. Following a Section 301 investigation, USTR determined that China’s policies have disadvantaged U.S. businesses and workers, prompting potential countermeasures.

Background of the Investigation

The investigation began in April 2024 after several U.S. labor unions filed a petition citing China’s long-standing efforts to dominate the shipbuilding and logistics sectors. Over the past three decades, China has significantly expanded its control, increasing its global shipbuilding market share from under 5% in 1999 to over 50% in 2023. Additionally, China now produces 95% of the world’s shipping containers and 86% of intermodal chassis, strengthening its influence over global trade logistics.

According to the USTR’s findings, China’s industrial policies have created unfair competitive conditions by displacing foreign businesses, limiting commercial opportunities, and posing economic security risks. As a result, USTR has determined that action is necessary under Section 301 of the Trade Act of 1974.

Proposed Trade Actions

To address China’s competitive advantage, the USTR is considering several measures:

Service Fees on Chinese Shipping Operators – A fee of up to $1,000,000 per vessel entry into U.S. ports for operators with Chinese-built vessels.
Tariffs on Operators Using Chinese-Built Ships – Additional fees for companies that operate or have pending orders for Chinese-manufactured vessels.
Incentives for U.S.-Built Vessels – A system of fee reimbursements for operators using U.S.-manufactured ships.
Shipping Restrictions on U.S. Exports – A phased-in requirement that a portion of U.S. goods be transported on U.S.-flagged and U.S.-built vessels.
Security Measures Against Chinese Logistics Platforms – Possible restrictions on the use of LOGINK, a Chinese-developed logistics data platform, due to security concerns.

Public Comment Period and Hearing Details

The USTR is encouraging stakeholders to provide feedback on these proposed actions. The key deadlines are as follows:

February 21, 2025 – Public comment period opens.
March 10, 2025 – Deadline to request participation in the public hearing.
March 24, 2025 – Deadline to submit written comments.
March 24, 2025 – Public hearing at the U.S. International Trade Commission in Washington, D.C.
Seven days after the hearing – Deadline for post-hearing rebuttal comments.

Comments and requests to participate in the hearing can be submitted via USTR’s online portal at https://comments.ustr.gov/s/ using docket numbers USTR–2025–0002 (for written comments) and USTR–2025–0003(for hearing requests).

Adapting to the New US Aluminum and Steel Tariffs

The logistics and trade sectors are in constant flux, and the latest escalation in tariffs exemplifies this dynamic landscape. President Trump’s recent decision to elevate aluminum and steel tariffs from 10% to 25% on all imports, without exceptions for any country, necessitates that businesses remain vigilant and adaptable. This significant policy change—removing exemptions previously granted to key partners such as Canada, Mexico, and the European Union—requires strategic planning from importers and supply chain managers.

Understanding the New Tariffs

The hike to a 25% tariff on aluminum imports represents a substantial shift in U.S. trade policy. Earlier, certain nations had secured exemptions or quota-based allowances, but these have now been rescinded. Additionally, new requirements concerning the processing origins of North American aluminum aim to prevent tariff circumvention by countries like China and Russia.

The U.S. government justifies these measures under Section 232 of the Trade Expansion Act, citing national security concerns and the need to bolster domestic aluminum production. However, the repercussions for the global supply chain are expected to be considerable.

Implications for Importers and Supply Chains

With the removal of exclusions, importers who previously benefited from duty-free aluminum must now account for increased costs and heightened compliance requirements. Manufacturers in industries such as automotive, aerospace, and construction, which rely heavily on aluminum, may face cost fluctuations as suppliers adjust their pricing structures.

Beyond financial impacts, logistics professionals should anticipate potential delays, challenges in customs processing, and the need to reassess sourcing strategies. For instance, foreign producers that had shifted operations to Mexico and Canada in recent years may now find their supply chains disrupted by the new restrictions, compelling importers to seek alternative solutions.

Strategies for Businesses

Evaluate Supplier Relationships: If the new tariffs affect your aluminum sourcing, it’s crucial to review existing contracts and explore alternative suppliers.
Incorporate Tariff Costs: Collaborate with financial and logistics partners to integrate the new tariff rates into your budgeting and pricing models.
Stay Abreast of Compliance Requirements: The updated processing origin requirements for North American aluminum will lead to more stringent customs inspections; ensuring thorough and accurate documentation is essential.
Partner with Experienced Logistics Providers: In times of regulatory change, having a knowledgeable freight forwarder is vital for navigating customs procedures, managing duties, and maintaining efficient cargo movement.

Future Forwarding: Guiding Your Cargo Through Change

At Future Forwarding, we recognize that change brings both challenges and opportunities. Our commitment to understanding each client’s unique needs allows us to offer tailored solutions that keep your supply chain resilient amidst evolving regulations.

Our comprehensive services include freight forwarding, customs brokerage, warehousing, and compliance consulting, all designed to ensure your cargo moves seamlessly, regardless of policy shifts.

If you have questions about how the new aluminum tariffs may affect your supply chain, contact Future Forwarding today. We’re here to help you plan proactively, mitigate disruptions, and keep your operations running smoothly.

Know Your Cargo: Strengthening Compliance in Maritime and Transportation Logistics

The complexities of global supply chains present both opportunities and risks for entities involved in the movement of goods. The Quint-Seal Compliance Note—issued by the Departments of Commerce, Treasury, Justice, State, and Homeland Security—emphasizes the importance of powerful compliance measures to prevent sanctions and export control violations. Companies operating within maritime and broader transportation industries must proactively mitigate the risk of facilitating illicit activities.

Understanding Sanctions and Compliance Risks

The global trade network involves multiple stakeholders, including vessel owners, exporters, brokers, freight forwarders, insurers, and financial institutions. However, this intricate ecosystem is vulnerable to exploitation by malign actors seeking to bypass U.S. sanctions. These actors employ various deceptive practices, including:

Manipulating vessel location and identification data (e.g., disabling or falsifying Automatic Identification System (AIS) signals).
Falsifying cargo documentation to obscure a shipment’s true origin or destination.
Engaging in ship-to-ship transfers to disguise illicit cargo movement.
Using abnormal shipping routes and frequent vessel re-registrations (“flag hopping”) to evade scrutiny.
Operating through opaque ownership structures to conceal beneficial ownership.

Failure to detect and prevent these activities can expose companies to severe legal, financial, and reputational consequences.

Best Practices for Strengthening Compliance

To ensure adherence to U.S. export controls and sanctions regulations, industry participants should implement a risk-based compliance framework, including:

Developing Comprehensive Compliance Programs
- Establish written policies and procedures aligned with U.S. government guidance.
- Communicate compliance expectations to all business partners.
Enhancing Location and Shipment Monitoring
- Conduct due diligence on vessel movement histories to detect irregularities.
- Investigate gaps in AIS data and implement contractual clauses prohibiting illicit activities.
Strengthening Due Diligence on Counterparties
- Conduct Know Your Customer (KYC) screenings and vet counterparties using government lists like the U.S. Consolidated Screening List.
- Verify the accuracy of bills of lading, licenses, and other shipping documents.
Improving Supply Chain Oversight
- Monitor cargo flow to prevent unauthorized diversions.
- Use open-source intelligence and commercial satellite imagery to verify reported shipment routes.
Industry-Wide Information Sharing
- Participate in industry forums to exchange risk intelligence and compliance best practices.
- Report suspicious activities to relevant U.S. authorities.

Enforcement Actions and Legal Consequences

The Department of Justice (DOJ) and other enforcement agencies have aggressively pursued civil and criminal actions against companies and individuals attempting to evade U.S. sanctions and export controls. Recent cases have targeted networks tied to sanctioned entities in Iran, Russia, North Korea, and China, demonstrating that non-compliance can result in asset seizures, financial penalties, and criminal prosecution.

By institutionalizing compliance measures and actively monitoring cargo movements, companies can safeguard their operations, ensure regulatory compliance, and contribute to a more secure global trade environment.

Want to know more? Reach out to us today.

Adapting to the UK SAF Mandate: Insights for the Logistics Industry

The UK’s newly enforced sustainable aviation fuel (SAF) mandate is reshaping air cargo operations and influencing logistics strategies across the board. As of January 1, airlines operating in the UK must blend SAF with traditional jet fuel, driving efforts to reduce carbon emissions and meet environmental targets.

This development presents both challenges and opportunities for logistics providers, shippers, and freight forwarders navigating an increasingly sustainability-focused market.

Key Implications for the Logistics Industry

Cost Adjustments:
SAF production costs remain higher than those of conventional fuels. As airlines pass these expenses along, shippers and logistics providers should anticipate increased surcharges for air freight services. Strategic cost management will become essential to mitigate these impacts.
Capacity and Scheduling Shifts:
To optimize SAF use, airlines may adjust routes and schedules, impacting cargo capacity and delivery timelines. Logistics providers must remain agile, leveraging technology and strong partnerships to adapt swiftly.
Sustainability Reporting:
With rising pressure for companies to reduce their environmental footprint, the logistics industry will need to prioritize transparent emissions reporting. Companies proactively offering carbon reporting and offsetting options can differentiate themselves in this evolving market.
Regulatory Compliance:
Logistics providers operating internationally must keep pace with evolving environmental regulations in multiple jurisdictions, ensuring seamless operations and compliance with all new mandates.

Preparing for a Sustainable Future

The SAF mandate signals a significant shift in the air cargo landscape. Logistics leaders can take proactive steps to adapt by:

Building Resilient Partnerships: Collaborate closely with airline partners to understand SAF strategies and secure reliable cargo capacity.
Investing in Technology: Use advanced data analytics to optimize routing, manage fuel efficiency, and track emissions.
Enhancing Client Communication: Educate customers on the environmental benefits of SAF and help them meet sustainability goals through comprehensive service offerings.
Exploring Green Initiatives: Complement air freight strategies with sustainable ground operations and warehousing practices to bolster overall efficiency.

By embracing sustainability as a competitive advantage, the logistics industry can not only adapt to regulatory changes but lead the way in environmental stewardship. Have questions? Reach out to your representative today.

A New Era for U.S. Shipping: The SHIPS for America Act

The maritime industry is poised for a seismic shift with the introduction of the SHIPS for America Act, a bipartisan bill designed to revitalize U.S. shipbuilding and strengthen the country’s maritime security. This legislation aims to mandate that at least 10% of seagoing imports from China to the United States be transported on American-built, U.S.-flagged ships staffed by American crews. This ambitious requirement is set to take effect in 2029 and marks a bold step toward reshaping the global shipping landscape.

A Maritime Nation Reasserting Leadership

The SHIPS for America Act underscores the critical role of the maritime industry in national security and economic stability. “We’ve always been a maritime nation, but the truth is we’ve lost ground to China, who now dominates international shipping and can build merchant and military ships much more quickly than we can,” said Senator Kelly, a Navy veteran and the first U.S. Merchant Marine Academy graduate to serve in Congress.

By focusing on shipbuilding, workforce development, and shipping infrastructure, the legislation aims to:

Strengthen U.S. supply chains.
Reduce dependency on foreign vessels.
Create high-paying maritime jobs for Americans.
Support the Navy and Coast Guard’s shipbuilding requirements.

The Current Landscape: Challenges and Opportunities

China accounts for nearly a third of global shipbuilding, leaving the U.S. far behind in terms of maritime capacity. Presently, fewer than 200 oceangoing merchant vessels are U.S.-flagged, with operators such as Matson, CMA CGM’s APL subsidiary, and Maersk Line Ltd. leading the charge. The SHIPS for America Act seeks to reverse this trend by creating a strong commercial fleet of 250 U.S.-flagged ships within the next decade.

Key Provisions of the Legislation

Increased Shipping Mandates: The bill requires all U.S. government cargo to move on U.S.-flagged vessels, doubling the current mandate from 50% to 100%.
Berthing Preferences: U.S.-flagged ships would receive priority access at congested American ports, offering a competitive edge over foreign carriers.
Maritime Security and Infrastructure: A newly established Maritime Security Trust Fund would channel industry-paid duties and fees into security programs and infrastructure projects essential for seagoing commerce.
Streamlined Regulations: Efforts to enhance the international competitiveness of U.S.-flagged vessels by simplifying regulatory frameworks.
Workforce and Shipyard Incentives: The bill includes tax credits for domestic shipyards and funding to bolster the maritime workforce, ensuring a steady pipeline of skilled professionals to meet growing demands.
Creation of a Maritime Security Czar: A dedicated official would oversee the implementation of a comprehensive U.S. maritime strategy.

Implications for Global Shipping

The SHIPS for America Act will have far-reaching implications for global logistics and trade. For Chinese container carriers and alliances operating under vessel-sharing agreements (VSAs), the 10% requirement introduces significant operational and cost complexities. Moreover, the legislation’s preferential treatment for U.S.-flagged vessels at American ports may disrupt established shipping routes and alliances.

For forwarders and logistics providers, the operational impact remains uncertain, but compliance with the new rules will likely necessitate strategic adjustments. The proposed regulations aim to reduce America’s reliance on foreign shipping and prioritize national security, even if they lead to short-term challenges for the industry.

A Vision for the Future

If enacted, the SHIPS for America Act promises to usher in a new era of maritime innovation and self-reliance. By fostering domestic shipbuilding and workforce development, the U.S. can reclaim its position as a dominant player in the global shipping arena. This legislation is not just about economics; it’s about reaffirming America’s maritime identity and ensuring the resilience of its supply chains in an increasingly competitive world.

The maritime industry, lawmakers, and stakeholders will now watch closely as the bill progresses through Congress. Should it pass, the SHIPS for America Act could serve as a blueprint for how nations can leverage maritime policy to bolster national security and economic prosperity.

Safety & Security Waiver for Imports from EU: Effective January 31, 2025, companies will be required to submit Entry Summary Declarations for all goods entering GB from the EU

On January 31, 2025, the United Kingdom will remove the Safety and Security (S&S) waiver for imports coming from the European Union (EU). This change means that businesses and carriers importing goods into Great Britain (GB) from the EU will be required to submit Safety and Security declarations, commonly referred to as Entry Summary Declarations (ENS).

Key Points to Understand

What is the S&S Waiver?:
- The Safety and Security waiver allowed certain goods entering the UK from the EU to bypass the requirement for Safety and Security declarations. This waiver was part of a transitional arrangement following Brexit, designed to facilitate trade and minimize disruptions during the initial phase of the UK’s exit from the EU.
What Changes with the Removal of the Waiver?:
- Once the waiver is removed, all goods moving into GB from the EU will require an ENS. This includes submitting specific details about the shipment to customs authorities. The ENS is designed to enhance border security by allowing customs to assess potential risks associated with incoming shipments before they arrive in the UK.
What is an Entry Summary Declaration (ENS)?:
- The ENS includes information about the goods being imported, such as the nature of the goods, the consignor and consignee details, and the means of transport. It is a safety and security measure that helps customs authorities identify and mitigate risks associated with incoming cargo.
Compliance Requirements:
- Importers and carriers will need to ensure compliance with the new regulations, which may involve updating their logistics and supply chain processes. This includes providing timely and accurate information in the ENS to avoid potential delays, fines, or penalties.
Impact on Trade:
- The removal of the S&S waiver is significant for businesses engaged in trade between the EU and the UK. It may lead to increased administrative burdens and operational changes, as companies will now need to allocate resources to handle the ENS submissions.
Timeline for Implementation:
- As businesses prepare for the new requirements, they have a window until January 31, 2025, to adapt their processes. This preparation period allows companies to set up necessary systems, train staff, and ensure they understand the new compliance landscape.

The removal of the Safety and Security waiver for EU imports represents a key change in the regulatory landscape for businesses trading with the UK. Effective January 31, 2025, companies will be required to submit Entry Summary Declarations for all goods entering GB from the EU. Organizations should begin taking proactive steps to prepare for this change, ensuring that they understand the requirements and have the necessary systems in place to comply with the updated rules. This transition will be critical for maintaining a smooth and efficient flow of goods across the border while ensuring safety and security in the import process.

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Trump Backs Dockworkers in Automation Dispute as Port Contract Deadline Looms

The ongoing contract negotiations between the International Longshoremen’s Association (ILA) and the United States Maritime Alliance (USMX) have taken a new turn with President-elect Donald Trump’s recent involvement. On December 12, 2024, Trump met with ILA leadership, including President Harold Daggett, and expressed strong support for the union’s stance against port automation.

In a post on his Truth Social platform, Trump stated, “I’ve studied automation, and know just about everything there is to know about it. The amount of money saved is nowhere near the distress, hurt, and harm it causes for American Workers, in this case, our Longshoremen.” This statement aligns closely with the ILA’s position, which has been a major sticking point in negotiations with USMX.

The meeting comes at a critical time, as the current contract extension is set to expire on January 15, 2025, just five days before Trump’s second inauguration. This deadline was established after a three-day strike in October 2024, which was partially resolved with the help of the Biden administration.

Negotiations At Impasse Over Automation

In early October after a brief walkout, ILA members agreed to a 62% pay increase over the six-year agreement’s lifetime, but left the automation issue unsettled.

In November, the employers and ILA scheduled four days of contract talks. Those talks abruptly broke down after only two days over the issue of automation. The ILA reported that negotiations ended when management introduced their intent to implement semi-automation, which the union views as a direct contradiction to earlier assurances. The union fears that even the slightest concession to semi-automation is a stepping stone to full automation, potentially leading to significant job losses..

USMX, on the other hand, argues that modernization is essential for improving worker safety, boosting port efficiency, and increasing capacity. They claim that greater port capacity would lead to more goods being moved, ultimately resulting in higher compensation for ILA members.

East Coast and Gulf TEU Figures

The stakes are high, given the significant volume of cargo handled by east and gulf coast ports. In 2023, the world’s top 20 ports, including several on the U.S. east coast, handled a cumulative traffic of 387.5 million TEUs, up 1.24% from the previous year. Specifically, during the first seven months of 2024, those ports handled 50.8% of total imports measured in TEU through the country’s top 10 ports.

Any interruption in January ahead of the two-fold rush of cargo leaving Asia both in advance of Lunar New Year closures and to potentially beat any additional tariffs the administration might seek to impose would likely both lead to congestion and higher rates for vessels bound for west coast ports as well as delays in unloading cargo on services that are only calling on the eastern seaboard or gulf.

What’s Next With Less Than A Month Remaining?

USMX has responded to Trump’s comments with a statement emphasizing their shared goal of protecting American jobs while also stressing the need for modernization to maintain competitiveness.

Trump’s support for the ILA could influence the negotiations, potentially emboldening the union in its stance against automation. However, it remains to be seen how this will play out in practical terms, especially given the complex economic and technological factors at play.

Future Forwarding continues to monitor these negotiations closely. With Savannah just up the road from our U.S. headquarters in Atlanta, Georgia, we are attuned to the situation and are working with individual customers on contingency plans that include alternate ports of call, transshipment of urgent cargo and, if necessary, air freight options. If you have any questions, contact your Future Forwarding representative or schedule a call with a member of our sales team to explore your shipping options.

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