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US importers face a new era of customs scrutiny

Sep 16, 2026 | ,

US import compliance is becoming more demanding, with Customs and Border Protection strengthening enforcement, scrutinising importer data and using technology to examine transactions long after goods have cleared the border.

From 18 September, inaccurate information held by US Customs and Border Protection (CBP) could result in an Importer of Record (IOR) losing the right to bring goods into the country.

The change may sound administrative, but its implications go much further. CBP is comprehensively reviewing importer records, while wider enforcement reforms are placing greater responsibility on businesses to demonstrate the accuracy of classifications, valuations, origins and sourcing decisions.

For importers already managing changing tariffs, suppliers and sourcing strategies, compliance increasingly needs to begin before cargo leaves origin and continue long after it arrives.

Importer responsibility starts before shipment

Under the new requirements, CBP can revoke import privileges when IOR information is inaccurate. That includes fundamental information such as physical addresses, telephone numbers and email addresses.

Crucially, responsibility remains with the importer even when a customs broker submits the information. Importers must ensure their records are correct when initially filed and remain accurate afterwards.

That principle extends across the customs process and cargo release does not necessarily mean CBP has accepted an entry as correct. Entries can remain subject to review during the 314-day liquidation process, while importers must retain supporting records for five years.

CBP is also becoming better equipped to identify inconsistencies. Investment in technology and AI means customs authorities can examine patterns across an importer’s history rather than treating every shipment in isolation.

That matters as businesses respond to tariff changes by switching suppliers, changing sourcing countries, restructuring transactions or altering declared values.

A legitimate commercial change can still attract attention if the customs data suddenly looks different. Importers therefore need records that demonstrate not only what changed, but why.

Relying solely on information supplied by overseas vendors or assuming a customs broker carries the compliance responsibility creates unnecessary exposure.

Importers should instead have visibility of the transaction before shipment, checking purchase orders, commercial invoices, quantities, product classifications, declared values and country of origin while there is still time to resolve discrepancies.

Broker oversight is equally important. Regularly reviewing customs entries against underlying commercial data can identify inconsistencies before they develop into a wider compliance problem.

CBP wants visibility deeper into the supply chain

The direction of travel suggests these requirements could become more extensive. CBP is consulting on proposals that could require importers to retain or submit overseas customs documentation, potentially including foreign customs entries, commercial invoices, packing lists and bills of lading.

It is also considering deeper disclosure of the upstream inputs and parties involved in producing foreign-sourced goods. Existing manufacturer information does not always provide the visibility CBP wants for enforcement purposes.

Taken together, the changes point towards a more data-led compliance environment in which CBP can compare US declarations with overseas documentation, supply-chain information and an importer’s historic trading patterns.

For US importers, several priorities follow: keep IOR contact and registration information current; validate classification, valuation and origin before shipment; retain the evidence supporting customs decisions; monitor brokers rather than simply delegating responsibility; and investigate unusual changes in customs data before CBP does.

Established practices also deserve scrutiny. “We’ve always done it this way” is increasingly difficult to defend when CBP can examine years of transaction history and ask for evidence that reasonable care was taken.

Compliance is therefore becoming an end-to-end supply-chain requirement rather than something addressed when cargo reaches the US border.

Metro combines international freight management with experienced US customs brokerage and compliance support, giving importers greater visibility and control from origin through clearance and beyond. 

We can help you validate shipment data, strengthen customs processes and identify potential compliance issues before they put your cargo, or your ability to import, at risk.

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US tariff uncertainty is becoming a permanent supply chain challenge

Aug 19, 2026 | , , , , , , , , , , , , , , , ,

US importers face another period of significant trade policy change as the Trump administration expands its use of tariffs across countries, commodities and industries.

The immediate challenge is understanding which measures apply and how they interact. The wider issue is more fundamental: Section 301 is developing into a broad mechanism for imposing additional tariffs, while stricter customs enforcement increases the financial consequences of getting classification, valuation or origin wrong.

For importers, tariff exposure can no longer be treated as a temporary disruption. It increasingly needs to form part of sourcing, landed-cost and customs compliance decisions.

New tariffs broaden importer exposure

The latest changes follow the expiry of temporary Section 122 tariffs introduced in February 2026 after the Supreme Court overturned the administration’s earlier use of emergency powers for its ‘Liberation Day’ tariffs.

On 24 July, the administration introduced new tariffs on 59 countries and the European Union following a Section 301 investigation into goods allegedly produced using forced labour. The measures effectively restored a 10%–12% minimum tariff across economies responsible for around 99% of US imports, although significant product exemptions remain.

The UK was placed in the 10% group rather than the 12.5% tier applied to many other countries. There are product-specific exemptions under the UK-US Economic Prosperity Deal, so the 10% does not apply universally.

UK automotive exports benefit from a 10% tariff within the agreed 100,000-vehicle quota, aerospace goods have preferential treatment, and UK pharmaceutical exports secured 0% tariffs in April 2026. Different Section 232 or other measures can also apply depending on the commodity.

These duties can also stack on top of existing measures, helping push the estimated overall US effective tariff rate to approximately 10.8%.

Some individual measures go considerably further. Selected Brazilian goods face additional tariffs of 25%, while certain Canadian products have been targeted with duties of 50%. From 31 July, some pharmaceutical imports also became subject to tariffs reaching 100%.

More measures could follow. An investigation into excess industrial capacity covers 16 economies, including China, India, Japan and the EU, while further action targeting digital policies and specific industries remains possible.

The near-term outlook therefore points towards continued volatility rather than simplification. Importers should expect tariffs to change by country, product and policy objective, making total landed-cost calculations increasingly important when comparing suppliers and sourcing locations.

Enforcement raises the cost of getting customs wrong

Tariffs are only one part of the financial exposure. US Customs and Border Protection is also moving towards more aggressive enforcement.

Importers face increased scrutiny of the three areas fundamental to duty assessment: tariff classification, customs valuation and country of origin. Errors can result not only in additional duty assessments but potentially penalties where authorities believe tariffs have been avoided.

The scope for mitigating penalties may also be narrowing. Industry analysis indicates that reductions which historically could reach 90% are becoming less readily available, with mitigation potentially limited to around 50% for trusted traders able to demonstrate effective written controls and robust compliance procedures.

This makes customs governance increasingly important. Importers should review classifications, origin determinations and valuation methodologies before goods arrive rather than relying on retrospective corrections.

Procurement contracts also deserve attention. Businesses may need clearer provisions determining which party absorbs new tariffs and what happens if government action materially changes the economics of an existing sourcing agreement.

Tariffs are likely to remain part of the landscape

Legal challenges continue, including action involving 25 US states, but importers should be cautious about building their strategy around the prospect of tariffs disappearing.

Section 301 has expanded well beyond its previous association with China and is increasingly being used across different countries and policy objectives. Further investigations are expected, suggesting additional tariff announcements remain possible.

Even successful legal challenges may not deliver lasting certainty if the administration replaces overturned measures using alternative statutory authority.

For importers, this changes the emphasis from reacting to individual tariff announcements to building greater resilience into customs and sourcing strategies. That means modelling landed costs under different tariff scenarios, reviewing alternative origins and suppliers, maintaining accurate customs data and identifying opportunities to use legitimate duty-management mechanisms.

Metro’s growing US footprint combined with customs brokerage capability at every US gateway gives importers the support they need as tariff and enforcement requirements become more complex. Our teams can review classification, valuation, origin and duty exposure before cargo moves, identify potential customs risks and help you understand how changing tariffs affect your true landed cost.

With US trade policy changing quickly, don’t wait for a new tariff or customs intervention to expose a problem. Talk to Metro now about reviewing your imports, customs compliance and duty exposure. EMAIL Managing Director Andrew Smith.

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US customs enforcement is tightening

Jul 22, 2026 | , , ,

Importing into the United States is becoming significantly more complex as federal agencies introduce new compliance requirements that place greater responsibility on importers to prove the accuracy, legitimacy and traceability of every shipment.

President Trump's Executive Order on ‘Strengthening Customs Enforcement’ requires the Department of Homeland Security (DHS) to overhaul importer eligibility regulations, customs guidance and enforcement policies, while introducing significantly tougher penalties for businesses that fail to comply. The Department has 180 days to implement the changes.

The focus is no longer simply on collecting duties. Authorities are strengthening oversight of product compliance, importer eligibility, valuation, supply chain transparency and customs declarations, with higher penalties for businesses that fail to meet their obligations.

Customs enforcement is entering a new era

While detailed regulations are still being developed, the direction of travel is already clear. Over the next six months, the Department of Homeland Security is expected to introduce the most significant changes to US customs compliance requirements in years. Importers should prepare for greater disclosure requirements, more extensive due diligence and substantially tougher financial penalties for non-compliance.

Future importer eligibility is likely to require more comprehensive information covering company ownership, business affiliations, production methods, anticipated import volumes, sanctions compliance and supply chain transparency.

The objective is to identify deliberate fraud more quickly, particularly around forced labour, transhipment, undervaluation and product misclassification. However, the measures are also likely to affect compliant businesses, making accurate documentation, complete supply chain visibility and robust internal controls more important than ever.

Current proposals would introduce substantially higher minimum penalties for customs breaches, potentially reducing the flexibility previously available where businesses voluntarily disclosed errors or where mistakes were considered administrative rather than deliberate.

Simple documentation errors, late duty payments or inaccurate declarations that might previously have been resolved with relatively modest consequences could carry much greater financial exposure.

For many businesses, the greater risk may not be the penalty itself, but the commercial impact of delayed cargo, disrupted production schedules and additional storage charges while customs investigations are completed.

eFiling raises the importance of product compliance

Alongside broader customs reforms, mandatory CPSC electronic filing since 8 July is now transforming how regulated consumer products enter the United States.

As Metro highlighted in previous updates, businesses importing products covered by Consumer Product Safety Commission regulations must now submit structured electronic certificate data before goods enter the country.

The early weeks of implementation have already revealed common compliance issues that increase the likelihood of inspections and customs intervention.

Many businesses continue to treat certification as a final documentation exercise immediately before shipment. In reality, compliance now needs to begin much earlier, with manufacturers, suppliers, testing laboratories, freight forwarders and customs brokers all working from consistent product information before cargo is booked.

Certificates must correspond precisely with the products being shipped. Even relatively minor differences in factory location, production batch, product specification or SKU can require different supporting documentation.

The emphasis has shifted from declarations to verifiable data. Informal assurances from suppliers are no longer sufficient if the underlying certification data cannot be submitted electronically in the correct format.

Visibility across the supply chain is becoming essential

These changes reinforce a wider trend across global trade. Whether responding to customs enforcement, product compliance requirements or supply chain security programmes, importers increasingly need complete visibility from manufacturing through to final customs clearance.

Businesses must understand not only where their products are, but how they were manufactured, which suppliers contributed components, what testing has been completed and whether every document can be matched accurately to each shipment.

Without that visibility, customs compliance becomes slower, more expensive and considerably more vulnerable to disruption.

Compliance should start before goods leave origin

The common thread linking every recent regulatory change is preparation.

Companies that establish product compliance, customs documentation and supply chain data before production is completed are far better positioned than those attempting to resolve issues after shipments have been booked.

As customs authorities continue strengthening enforcement, proactive compliance will increasingly become a competitive advantage, helping businesses avoid delays, reduce costs and maintain reliable access to one of the world's largest consumer markets.

Turning compliance into confidence

As Metro continues to expand its customs brokerage capability and operational footprint across the United States, with senior leadership currently visiting colleagues, customers and strategic partners nationwide, we're strengthening the expertise, relationships and technology that help businesses trade with confidence.

Combined with our US customs specialists, CuDoS automated customs platform and MVT supply chain visibility solution, Metro delivers end-to-end visibility from origin to final delivery, right down to SKU level. By integrating customs compliance, shipment tracking and supply chain intelligence into a single solution, we help businesses reduce risk, respond faster to disruption and keep cargo moving efficiently through US Customs.

To discover how Metro can simplify your US customs processes and build a more resilient international supply chain, EMAIL Managing Director Andrew Smith today.

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July deadline for eFiling US product compliance

Jun 24, 2026 | , , , , , , , , , , , ,

From 8 July, regulated consumer products entering the US must be supported by electronic compliance certificates filed at the time of customs entry, turning missing or inaccurate information into a direct threat to supply chain continuity.

This is not a change to the underlying safety rules, but to how they are enforced in practice. Paper or PDF certificates kept “on file” will no longer be enough; instead, compliance data must travel with the goods through US Customs and Border Protection’s Automated Commercial Environment (ACE), creating a new operational dependency on clean master data and structured product records.

What is changing in July

The US Consumer Product Safety Commission (CPSC) is rolling out mandatory electronic filing of Certificates of Compliance for regulated consumer products from 8 July, covering finished goods already in scope of existing CPSC requirements.

Importers (or their customs brokers) must now submit defined certificate data elements electronically via ACE with every applicable customs entry, including low-value and de minimis consignments. Shipments into US Foreign Trade Zones benefit from a longer transition, with mandatory eFiling pushed back to January 2027, but they will ultimately be brought into the same regime.

The new rules will be felt most acutely in sectors with broad product ranges, frequent line changes and complex safety obligations.

Fashion, retail, toys, consumer electronics, nursery products, homeware and household goods are all directly affected, particularly where products require either a Children’s Product Certificate (CPC) or a General Certificate of Conformity (GCC). 

For brands with high-volume direct-to-consumer flows and seasonal collections, the inclusion of de minimis parcels means that even small data gaps can disrupt launches and delay customer deliveries.

From paper certificates to digital compliance

For each shipment, importers must transmit a structured set of data points, including product identifiers (such as SKUs), details of the certifying party, the specific safety rules applied, manufacturing dates and locations, test dates and locations, and contact details for the laboratory and record keeper. 

Importers can choose between two methods of submitting compliance data:

1. Full PGA Message Set

Under this option, all certificate data is filed directly into ACE for every shipment. Required information includes:

  • Product identifiers such as SKU or GTIN
  • Applicable CPSC safety standards
  • Manufacturing dates and locations
  • Manufacturer or assembler details
  • Testing dates and testing facility information
  • Laboratory details
  • Contact details for the party maintaining compliance records

This approach is generally more suitable for importers handling smaller product ranges or irregular shipments.

2. Reference PGA Message Set

For businesses importing the same regulated products regularly, the CPSC Product Registry offers a more streamlined alternative.

Product certificate information can be pre-registered in advance, allowing customs brokers to submit only:

  • Certifier ID
  • Product ID
  • Certificate Version ID

This method can significantly reduce repetitive data entry and support faster customs processing.

Both approaches rely on accurate, pre-prepared data that aligns exactly with the physical shipment.

New operational and data challenges

Importers now need to manage the intersection of multiple requirements at SKU level, for example combining US flammability rules for clothing, chemical restrictions on substances such as lead and phthalates, and labelling standards for fibre content, care instructions and safety warnings.

For fashion and lifestyle brands, that means building robust testing programmes, maintaining complete technical files and ensuring master data can be translated into CPSC-compliant certificate records without manual rework at the point of entry.

Regulators have signalled that they expect full compliance from the implementation date, with no broad indication of delayed enforcement.

Incorrect or incomplete eFilings can trigger automated customs holds, manual inspections, potential seizure or refusal of non-compliant shipments, and even civil penalties where systemic failures are identified. For time-sensitive sectors such as fashion and retail, where margins and calendars are already under pressure, even short delays at the border can undermine entire seasons or promotional campaigns.

Why exporters and origin teams matter

Although legal responsibility for eFiling sits with the US importer, a significant proportion of the required information resides with exporters, manufacturers and upstream partners.

Testing records, manufacturing details, lab certifications and product specifications are typically held at origin, and without structured access to this data, importers may struggle to complete mandatory filings accurately and on time. Exporters targeting the US market therefore need to map CPSC scope with their customers and embed electronic information sharing into standard shipping processes so certificate data is available well before cargo departs.

Turning compliance into an advantage

Businesses that invest early in mapping their CPSC exposure, closing testing gaps, building digital certificate libraries and rehearsing eFilings in test environments will move through the new regime with fewer delays and lower risk. 

Those that treat compliance as a last-minute paperwork exercise risk finding that missing or inconsistent data becomes a bigger threat than tariffs, capacity constraints or transport disruption.

Metro is already working with customers in fashion, retail, consumer goods and wider international trade to align product data, testing records, documentation and customs processes across origin and destination teams. 

If you import into the United States and want to turn the new CPSC eFiling rules into a competitive advantage rather than a source of disruption, EMAIL our Managing Director, Andrew Smith, directly. 

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