Investigation

US Customs and Border Protection to target undervaluation and DDP abuse

Jun 9, 2026 | , , , , ,

President Trump’s new customs enforcement drive is turning DDP and other seller‑controlled models into a high‑risk area, especially where duties are undervalued or the true importer of record is unclear.

The 3 June 2026 “Strengthening Customs Enforcement” executive order marks a significant tightening of how US Customs and Border Protection (CBP) vets and polices importers of record. It directs CBP to raise minimum asset and bond requirements, collect more detailed data at registration, and classify importers into risk‑based tiers linked to their compliance history.

Importers will have to disclose anticipated import volumes, beneficial ownership, business affiliations and domestic assets, and maintain a defined “good standing” status to continue importing or appointing a customs broker. Foreign‑based importers face additional restrictions, including limits on informal entries and tighter conditions for using continuous bonds.

Why DDP and DAP are in the spotlight

Higher tariffs in Trump’s second term have nudged contract terms towards Delivered Duty Paid (DDP) and similar structures, where the seller takes responsibility for duties, taxes and customs clearance. On paper, this can simplify life for buyers, but it also shifts control of declarations and valuations to the party with the strongest incentive to cut landed costs.

CBP has highlighted undervaluation, mis-declaration and opaque importer structures as priority enforcement areas. In a DDP or DAP model with a foreign importer of record, there is a heightened risk that declared values are artificially low, classification is aggressive, or the nominal importer is a thinly capitalised shell with few US assets. These are exactly the patterns the new regime is designed to catch.

Delivered Duty Paid arrangements often rely on overseas documentation and invoicing that CBP cannot easily verify at the border. Low‑value or informal entries have historically been harder to police, and this has created room for abuse, such as splitting shipments, manipulating invoice values or using rebates that never appear on the customs invoice.

Under the new enforcement approach, CBP is explicitly targeting misclassification, undervaluation and duty‑avoidance schemes. With higher tariffs in play, the financial upside of under‑declaring value is greater, but so is the downside: higher penalty floors, fewer mitigation options, and an increased likelihood of audits, holds, and retrospective assessments if patterns look suspicious.

Foreign IORs and “shell” structures

The executive order draws a sharper distinction between US and foreign importers of record, and seeks to close loopholes that have allowed foreign entities to mimic US presence using shell companies. To qualify as a US importer, entities will need a genuine US footprint: incorporation under US law, a principal place of business in the US, tangible domestic assets and identifiable US beneficial owners.

Foreign IORs will be barred from using informal entries and will face stricter bond and vetting requirements for formal entries, often needing validation via trusted trader programmes or a validated US customs broker. This makes it more difficult for lightly capitalised overseas sellers to hide behind complex structures when operating DDP models into the US.

Higher penalties, more data, more audits

The enforcement framework is also being hardened across the board. CBP is moving to set minimum penalty and liquidated damages floors, reduce mitigation options, particularly for repeat offenders, and expand the use of audits and data‑driven targeting. Brokers that turn a blind eye to high‑risk clients, or fail to exercise due diligence, can expect higher penalties and closer scrutiny.

Importers will be required to submit additional documentation, including the same export paperwork filed with the foreign customs authority, supply chain certifications and more detailed product specifications. This expanded dataset supports CBP’s increasing use of analytics and AI to flag unusual trade patterns, valuation anomalies, and sudden shifts in importer or routing behaviour.

If your US trade relies on DDP, DAP or foreign importer‑of‑record models, this new enforcement environment demands a fresh look at your structures, contracts and declarations before CBP does it for you.

To review your current arrangements, assess your exposure and design a compliant, resilient approach to US customs under the new rules, please EMAIL Andy Fitchett, Metro’s Head of Customs & Compliance.

USMCA

USMCA renewal talks critical for North American manufacturing supply chains

Jun 9, 2026 | , , , , , ,

The United States-Mexico-Canada Agreement (USMCA) is the legal and operational backbone of a $31 trillion North American trading bloc, and its renewal process is a live strategic risk factor for manufacturers and automotive brands active in the region.

Renewal negotiations are one of the most strategically important issues facing North American manufacturers, automotive brands and industrial supply chains.

While the agreement itself is not due to expire immediately, the failure to secure a straightforward 16-year renewal by the July 2026 review milestone is creating growing uncertainty across sectors heavily reliant on integrated US, Mexican and Canadian manufacturing operations.

The negotiations are particularly important for automotive, machinery, steel, aluminium and advanced manufacturing supply chains that have spent years restructuring production around the USMCA framework.

Why USMCA matters

The USMCA effectively underpins North America’s position as a highly integrated manufacturing bloc, supporting nearly $2 trillion in annual trade and deeply interconnected cross-border production networks.

The agreement provides the legal and operational framework that allows manufacturers to build complex regional supply chains with long-term investment certainty, streamlined customs processes and unified rules governing trade across all three countries.

That stability has become increasingly valuable as global manufacturers continue reducing dependence on long-distance Asian supply chains and accelerating near-shoring strategies closer to North American demand centres.

Mexico, in particular, has become a major beneficiary of this shift, offering shorter transit times, lower logistics risk and strong manufacturing integration with US production.

Automotive supply chains remain at the centre of negotiations

USMCA rules already require 75% of vehicle content to originate within North America for tariff-free treatment, helping drive major investment into regional automotive manufacturing and supplier networks.

Modern automotive production across North America is now deeply interconnected, with components often crossing borders multiple times before final vehicle assembly.

A single component may be stamped in Mexico, machined in the US and assembled into a finished vehicle in Canada or back in Mexico. That level of integration means even relatively small tariff or rules-of-origin changes can have significant operational and commercial consequences.

The Trump administration is now reportedly pushing for even higher US content requirements within vehicles as part of the renewal process, alongside broader efforts to bring more manufacturing activity back into the United States.

At the same time, steel, aluminium and automotive tariffs remain major areas of disagreement between the three countries.

Negotiations becoming more complex and politically sensitive

Formal negotiations between the US and Mexico are now under way, while Canada is still waiting to enter full trilateral discussions with Washington.

Current expectations are that the July review deadline will pass without a full agreement, triggering an extended review and negotiation period rather than an immediate collapse of the agreement itself.

In practical terms, USMCA would remain operational, but uncertainty around future rules, tariffs and investment conditions could persist for months or even years.

That uncertainty matters.

Manufacturers making long-term investment decisions around factories, tooling, supplier sourcing and critical minerals need confidence that North American trade rules will remain stable over the life of those investments.

The White House is also increasingly using separate bilateral negotiations alongside the formal USMCA review process, creating additional complexity around tariffs, automotive rules, steel, aluminium, labour standards and critical minerals.

For many manufacturers, the agreement is now viewed not simply as a trade deal, but as a strategic foundation for North American industrial resilience.

What this means for manufacturers and importers

For businesses operating across North America, the current environment reinforces the importance of supply chain flexibility, customs planning and close monitoring of trade policy developments.

Automotive, industrial and manufacturing sectors remain particularly exposed to any changes involving rules of origin, tariffs, customs procedures or regional content requirements.

While the direction of negotiations remains uncertain, all three governments continue publicly supporting the importance of maintaining a trilateral North American trade structure.

The challenge now is whether that shared strategic interest can overcome increasingly difficult political and economic negotiations.

Metro helps customers manage complex cross-border logistics, customs compliance and North American supply chain strategies across the US, Mexico and Canada.

To discuss your North American logistics requirements or USMCA-related supply chain planning, EMAIL Managing Director Andrew Smith.

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U.S. Supply Chains Grapple Cost Pressures and Uncertainty

May 28, 2026 | , , , , , , , , ,

Heading into the second half of 2026 shippers face, a politically charged USMCA review, an early tightening on the trans‑Pacific, and war‑driven fuel costs pushing up inland transport prices across North America. 

Together, they are rewriting the assumptions many companies use for peak‑season planning, pricing and inland network design.

USMCA stability at stake for North American production

The United States–Mexico–Canada Agreement (USMCA) reaches its first scheduled “joint review” on 1 July 2026, six years after it took effect. The three governments must decide whether to confirm the deal through 2042, seek adjustments, or signal opposition that could trigger renegotiation and, in the worst case, open the door to an eventual sunset in 2036 if no resolution is found.

Manufacturing across North America, and especially in the automotive sector, has a lot riding on the outcome. Automotive trade accounts for roughly 20–25% of total USMCA trade flows, making it the single largest sectorial user of the agreement. Since 2020, higher regional content requirements and labour‑value rules have already reshaped sourcing patterns for OEMs and tier suppliers, driving more production and component sourcing into Mexico, the U.S. and Canada.

Industry groups on all sides of the border are pushing for a stable, growth‑oriented review that preserves tariff‑free access and gives long‑term visibility to investors. At the same time, policymakers are signalling that the review will not be a formality. Areas likely to come under scrutiny include automotive rules of origin and tracing, enforcement of labour and environmental commitments, energy and state‑owned enterprise disputes, digital trade and data rules, and the role of Chinese investment and components in North American supply chains.

For U.S. manufacturers and importers, this means the next 12–18 months are a critical window to:

  • Verify that products truly qualify under current USMCA rules and identify any borderline cases.
  • Model how tighter regional content or new tracing requirements could change compliance status and cost.
  • Stress‑test footprint and sourcing decisions, particularly where there is high China content flowing via Mexico or Canada into the U.S.

Trans‑Pacific signs of an early peak

Eastbound trans‑Pacific trades are already showing signs of an early peak‑season, with container spot rates from Asia to the U.S. west and east coasts climbing sharply on the back of May general rate increases, as carriers tighten capacity and push through surcharges.

Recent data shows:

  • Spot rates from major South China ports to the U.S. west coast rising almost 100% on levels from only weeks earlier.
  • Asia–U.S. east coast spot rates climbing by 50–60% over a similar period, with some indices even higher.
  • Carriers rolling out peak season surcharges and emergency fuel surcharges ahead of the usual schedule, with higher amounts signalled for late June and 1 July.

Several dynamics are driving this early tightening:

  • Importers are front‑loading orders to get ahead of further cost increases later in the year, including potential tariff changes and bunker‑linked adjustments.
  • Vessel diversions around southern Africa to avoid Red Sea and Gulf of Aden risks, coupled with congestion at some Asian load ports, are absorbing capacity and disrupting schedules.
  • Capacity additions have lagged demand on key lanes, and carriers are using blank sailings and service adjustments to keep utilisation high.

We expect some rate relief later in the summer if additional capacity returns and front‑loaded volumes drop off, but the near‑term picture is one of elevated spot rates and tight space as peak‑season volumes converge with constrained supply.

Trucking and inland costs rise on fuel‑driven inflation

War‑driven fuel prices are pushing trucking and intermodal costs sharply higher, even before demand has fully recovered.

Since the escalation of conflict involving Iran, U.S. retail diesel prices have moved from just under USD 4 per gallon to around USD 5.60 per gallon on average, with some regions significantly higher. This jump has fed directly into trucking Producer Price Index (PPI) measures:

  • Truckload and LTL PPIs have risen markedly in recent months, reversing a multi‑year period of freight deflation;
  • Spot truckload rates on long‑haul lanes have climbed to their highest levels since 2022, with average per‑mile prices up more than 25% year‑on‑year in some benchmarks;
  • Higher fuel and capacity discipline are also starting to pull contract rates up, with increases spreading from truckload into LTL and intermodal.

It is worth noting that these increases are being driven largely by supply‑side constraints, reduced capacity, higher fuel costs and more disciplined carrier pricing, rather than by booming freight demand. For shippers, that means transport inflation can persist even if volumes remain only modestly above 2025 levels.

Metro’s CEO Grant Liddell and Managing Director Andrew Smith will be visiting U.S. offices and customers next week, to review operations and discuss these challenges on the ground, to help shape next‑step plans.

If you’d like to sense‑check your outlook for the second half of 2026 – from USMCA exposure and sourcing footprints to peak‑season capacity and inland cost pressures you can EMAIL Andrew directly or connect with the Metro Global USA team.

US tariffs

US tariff refund process opens

Apr 29, 2026 | , ,

The long-anticipated process to recover US tariffs imposed under the International Emergency Economic Powers Act (IEEPA) has now begun, with U.S. Customs and Border Protection (CBP) launching its new refund system.

The introduction of the Consolidated Administration and Processing of Entries (CAPE) platform on 20 April 2026 marks a critical milestone. Businesses can now begin submitting claims for duties paid during the affected period, with the first submission deadlines from 4 May 2026.

However, while access to refunds is now available, the window to act is narrow and the process itself is far from straightforward.

For UK businesses trading with the United States, and particularly those operating under Delivered Duty Paid (DDP) terms, this represents a significant financial opportunity and a complex compliance exercise.

CAPE system introduces structured but time-sensitive process

The CAPE system, accessed via the ACE portal, is the exclusive route for submitting refund claims. Only the Importer of Record or an authorised customs broker can file, using a structured declaration format that requires detailed historical entry data.

Phase 1 of the programme is now active, covering unliquidated entries and those recently finalised. This initial phase is expected to account for a significant proportion of eligible claims, but strict timelines mean businesses must act quickly to avoid missing eligibility windows.

Once claims are accepted, refunds including interest are expected within 60 to 90 days, although actual timelines will depend on the quality and completeness of submissions.

A large-scale reconciliation exercise, not a simple refund

Despite the introduction of automated systems, the process is best understood as a full customs reconciliation programme rather than a standard reimbursement.

Each claim must be validated against historical entry data, including confirmation of importer-of-record status, tariff classifications, and whether entries have been liquidated, adjusted or previously disputed.

Given the scale, with tens of millions of entries under review, submission, validation and payment will take place in phases, and delays are likely where data is incomplete or inconsistent.

For entries outside the initial phase, businesses may need to pursue alternative routes such as formal protests, typically within 180 days of liquidation, adding further complexity.

The opportunity to recover duties is not limited to US-based importers. Many UK and international exporters may also be eligible where they acted as importer of record under DDP terms.

In these cases, businesses must demonstrate full control and responsibility for the original customs entries, making data accuracy and documentation critical to a successful claim.

Early action will determine success

With submission windows already open and deadlines in force, the focus now shifts to preparation.

Businesses should prioritise identifying affected shipments, confirming importer-of-record status, verifying tariff classifications, checking liquidation timelines and consolidating supporting documentation.

Those that act early and submit accurate, well-prepared claims will be best placed to move through the process efficiently and secure full recovery.

Metro supports importers and exporters in identifying eligible entries, preparing compliant submissions and managing claims through to reimbursement. If your business has exposure to US tariffs, EMAIL our Head of Customs & Compliance, Andy Fitchett, today to assess your position and secure the recovery you are entitled to.

Category: United States

4PL | Customs | Economics | Finance | International Trade | United States

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