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U.S. Customs and Border Protection (CBP) announced that it would begin tighter enforcement of either late or inaccurate Importer Security Filings (ISF) beginning June 30, 2016. Non-compliant Importer Security Filings could result in an increase in penalties or cargo holds for importers at ports of entry. (CSMS #14-000283)
Updated Importer Security Filing (ISF) Enforcement
CBP recently issued a CSMS for updated Importer Security Filing (ISF) Enforcement.
This new phase of ISF enforcement applies to ISF-10 shipments, not ISF-5, for ocean shipments on the water on or after June 30, 2016.
CBP-HQ provided new guidance to the ports to issue any ISF claims within 90 days of discovering the violation.
Although CBP ports will no longer be required to take a "three-strikes" approach before issuing liquidated damage (LD) claims or send these claims to CBP-HQ for review, each port will continue to have authority to manage their local enforcement posture as they do today.
Per existing policy, CBP will continue to focus on "significantly" late ISF shipments that preclude or compromise CBP's ability to target the cargo before it arrives in the U.S. For example, West Coast ports have longer ocean voyages so "significantly" late may be ISFs that are not filed within 72 hours to 5 days prior to arrival of the cargo in the U.S. Other ports with shorter voyages may focus on 24 hours prior to vessel departure (what the law requires).
We also expect CBP to focus on repeat violators which can include ISF shipments that are inaccurate because there is no bill of lading match, and/or the match was not made timely and compromised CBP's targeting prior to the cargo's arrival in the U.S.
Although CBP delayed these enforcement changes for over a year, the webinar that CBP hosted last May still provides relevant information. We encourage you to view the CBP Webinar Recording, Presentation, Transcript, and Q&A .
Tariffs on Imports
Note this information is subject to change
Canada
• 25% IEEPA tariff on goods not meeting USMCA (U.S.-Mexico-Canada Agreement) rules of origin.
• 10% IEEPA tariff on potash not meeting USMCA (U.S.-Mexico-Canada Agreement) rules of origin.
• 10% IEEPA tariff on energy not meeting USMCA (U.S.-Mexico-Canada Agreement) rules of origin.
• USMCA qualified goods can be entered without the additional IEEPA rate.
Mexico
• 25% IEEPA tariff on goods not meeting USMCA (U.S.-Mexico-Canada Agreement) rules of origin.
• USMCA qualified goods can be entered without the additional IEEPA rate.
China
• IEEPA 20% tariff on all imports.
• Existing Section 301 tariffs still in affect on top of IEEPA tariffs.
• Tariffs stack including IEEPA, 301 and 232 tariffs.
Section 232: Steel & Aluminum Tariffs
• All non-US steel and aluminum tariffs are 25% regardless of origin
• 25% tariffs expanded to include derivative products.
• No more exclusion process
• No Drawback allowed
• End of quota agreements with affected countries
• FTZ admissions must be in Privileged Foreign Status
• Listing of affected HTS codes and their corresponding chapter 99 program tariff can be found at the link below.
International Emergency Economic Powers Act (IEEPA)
• Grants the U.S. President authority to regulate commerce in response to national emergencies.
• Used to impose economic sanctions, restrict trade, or freeze assets of individuals, companies, or governments.
• Aims to protect U.S. national security and foreign policy interests.
• No drawback allowed
JAS Forwarding (USA) Inc. Compliance Team is pleased to announce that we will be hosting a webinar on all things tariffs on March 25, 2025, at 3PM Eastern time.
On the agenda, we will cover Canada tariffs, Mexico tariffs, China tariffs, Steel & Aluminum, reciprocal tariffs and much more.
Our own Laurie Arnold and Scott Cassell will discuss tariffs and answer questions. Check out our webinar flyer and the link to the registration page below.
Multiple media outlets are reporting that the President will increase tariffs on steel and aluminum from Canada from 25% to 50% in response to the electricity price increases announced by the Ontario government for electricity sold to the United States. The President noted on a Truth Social post that the increase is effective starting tomorrow, March 12, 2025.
Read our full advisory by clicking below.
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