The New Trade Landscape

Priority Actions for Customers

Due to the implementation of new tariffs on U.S. imports, A.N. Deringer, Inc. will require advance payment for any new duties. We encourage clients to set up their own ACH accounts to pay Customs and Border Protection (CBP) directly. To avoid shipment holds and delays, customers should contact us before booking or sending shipments affected by the new tariffs.
If you do not have your own Customs Automated Clearing House (ACH) Account, we strongly recommend that you apply for it as soon as possible.
If you have your own ACH Account, verify your transaction limits with your bank now. Insufficient transaction limits will cause your bank to reject Customs payments.
Check and adjust your bond limits to ensure your bond is sufficient. The new tariffs may saturate your limit very quickly.

Section 232: Aluminum and Steel Import Resources

One of the more complex and evolving regulatory developments, Section 232 tariffs were recently expanded to include 407 HTS provisions effective August 18, 2025.

Section 232 entry requires verification from importers’ suppliers to report the primary country of smelt/cast. If a country that is not known to have smelting capabilities is listed on a U.S. entry, that could be a red flag for CBP. Given the increased focus on tariff evasion and enforcement by the regulatory authorities, we suggest importers use this Country Smelt Dashboard provided by the International Trade Administration (ITA) to double check the information provided by suppliers and noted on the entry.

Another helpful tool from ITA is a Melt/Pour Dashboard. This tool is somewhat different than the Country Smelt tool noted above, as it uses a world map showing U.S. imports by country of melt/pour, providing another reference and verification of data provided by suppliers.

Additional websites from ITA on steel/aluminum that importers may wish to reference include:

https://www.trade.gov/steel

https://www.trade.gov/aluminum

Trade Alerts Recap

We provide up-to-date information on tariffs and new policies through Trade Alerts. Here's some of the latest news:

12/19/25: UPDATE Potential Refunds of IEEPA Duties

On August 29, 2025, the Court of Appeals for the Federal Circuit (CAFC) had ruled that the International Emergency Economic Powers Act (IEEPA) does not grant the President the authority to impose specific import tariffs. The case is under review by the Supreme Court, however, the IEEPA duties remain in effect for now.

This situation raised many questions related to potential IEEPA refunds, and what importers should do to protect their refunds if the Supreme Court upholds the CAFC’s decision. Trade attorneys provided guidance ranging from filing protective protests, filing an injunction against liquidation before these entries liquidate to filing a lawsuit with the Court of international Trade (CIT).

On December 15th, the CIT denied a motion for an injunction stopping liquidation of entries from a group of importers that filed challenges to IEEPA.

Judges Gary Katzmann, Timothy Reif and Jane Restani held that an injunction is unnecessary because the trade court has the authority to reliquidate finally liquidated entries from the importers that filed suit under the court’s 28 U.S.C. 1581(i) jurisdiction if the Supreme Court invalidates the tariffs.

The judges also noted the government’s commitment that it won’t fight against CIT’s ability to order refunds, finding the U.S. is barred from changing its position in the future.

Following the CIT’s decision, trade attorneys are issuing somewhat varied opinions on what importers should do now to protect their potential refunds.

We recommend consulting with a trade attorney to determine your company’s best course of action.

We continue to advise importers to monitor transactions and liquidation status where the IEEPA duties have been paid, as well as the amount of IEEPA duties paid.

Please note that Post Summary Correction (PSC) filings cannot currently be submitted for unliquidated entries that remove IEEPA tariffs. However, this may change in the future if the Supreme Court upholds the CAFC ruling. We have also been notified that CBP will not be accepting extension of liquidation requests.

12/3/25: Tariff Updates Under U.S.-Korea Agreement

The Office of the U.S. Trade Representative (USTR) announced today, December 3, 2025, that tariff modifications under the recent U.S.–South Korea agreement and outlined in a Nov. 13 fact sheet apply retroactively:

Automobiles & Auto Parts: Effective for entries on or after Nov. 1, 2025
Other Products (timber, lumber, aircraft parts, etc.): Effective for entries on or after Nov. 14, 2025

These changes are detailed in the Federal Register notice and modify the HTSUS as outlined in the agreement’s annex.

Due to the rapidly changing application and modifications of duty rates, please note that Deringer is not responsible for coordinating the timing of U.S. entry and imposed tariff rates.

12/2/25: Key IEEPA updates, exclusions, and agreements

President Trump signed an executive order removing certain agricultural products from IEEPA reciprocal tariffs. These items were added to Annex II (covering all countries) and removed from Annex III (PTAAP). While exclusions were announced on November 13, no implementation dates have been established yet for the countries delineated below:

South Korea Trade Agreement Finalized
The U.S. and South Korea completed an IEEPA trade agreement with a “no stacking” provision: tariffs will be the higher of KORUS, MFN, or 15%. Annex III products are exempt.
[Joint Fact Sheet]

Agreements with Switzerland & Liechtenstein
Both countries negotiated similar “no stacking” provisions; Annex III products exempt. Negotiations are expected to conclude in Q1 2026, with one-third of investment commitments completed by the end of 2026.
[Joint Statement] | [Fact Sheet]

Additional Framework Agreements
The U.S. will finalize IEEPA agreements with El Salvador, Argentina, Ecuador, and Guatemala soon. Annex III exemptions apply.
[Fact Sheets]

Agricultural Products from Brazil
Unlike the agreements noted above, CBP announced Brazilian agricultural products exemptions that are retroactively effective on or after 12:01 EST on November 13th.
[Executive Order]

12/1/25: Supreme Court Weighs Legality of IEEPA Tariffs

As we previously noted in a Trade Alert dated September 10, 2025, the Supreme Court continues to weigh the legality of International Emergency Economic Powers Act (IEEPA) tariffs. At this time, IEEPA duties remain in effect until the court arrives at a decision.

What does this mean for your company?

Unfortunately, this is uncharted territory, and we do not yet know the outcome of the IEEPA case, nor how exactly to protect potential refunds, as no guidance on that has been released.

Here are some options to consider:
• Monitor: It is crucial to track transactions and liquidation status where the IEEPA duties have been paid, as well as the amount of IEEPA duties paid.
• Protective Protest: If an entry has liquidated, one option is to submit a formal protest against the liquidation to potentially preserve the right to a refund. Please note that filing the protective protest is not a guarantee of a refund. Some Customs attorneys are advising that importers would have to file an injunction against liquidation to protect any potential IEEPA refunds instead of a protest.
• File a lawsuit with the Court of International Trade (CIT): Importers can file legal action with the CIT to challenge the validity of the IEEPA tariffs.
• Take no action pending the Supreme Court Ruling: The case is now under expedited review by the Supreme Court. Importers can decide to wait and see if the Supreme Court upholds the CAFC ruling before determining a course of action.

It is currently unclear whether refunds will be issued if importers do not take action on the affected entries in the event that the Supreme Court declares these tariffs illegal. We recommend consulting with a trade attorney to determine your company’s best course of action.

11/21/25: Update-Agricultural Products Exempt from Brazil Tariffs (Effective November 13, 2025)

Effective November 13, 2025, 238 HTSUS classifications and 11 additional agricultural product categories are now exempt from tariffs imposed under Executive Order 14323.

Importers should declare heading 9903.01.81 or 9903.01.90 for qualifying goods and maintain supporting documentation. For entries filed since November 13, corrections should be made promptly to avoid refund delays. Post Summary Corrections (PSC) or protests may be filed for unliquidated or liquidated entries.

For details and the full exemption list, see Annex II of the November 20 Executive Order.

11/18/25: New Executive Order Removes Tariffs (Applies to Certain Agricultural Products)

President Trump has issued an Executive Order removing reciprocal tariffs on select agricultural products. This change applies to goods entered for consumption or withdrawn from warehouses as of November 13, 12:01 a.m. ET. Details on affected products are listed in the Executive Order Annex.

U.S. Customs and Border Protection states:

“Filers must ensure that all supporting documentation that substantiates proof of the product’s intended use, where applicable, is kept on file for recordkeeping purposes.”

Additionally, CBP guidance indicates:

“…agricultural products identified as exempt from reciprocal tariffs and that have been entered for consumption or withdrawn from warehouse for consumption on or after 12:01am eastern standard time on November 13, 2025, importers should take action as necessary to correct entries to identify any products that are exempt from reciprocal tariffs pursuant to this amendment as soon as possible. For entries filed within the last 10 days, correct entries within 10 days of the cargo’s release from CBP custody and prior to estimated duties being deposited to avoid needing refunds. For unliquidated entries for which estimated duties have already been deposited, importers may file a post summary correction (PSC) to request a refund. Upon PSC approval, the refund will be issued at liquidation. For liquidated entries, importers may request a refund by filing a protest within 180 days after liquidation...”

We will share updates as they become available. For questions, please contact your Deringer representative.

10/22/25: Proposed 100% Tariffs on China Imports

On October 10, President Trump announced via Truth Social that his administration intends to impose 100% tariffs on all Chinese imports by November 1 or sooner, citing China’s recent export controls on rare earth metals and increased tariffs on U.S. goods. These new tariffs would be applied in addition to existing rates.

The administration also plans to implement new export controls on all critical software for China on the same date.

Separately, the Reciprocal Tariff rate for China was reduced from 125% to 10% on May 12, 2025, effective May 14 through August 12, and has since been extended to November 10.

While these announcements signal significant policy shifts, the scope and timing of implementation remain uncertain. It is not yet clear what, if any, changes will be made to China tariffs, and whether any action will occur on November 1 or November 10.

Deringer is closely monitoring the situation and will provide updates, including any guidance from U.S. Customs and Border Protection (CBP), as available.

10/21/25: New Section 232 Tariffs on Trucks and Buses

Effective November 1, Section 232 tariffs will apply to imported medium- and heavy-duty trucks and buses: 25% on Class 3 to Class 8 trucks and their parts, and 10% on buses. Under USMCA, trucks may receive preferential treatment, with only non-U.S. content subject to the tariff. However, this duty-free status for qualifying parts is temporary.

USMCA-compliant truck parts will remain exempt until the Secretary of Commerce establishes a process to apply tariffs to their non-U.S. content.

Buses are excluded from USMCA benefits and will be fully taxed. Parts from Canada and Mexico may enter duty-free if they meet USMCA origin requirements.

Additional Notes:

U.S. assembled trucks may qualify for a 3.75% Manufacturer’s Suggested Retail Price (MSRP) offset if tariffs were paid on qualifying parts.
Used and remanufactured trucks and buses are subject to the new tariffs only if manufactured within the last 25 years; older vehicles are exempt.
Aluminum and steel from Canada or Mexico may be eligible for a reduced 25% tariff, subject to production limits.

Products subject to tariffs under this proclamation will not be subject to additional or existing sectoral tariffs on steel, aluminum, copper, automobiles and automobile parts, or lumber. They will also be exempt from reciprocal tariffs and those imposed on Canada, Mexico, Brazil, or India.

Read the full proclamation here. If you have questions on how these changes may impact your imports, please contact your Deringer representative.

10/13/25: Section 232 Tariffs on Wood Imports

Effective October 14, 2025, U.S. Customs and Border Protection (CBP) will begin enforcing Section 232 tariffs under Proclamation 10976 on certain timber, lumber, and derivative products. These duties range from 10% to 25% depending on product type and country of origin.

Key Product Categories & Tariff Rates:

Softwood timber and lumber: 10% duty (HTSUS 9903.76.01)
Upholstered wooden furniture (excluding UK, EU, Japan): 25% duty (9903.76.02)
Kitchen cabinets/vanities and parts (excluding UK, EU, Japan): 25% duty (9903.76.03)
The same category of products from UK: 10% duty (9903.76.20)
From Japan or EU: 15% duty (9903.76.21/.22)

Exemptions & Exceptions:

Products subject to automobile-related Section 232 duties are exempt from these timber/lumber tariffs.
Certain IEEPA-related tariffs (Canada, Mexico, Brazil, India) do not apply to goods covered under Proclamation 10976.
Use specific HTSUS headings (e.g., 9903.01.33, 9903.01.83) to claim exemptions from overlapping tariffs.

Foreign Trade Zones & Drawback:

Goods admitted to FTZs must be entered under privileged foreign status.
Drawback claims remain available under 19 C.F.R. Part 190.

Additional Note:

On Truth Social, President Trump announced a 100% tariff on all Chinese imports, set to begin November 1, 2025, in response to China’s new export controls on rare earth minerals. The announcement has not yet been formalized through official channels and remains exclusive to Truth Social posts.

Read the full alert here. For trade remedy questions, visit CBP Trade Remedies or email TradeRemedy@cbp.dhs.gov. For help with your account or filing process, contact your Deringer representative.

10/9/25: Organic Imports Update

Effective October 1, 2025, all certified organic imports into the U.S. must be accompanied by a valid National Organic Program Import Certificate (NOPIC) issued by the exporting certifier prior to shipment. Shipments arriving without a valid NOPIC cannot be reconditioned and must be:

Reexported (with CBP 7512 and Export Booking Confirmation retained)
Donated (only by certified importers, with documentation)
Destroyed (with an official CBP Certificate of Destruction)

Please ensure compliance to avoid delays, penalties, or loss of goods.

For full details and official guidance, please visit the AMS Organics FAQ page.

10/1/25: CBP Remains Operational During Shutdown

U.S. Customs and Border Protection (CBP) has confirmed it is fully operational during the government shutdown. Ports of entry remain staffed and cargo clearance continues as normal. Key updates include:

CBP permits, license exams, and refunds may be affected.
- CBP will process refunds, but issuance depends on the U.S. Treasury. Broker license exams may be affected—CBP is currently reviewing the exam contract. However, all CBP permits are expected to remain unaffected.
ACE support and trade remedy functions remain active.
Partner Government Agencies (PGAs) may be impacted—contact local PGA officials first if issues arise.
- If you are unable to contact your local PGA official, contact your local CBP Officer who may be able to assist with certain PGA issues.
CBP trade webinars may be paused.
FTZ and bonded warehouse activations continue as usual.
Tariff entry guidance for lumber and furniture imports will be ready by Oct. 14.

For questions, contact CBP at tradeevents@cbp.dhs.gov.

Source: NCBFAA

12/18/2025: Increasing Section 232 Duties

This is a reminder that Section 232 duties on certain wood and wood‑based products will increase on January 1, 2026. These changes follow the Administration’s national‑security review of wood product imports. These changes stem from the Presidential Proclamation issued on September 29, 2025, following the Department of Commerce’s determination that current import levels of wood products pose a national security risk.

You may view the Presidential Proclamation here.

Beginning January 1, 2026, the following Section 232 tariff increases will take effect:

Upholstered wooden furniture:

Duty rate increases from 25% to 30%.

Kitchen cabinets, vanities, and parts thereof:

Duty rate increases from 25% to 50%.

These increases follow the initial imposition of Section 232 duties on October 14, 2025, which included:

10% on softwood timber and lumber,
25% on certain upholstered wood products, and
25% on kitchen cabinets and vanities.

WHAT CAN IMPORTERS DO NOW?

Despite the uncertainty of the timing, scope, and duty rates associated with new tariffs, there are strategic steps importers can take to lower risk, mitigate the impacts of new duties, and build a more resilient supply chain. We are here to help you every step of the way. Here are some of our recommendations:

Tariff / Product Engineering

Discover opportunities to legally classify and declare goods under an HTSUS provision to benefit from a lower duty rate.

Tariff engineering refers to design and manufacturing decisions made in such a way that the manufactured goods are classified with the U.S. HTS numbers that carry lower duty rates.

First, verify your U.S. HTS classification numbers to ensure that your products are classified correctly, and that you are not missing an opportunity for a lower duty rate.

Second, explore opportunities to change your product’s design resulting in a different HTS classification and lower duty rate.

Origin Engineering

Origin engineering focuses on sourcing essential inputs from countries not affected by increased tariffs. By altering key manufacturing steps or changing suppliers, businesses can leverage trade agreements and reduce exposure to higher duties. When exploring import options from various countries, numerous factors must be considered. This proactive approach requires careful planning and execution but offers substantial cost savings.

It is also wise to investigate any benefits from existing trade agreements, as these can provide cost savings and smoother operations. Consider any potential changes to logistics costs or capabilities, as these can influence your overall strategy. Finally, examine the regulatory requirements to ensure compliance and avoid legal hurdles.

As you consider these different strategies, keep in mind the dynamic and unpredictable nature of the new environment. For example, countries with lower tariffs today, may not provide the same opportunities in the near future.

Additional Strategies

First Sale Strategy: Explore a possibility of lowering your import duties by using the first sale price instead of subsequent higher prices to determine Customs value and calculate duties.

Here is how it works:

When goods are imported, Customs duties and fees are typically calculated based on the transaction value. In many supply chains, products are sold multiple times before reaching their final destination. Where two or more transactions may qualify as “sales for exportation to the United States”, the First Sale Strategy allows importers to use the price paid in the first sale in the supply chain, often between the manufacturer and the middleman, as the basis for duty calculation. This price is often lower than the price in subsequent transactions, which means lower duties and fees. For a transaction to qualify as the First Sale, it has to satisfy numerous requirements.

To successfully adopt the First Sale Strategy, Deringer customers should work closely with an expert to ensure compliance with all applicable regulations. Additionally, maintaining detailed documentation of all transactions and agreements in the supply chain is crucial.

Value Adjustments: Minimize payments or charges that are not directly related to the production of your goods.

The Trade Agreements Act of 1979 codified at 19 U.S.C. 1401a, sets forth the rules for appraisement of imported merchandise. The Act sets forth six different methods of appraisement, and their order of preference. The Act allows for certain deductions from the appraised value.

At its core, value adjustment is about understanding Customs valuation law, using the correct valuation methodology and lowering the declared value by applying allowable deductions.

Tariffs are typically calculated as a percentage of the declared value of the goods being imported. Therefore, by lowering the Customs value, companies can effectively reduce the amount of tariffs they are obligated to pay.

Making value adjustments requires a thorough understanding of the Customs regulations and guidelines. Engaging in this practice necessitates a detailed analysis of invoices and contracts, ensuring that all deductions are compliant with Customs valuation laws. This strategic foresight not only helps in mitigating tariffs but also ensures that businesses remain compliant with international trade regulations, avoiding potential fines, penalties, or liquidated damages.

Trade Remedy Reviews: Decrease anti-dumping and countervailing duties through administrative reviews, new shipper reviews, or scope rulings. A trade remedy review aims to ensure that these duties remain fair, relevant, and reflective of current market conditions.

Administrative Reviews are periodic assessments that re-evaluate the necessity and rate of existing anti-dumping or countervailing duties. They ensure that the duties correspond to the current level of dumping or subsidization. By participating in an administrative review, companies may demonstrate changes in pricing, cost structures, or market conditions, which could result in a reduction of duties if the original reasons for imposing them have altered.

New Shipper Reviews are tailored for companies that were not originally subject to the duties but have since begun exporting the products in question. By undergoing a new shipper review, these companies can potentially secure a lower duty rate if they can prove that they are not engaged in dumping or benefiting from unfair subsidies.

Scope Rulings determine whether a particular product falls within the scope of an existing trade remedy measure. If a product is found to be outside the scope, it would not be subject to the duties, potentially saving significant costs for the importer or exporter.

By engaging in these reviews, companies can potentially decrease or eliminate the additional costs imposed by trade remedies, thus enhancing their competitiveness in the market. Lowering these duties can significantly reduce the cost of importing goods, translating into savings that can be passed on to consumers or reinvested into the business.

Deferral Tactics: Explore the use of bonded warehouses, Temporary Import Bonds (TIB), or in-bond movements to defer duty payments.

Bonded warehouses operate in a secured area in which imported dutiable merchandise may be stored, manipulated, or undergo manufacturing operations without payment of duty for up to five years from the date of importation. Goods can remain in these warehouses for extended periods, allowing businesses to defer duty payments until the products are withdrawn for sale or distribution. This not only delays the financial outlay, but also provides flexibility in inventory management and market timing.

Transportation Bonds can be used by importers to avoid making entry and paying duties on goods that are merely transporting through the U.S., as long as certain export or bond cancellation timeframes are met.

Temporary Import Bonds (TIBs) are particularly beneficial for businesses importing goods temporarily for specific purposes, such as exhibitions, repairs, or processing. A TIB allows these goods to enter the country without duty payment, provided they are exported or destroyed within a specific timeframe. This approach helps companies avoid unnecessary duty costs on temporary imports.

Effective Advocacy for Tariff Reduction

Advocacy plays a crucial role in influencing trade policies and securing tariff reductions. Engaging with legislative bodies and regulatory agencies through trade organizations, coalitions and formal requests can lead to favorable outcomes.

Advocacy may take the form of becoming champion for the reduction of tariffs and deregulation through strategic measures such as the Miscellaneous Tariff Bill, executive actions, and legislative or agency rulemakings.

Specifically, there is still time for importers to seek Section 301 Exclusions. Out of 312 subheadings in Chapters 84/85, 164 products remain eligible for exclusions until May 2025. To qualify, requests for exclusions must be submitted by March 31, 2025.

Importers may wish to urge the U.S. Trade Representative (USTR) and Congress to reinstate a comprehensive exclusion process. Advocate for the renewal of expired exclusions and the implementation of retroactive applications for these exclusions.

2025 Importers Toolkit

KEEP YOUR GOODS MOVING WITH 2025 IMPORTERS’ TOOLS:

Start with Your Overall Finances

Navigating the financial landscape can be daunting, but understanding a few essentials can make all the difference. First and foremost, prioritize having your financials audited. This step provides a transparent and accurate picture of your financial health, which is crucial for making informed decisions.

We suggest simulating various scenarios to understand the potential financial implications. Consider the direct tariff costs that may arise from different countries and at varying rates. Additionally, factor in associated supply chain expenses, including logistics costs such as transportation, warehousing, and freight forwarding.

It is also essential to account for risks stemming from currency fluctuations and the costs involved in hedging against them. Furthermore, evaluate inventory carrying and storage expenses, as well as the costs related to maintaining quality control and ensuring compliance with regulations. Don't overlook the investments needed for supplier development and technology enhancements, as these can significantly impact your overall financial strategy.

First Order of Business: Establish an ACH Account

Due to the unprecedented scope and scale of the new administration’s potential actions, we are advising our clients to obtain their own automated clearing house (ACH) account to guarantee timely duty payments. There are multiple advantages to ACH payment of duties. The primary benefit is the ability to pay duties directly to U.S. Customs and Border Protection (CBP). Obtaining an ACH account will also permit you to take advantage of periodic monthly statement (PMS) procedures, which allows payment of duties on a monthly basis.

Learn how to obtain an ACH Account

01Avoid Delays, Apply for ACH

Establish an ACH Account as soon as possible so that your duty payments are recorded in time.

02Take the First Steps to Compliant Trade in 2025

Download our New Trade Landscape Tariff Tip Sheet and proactively prepare for what's ahead.

03Use Our eShipPartner® Trade Remedy Tool

Log in to our Analytics tool and begin to estimate possible tariff/duty rates. Learn how to use our Trade Remedy Tool & Amounts Due Tool.

04Check Your Bonds

Use this Bond Calculator from our friends at Roanoke to verify your bond limits are sufficient.

05Join Our Webinars

06Sign Up for Our Trade Alerts

Receive notifications of policy and regulatory changes, guidelines, and developments in international trade. Sign up here.

07Duty Defense Strategies

View strategies created by Deringer's Trade Advisory Group to help you reduce duty exposure amidst tariffs.

What is Bond Saturation?

Generally speaking, continuous Customs bonds are financial guarantees to the U.S. Government and indicate a commitment to comply with U.S. import laws. Importers typically purchase these bonds from specialized insurance companies through their Customs broker. Bonds are required to import to the United States, and are based on the importer’s estimated annual duty, taxes and fees due the U.S. Government. U.S. Customs monitors the size of your bond against your import trends, and will cancel your bond if the limit is exceeded – it becomes ‘saturated’ relative to import trends/activity. If the bond is canceled, imports will not continue – until such time as a new bond is in place.

Deringer anticipates that many importers’ bonds will saturate quickly if the new proposed tariffs are imposed. If an importer’s bond becomes saturated, there is the risk of that CBP may terminate the bond. Without a valid bond in place, imports may not proceed until such time as a new bond is in place. In addition, importers may experience underwriting delays from sureties, due to the high volume of bonds that will saturate. We strongly recommend that importers proactively review their bond limits now.

Securing a sufficient Customs bond is a critical consideration. Proactively increasing bonds when necessary ensures you are prepared for duty increases and avoid delays at the border.

Determine Your Bond Needs

U.S. Customs and Border Protection (CBP) reviews the sufficiency of continuous bonds on a monthly basis. The bond amount is calculated as 10% of the total duties, fees and taxes paid in the last 12 months. With the anticipated increases in tariffs, it is critical to calculate your bond amount based on the projected amount of duties and fees rather than on prior duty amounts. Failing to make accurate projections and securing an adequate bond amount can have serious consequences including the inability to import into the United States.

Start by anticipating Customs duties and fees you expect to pay in the next 12 months. This includes all duties and fees such as AD/CVD and tariffs under Sections 201, 232, and 301.

Once you determine the amount of coverage required by your bond (remember 10% of taxes duties and fees for the next 12 months) you should understand the Rounding Process:
- For duties and fees ranging from $0 to $1,000,000, your bond amount is rounded up to the nearest $10,000 (note that the minimum Customs bond starts at $50,000).
- For duties and fees exceeding $1,000,000, the bond amount is rounded up to the nearest $100,000.

For example: assuming that an importer currently has a $50,000 bond because in the past their goods have been duty free under a trade agreement. The importer calculates that over the last year they have imported $3,500,000 into the United States. Anticipating additional duties of 25%, this could result in a future duty outlay of $875,000. To calculate the proper bond amount, 10% of the anticipated duties would be $87,500 - and with the bond rounding rules – this results in a $90,000 Customs entry bond.

Comprehensive Coverage

Incorporate All Payments: Your calculations should include all paid and payable duties, and dutiable government fees, ensuring no detail is overlooked.
Handle Outstanding Bills: Calculate 10% for unpaid or protested bills under 210 days.
- For delinquent bills over 210 days or denied protests, factor in the full amount.
Include Unpaid Debit Vouchers: Ensure every aspect of your financial obligations is covered.

We recommend that you use the most recent version of your entry data, guaranteeing up-to-date calculations.

Bond Usage Review

We recommend that all importers proactively review their bond level and forecast if and when their bond may saturate. Waiting for CBP to issue a mandated increase will limit the time to react/obtain a new, larger import bond, so we strongly recommend action as soon as possible. If you believe your company’s import bond may be insufficient, we suggest completing a new import bond application and returning it to us (BondDept@anderinger.com) for processing. (Please note that it is possible that we (and other sureties) will receive a high volume of applications, another reason we recommend importers start now.)

Bond Sufficiency Report

Should Deringer bond clients find they are suddenly paying significant amounts of duties, taxes and fees to U.S. Customs and would like to get a snap shot of their current bond sufficiency, they can contact us at BondDept@anderinger.com and request a bond sufficiency summary report. When doing so, please provide your company’s name and account number.

Financial statements may be required for underwriter review on any bond, but very likely for new import bonds valued at $400,000 or more. When financial statements are required, the underwriters are looking for the importer’s latest complete, year-end financial statement:

A year-end financial statement is defined as a 12-month CPA prepared statement which includes, Statement of Income, Balance Sheet, and Statement of Cash Flows and accompanying notes. If the statement is not CPA prepared, the underwriters will require it to be signed by an officer of the company attesting to its accuracy. If the financial statements are not already in English, an English translation must accompany the original version. Also, if the financial statement is over a year old, the underwriters will require additional information.

Termination and Replacement Import Bonds

Importers should be aware that there may be a collateral requirement when terminating/replacing existing bonds. It may take banks up to 30 days to issue a letter of credit (LC) once it has received all of the required information. Should collateral be required by the underwriters to secure the new import bond, it will likely be required to be issued for the face value of the new bond and the underwriters will release the required LC format for processing once the importer has provided the name and address of the U.S. bank they wish to use.

If a General Indemnity Agreement (GIA) is required by the underwriters, the GIA will need to be sign by one of the importer’s officers (CEO/CFO) and witnessed by another party (the witness does not need to be an officer of the corporation).

If a Collateral Release Policy (CRP) is required, it can either be physically signed by a corporate officer (CEO/CFO) or if the importer would prefer sent via DocuSign to the officer who signed the GIA. It is important that if collateral is required that the importer maintain a copy of the signed CRP as it details what must occur before the underwriters will agree to release the collateral at a later date.

Underwriter Requirements

Given the anticipated volume of mandated increased notices, Deringer anticipates delays in underwriter reviews/processing times. It is extremely important that the importer provide all the required information/completed documents as soon as possible in a legible complete format, including:

financial statements,
ADD/CVD forms,
non-reimbursement statements,
requests for entry summary copies,
collateral requirements,
General Indemnity Agreement (GIA) requirements,
Collateral Release Policy requirements (CRP), etc.

If the information provided is incomplete, provided in a foreign language (without an accompanying English translation), or not legible, then the underwriters will need to reject the information provided pending receipt of complete, legible information they can review/process.

CBP Insufficiency Notices

If the importer should receive an insufficiency notice from CBP before we have contacted them, the importer should reach out to us (BondDept@anderinger.com) with a copy of the notice they received immediately. While CBP tends to review/issue insufficiency notices early each month, a CBP insufficiency review can occur anytime. The deadlines for actions are detailed in the CBP notice and it is imperative that they are followed or the current bond will be rendered insufficient immediately by CBP and trigger a lapse in bond coverage. It is important to note that CBP insufficiency will not remove the requirement that the current import bond be terminated and replaced with a new import bond. Nor does a CBP insufficiency flag speed up the minimum 16 day term/release process.

We know import bonds are a complex and important topic. Feel free to review our recorded webinar series (part 1 and part 2) that provides bond considerations in detail.

Mexico

Vehicles other than railway, tramway. Examples: Passenger cars and trucks
Electrical, electronic equipment. Examples: TV receivers, electric heaters
Machinery, nuclear reactors, boilers. Examples: Air conditioners, refrigerators
Mineral fuels, oils, distillation products. Examples: Cigarette lighters, charcoal
Optical, photo, technical, medical apparatus. Examples: Surgical instruments, orthopedic equipment, hearing aids

The New Trade Landscape 2025

Priority Actions for Customers

Looking for forms to help you navigate the new tariffs?

Stay Informed: Tariff Updates Continue

Section 232: Aluminum and Steel Import Resources

Trade Alerts Recap

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WHAT CAN IMPORTERS DO NOW?

Tariff / Product Engineering

Origin Engineering

Additional Strategies

Effective Advocacy for Tariff Reduction

CBP Provided FAQs & Guidance

KEEP YOUR GOODS MOVING WITH 2025 IMPORTERS’ TOOLS:

Start with Your Overall Finances

First Order of Business: Establish an ACH Account

DON'T FORGET ABOUT YOUR BONDS

What is Bond Saturation?

Determine Your Bond Needs

Comprehensive Coverage

Bond Usage Review

Bond Sufficiency Report

Termination and Replacement Import Bonds

Underwriter Requirements

CBP Insufficiency Notices

TOP 5 U.S. IMPORTS FROM MEXICO, CANADA, AND CHINA

Mexico

Canada

China

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