Market Moves
A fast read on U.S. Customs, tariff & filings that could move your margins.
Classification — Kits, comps, and “principal use” under the microscope.
CBP exam teams are leaning harder on how importers classify multi-component products and kits. Expect more questions on whether goods qualify as a “set” under GRI 3(b) and whether your declared heading reflects the item’s principal use—not its marketing copy. Keep a defensible BOM, product photos, and use studies handy.
Tariffs — Quiet dockets, real exposure.
Even without headline tariff changes this week, rate misclassifications remain a stealth cost driver. Small shifts in heading/subheading (think materials content or “with/without” features) can swing duty liability meaningfully. A periodic HTS scrub on top movers is still the cheapest insurance in trade.
ISF (10+2) — Timeliness is tightening.
Terminals and carriers continue to flag late or error-ridden ISFs, and CBP penalties (often $5,000 per violation, capped at $10,000 per shipment) still bite. Common trip-ups: wrong seller/buyer parties, six-digit HTS placeholders that never get updated, and last-minute consolidator changes. Lock your upstream data earlier and memorialize corrections.
AES — Routed vs. standard is not a vibe, it’s paperwork.
Confusion over who files what persists in routed export transactions. If a foreign principal party directs the move, document it: written AES filing authorization, who’s providing which data elements, and how the ITN is flowing back into records. Double-check ECCN/license values before wheels-up—late fixes are audit bait.
Valuation & assists — the sleeper audit theme.
Where engineering, software, or tooling comes from matters. If provided free or at reduced cost, you may have an “assist” that belongs in customs value. Create a quarterly ritual with engineering/ops so those inputs don’t get lost outside the finance ledger.
What to do now (5-step quick check):
Pull your top 25 SKUs and re-test HTS against construction, materials, and principal use.
Sample last month’s ISFs for accuracy vs. final entry data; document any deltas.
Confirm routed-transaction procedures and AES authorizations with forwarders.
Map potential assists (tooling, firmware, CAD, packaging design) and document treatment.
Park a one-pager at the dock: “Who to call before we change suppliers/specs/packaging.”
Editor’s note: This brief is informational, not legal advice. For a second look at classifications or filings, ask TradeReady to run an HTS expert review or an AES/ISF spot audit.
Primary sources:
CBP: Classification of Sets under the HTSUS. U.S. Customs and Border Protection
CBP Help Center: Import Security Filing (10+2) — timing & $5,000 liquidated damages per violation. CBP Help Center
eCFR: 15 CFR §30.3 — FTR responsibilities; standard vs. routed export transactions. eCFR
