The trade landscape continues to evolve rapidly as tariff policies expand and new investigations emerge across multiple industries. Importers, exporters, and multinational businesses are finding that compliance, valuation, and supply chain strategy are now deeply interconnected.
To help clarify common areas of confusion, our team has organized insights into several key themes, from determining responsibility to mitigating tariff costs and preparing for policy change.
In the United States, the importer of record bears full responsibility for paying tariffs and ensuring compliance with customs laws. This rule applies universally, regardless of the importer’s size, structure, or location.
Tariffs are not always singular. Many goods are subject to stacked or cumulative duties—for example, the base duty under the Harmonized Tariff Schedule (HTS) may combine with Section 232 (national security) or Section 301 (trade enforcement) tariffs.
This layering is most common in materials such as steel and aluminum, where multiple classifications (and sometimes antidumping or countervailing duties) may overlap, leading to higher effective rates.
Businesses importing goods for repair, testing, warranty replacement, or re-export may qualify for tariff exemptions under HTSUS Chapter 98. These rules are narrow and documentation-heavy, requiring importers to prove the temporary nature and proper disposition of the goods.
Tariff outcomes are shaped by rules of origin, which determine where a product is considered to have been made. Under agreements such as the U.S.-Mexico-Canada Agreement (USMCA), origin depends on factors like regional value content or tariff classification shifts.
Changes anticipated in the 2026 congressional review of USMCA may tighten requirements for North American content in some industries, potentially affecting eligibility for preferential tariff treatment.
Tariffs influence transfer pricing for companies engaged in related-party transactions. Because customs valuation is based on the transfer price, adjustments in pricing can directly affect cost of goods sold and profit margins.
Royalties and licensing payments tied to imported goods may also need to be added to the dutiable value, which increases tariff costs. Any modification to pricing structures must comply with both IRS arm’s-length rules and U.S. Customs valuation standards.
Effective tariff management combines compliance diligence with proactive strategy. Key options include:
Most tariffs, including Section 301 and Section 201 duties, qualify for drawback. However, Section 232 and antidumping/countervailing duties generally do not.
For products assembled from components sourced globally, tariffs depend on whether a substantial transformation occurs in the final country of manufacturing. Determining the correct country of origin requires close examination of production steps and material composition, particularly for mixed-source goods such as automotive or electronic assemblies.
Tariff rates and lists are fluid. Recent U.S. investigations and policy proposals have focused on pharmaceuticals, semiconductors, critical minerals, renewable energy equipment, heavy-duty trucks, and aerospace products.
Importers should establish continuous monitoring of official updates to avoid surprise rate changes or missed opportunities for relief.
Importers can track shipment and tariff data through the Automated Commercial Environment (ACE), managed by U.S. Customs and Border Protection (CBP). Registration as the importer of record grants access to detailed import data and allows businesses to authorize brokers or advisors to manage records on their behalf.
Tariff complexity requires both awareness and foresight. By combining sound compliance practices with proactive planning, businesses can reduce risk, manage costs, and maintain flexibility in global supply chains.
At Wei, Wei & Co., LLP, our professionals help clients interpret evolving trade rules, evaluate cost implications, and implement strategies that align with their broader financial and operational goals.
If your company imports goods or is affected by current or pending tariff actions, we can help you assess exposure, strengthen compliance, and explore cost-saving strategies.
Contact Wei, Wei & Co., LLP to discuss your tax planning needs.