Executive Editorials
Memo from the Chief Customs & Trade Compliance Officer
Our remit is simple: eliminate surprises in landed cost and exposure in audit. Three decisions follow, effective immediately.
1) Classification governance is a board-level control.
The 2025 HTS updates are live. Any SKU whose construction or use has drifted—even subtly—must be retested against current headings and notes. Product, sourcing, and trade ops will maintain a single “authoritative code” per SKU with a change log tied to the HTS change record. No code changes via email threads; broker instructions update the same day a code is approved. Harmonized Tariff Schedule+1
2) ISF is not a paperwork hurdle; it is our frontline data test.
Late or inaccurate ISFs translate into liquidated damages, inspection risk, and downstream rework. New standard: freeze upstream parties and six-digit HTS placeholders 48 hours before vessel loading; corrections are version-controlled and owned by name, not by team. We will track a hard KPI: ISF error rate <1% and supplier-to-filer update lead time <12 hours. CBP Help Center+1
3) Routed exports: pick a lane and document it.
Where the foreign principal party directs the move, we will obtain written AES authorization, map who supplies each data element, and verify how the ITN returns to records. Contracts and SOPs must reflect the chosen model—standard or routed—and we will audit forwarders quarterly against it. Ambiguity here becomes an audit finding. eCFR+1
30-day plan (non-negotiable):
Run a “Rev-check” on the top 50 SKUs against the 2025 HTS change record; document any rate or stats impacts and refresh broker instructions the same day.
Stand up an ISF control ledger: every correction logged with timestamp, owner, and reason; sample last month’s filings against final entry data.
Refresh routed-export templates: authorization letters, data-element matrix, and ITN capture flow; train internal teams and forwarders.
Escalation triggers:
Any duty delta >50 bps on a top SKU after a spec or supplier change.
Any ISF correction less than 12 hours pre-load without executive visibility.
Any export where filer responsibility is unclear at booking.
If we operationalize these three decisions, customs stops being a source of variance and starts compounding margin.
Editorial note: This is general information, not legal advice. For a targeted HTS or filings check, TradeReady can run an accelerated “Rev-check” and ISF/AES spot audit.
Primary sources:
USITC — HTS 2025 Change Record / 2025 Basic Edition (current nomenclature and breakouts). Harmonized Tariff Schedule+1
CBP — Importer Security Filing (10+2): timing & $5,000 liquidated damages per violation; program overview. CBP Help Center+1
eCFR / Census — 15 CFR §30.3: responsibilities in standard vs. routed export transactions; most-recent FTR PDF. eCFR+1
