[Cindy's Version] Everything Has Changed

This week on Simply Trade: Cindy’s Version, Cindy Allen unpacks a dramatic shift in global trade policy—one that touches everything from tariff reductions to new exemptions and unexpected reversals. Inspired by Taylor Swift’s Everything Has Changed, Cindy explains how seemingly overnight, the trade landscape has transformed in ways that directly impact importers, customs brokers, and compliance professionals.

From significant tariff rollbacks for China and Europe to new carve-outs for select products, Cindy walks through the week’s biggest developments and breaks down what’s real, what’s promised, and what’s still uncertain. In a moment where policies shift faster than supply chains can adapt, this episode brings clarity to the change—and perspective to the pace of it all.

This Week in Trade

• The administration announces a 10% reduction in tariffs on Chinese goods, including items previously subject to Section 301 duties
• European-origin goods also receive reductions, with guidance forthcoming
• CBP releases clarification on how these reductions apply operationally
• Importers await confirmation on whether refunds will be automatic or require PSCs or protests
• Supply chains begin recalibrating landed cost models and forecasting impacts

New Trade Developments

• China signals cooperation by easing rare earth export controls and increasing U.S. agricultural imports
• The EU indicates interest in parallel reductions if the U.S. maintains consistency
• Treasury and USTR state reductions are prospective, while refund policy remains under review
• Early reduction categories include selected machinery, metals, and electronics
• CBP urges importers to verify HTS classifications to ensure correct duty application

Why This Feels Like “Everything Has Changed”

Cindy highlights how quickly and massively the trade environment has shifted in just a few days. Overnight tariff reductions require importers to revisit landed costs, adjust contracts, notify customers, and reevaluate sourcing strategies. Customs brokers must reconfigure systems, classification profiles, and compliance workflows while fielding urgent questions from clients looking for immediate clarity. And with refund policy still unknown, teams must prepare for multiple scenarios, even as new developments continue to unfold. The cumulative effect: everything truly feels like it changed all at once.

RESOURCES & MENTIONS

• Global Training Center
• TradeForce Multiplier

Credits

Host:
• Cindy Allen – LinkedIn
• Trade Force Multiplier

Producer:
• Lalo Solorzano – LinkedIn

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Machine Operated Script:

Cindy Allen (00:05)
Hello, today is Friday, November 21st. I’m Cindy Allen. I am CEO of TradeForce Multiplier, a global trade consultancy services. Welcome to Simply Trade Cindy’s version where I base an international trade update on a Taylor Swift song. This podcast is also brought to you in association with the Global Training Center. Today’s song is Everything Has Changed and we’ll get to the reason for that in a moment. But first,

what has happened in international trade this week. It’s been a little bit of a busy week, although no major trade announcements. The biggest thing that happened, I think, is that the administration announced that 40 % on food from Brazil has now been added to Annex II, which means that that is no longer required to be paid. All food…

There’s been a little bit more expanded food products mostly from Central and South America and depending on what side of the aisle you sit on if you’re on the administration side you’re saying that this is a sign that these tariffs are working that it’s forcing trade deals to be made and that as a result of that they can alleviate some of the tariff

Payments and pressures if you’re on the other side of the aisle you’re saying there’s a recognition that costs have gone up and that inflationary conditions exist and that this has had a negative effect on the consumers in the United States and a need to lower prices in the United States so Whatever side you’re on the end result is lower food prices just in time for the holidays. So I think that’s a win for everyone

CBP also has announced a major expansion of the Air Cargo Advanced Screening or the ACAS data. This is not unexpected. ACAS data submissions have been changed over the years. However, there’s expected to be a big data flow impact on this. This is going to have additional costs. It’s expected to have an impact of over $100 million.

based on some estimates in the Air Forwarding Association as well as in the Air Carrier Association. This will require additional consignee information, specifically contact information, phone and email addresses are gonna be required for consignees. Now it was a conditional field before, but now it’s gonna be required. Also where the goods were picked up, packed or collected is gonna be required. Those are the mandatory data elements

Among the conditional data elements, meaning that under some conditions it will be required or it will be optional, is the shipper’s contact information, so their email address, their phone number, as well as account details. Who’s paying for that shipment? Their contact information and the account information from the person filing the ACAS data. That’s going to be really hard if you are a downstream ACAS data filer and you don’t have that direct

direct account holder information. So I believe that’s why it’s conditional, but we can expect to see CBP wanting to see that information. Also, the device IP address of where the order was placed, if it was placed online, or the customer that arranged for the transportation, that’s not necessarily collected outside of an online environment. In an online environment,

there is a lot of data that’s collected. Not all of it is kept and certainly it’s not in a format that can usually be filed along with the transportation data. So I expect that piece of data to be challenging to transmit on the flow through results. So if you are ordering something online, expect that your IP address is gonna be collected and possibly filed with the US government and…

I don’t think that that’s such a big deal. think Amazon has my IP address anyway, as well some of the other major online retailers. They do believe that this is going to result in higher IT costs, course, higher costs to validate the information that they are receiving, higher costs to do accuracy checks and audit checks to make sure that what you filed and collected is accurate.

And that might be challenging because you may not have an ability to actually verify that information is accurate. I mean, if somebody gives you a dummy email address, how are you going to know as a freight forwarder filing that information? Also, it’s going to cause workflow redesigns and disruptions if you have to collect that information now and then include it in your transmission with your what is essentially manifest data. Is that going to cause

some disruptions, it’s going to cause some redesign of that information. And also, how do you expand that data collection when you’re taking that order in? That upfront customer impact is going to be noted as well. On top of this, TSA recently published a change to its security protocols as well. It’s asking for comments. The National Customs Brokers and Forwarders Association is spearheading an effort

to file comments along with the Air Forwarders Association to understand how that’s going to impact the security information all the way through. So these are both very security-related activities. So we’re seeing security becoming even more tight. As well, CTPAT is now open to 3PLs in a pilot environment.

also security related focus. But the three PLs have been clamoring, not necessarily clamoring, but they have been requesting to participate in this. And really it’s a link in the supply chain that CBP had no visibility to. So all of those security related activities, if you are interested, there is a federal register notice out that you can check to see if you want to participate.

News is also reporting that the semiconductor section 232s may be delayed and it’s likely to avoid angering China right now when we’re in the middle of those discussions with them trying to move forward trade agreements with China that benefit the US and although this is not an official announcement there is a lot of chatter in DC about semiconductors being

being delayed. This is on top of the pharmaceutical section 232 not being announced formally or yet put in place. The investigation has concluded but we’ve seen a rash of announcements from pharmaceutical companies that have made trade deals directly with the administration to avoid those section 232 duties on pharmaceuticals and we haven’t seen that rolled out yet. So it’ll be interesting to see how these

Section 232 investigations continue forward and if the industries that are going to be impacted have an ability to influence the timing in the amount of Section 232s going forward. As well, I listened or read about a House Small Business Committee that was actually held in the last few days.

It had mixed testimony. was on the impact of tariffs on the small businesses specifically. There were some, those who testified indicated that the exporters have eaten all of the tariff costs. So it had low to no impact on them moving forward. This is not the normal situation, however. Some indicated that the volatility was the major issue, understanding how to project for sales and costs.

have been extremely difficult. Some small manufacturers indicated that they didn’t know from week to week if there was gonna be no tariff, if it was gonna be 15, 20, 15, 25 or 30 or 50 % and that volatility has cost them business, especially as they have limited ability or no ability to change pricing once a contract has been signed.

And when you’re talking about heavy duty manufacturing, contracts are signed sometimes years in advance. So it’s very hard for these companies to affect the pricing on those contracts. And when you have a tariff of 25%, that eats directly into the profit margins of these small companies. One that was focused on steel and aluminum specifically said that it had almost eliminated some of the

profit margins moving forward and had severely impacted their ability to move forward. Small manufacturing is down. We do know that. We see that in all of the reports that manufacturing is down specifically on the small and medium businesses. The machinery shops have specifically been impacted because of the steel and aluminum tariffs as well as the other tariffs on heavy machinery coming in.

that assist them in their processes. I do recommend that if you are a small business or want to understand to actually go to the house website and look for readouts and possibly a recording of the hearing. It was very interesting to see the different points of view from the different manufacturers in all of the industries. So everything has changed from the Red album.

Why are we focusing on this? The song itself has a chorus that says, I just want to know you better, know you better, know you better now. And a few weeks ago, I talked about customs issuing 20, it’s in 29 and how they seem to be focused more on getting information from an enforcement perspective. And I think some recent examples of that have indicated that customs wants to know your supply chain better. They want to get to know you better.

They have the information, they have the systems to do that. I think this is particularly interesting when you look at a new video from CBP that was recently published. I saw it on LinkedIn, I’m sure it’s out there in all different kinds of forms, but it is the executive assistant commissioners from the Office of Field Operations, Diane Sabatino, and the Office of Trade, Susan Thomas, and they are focused on ensuring that trade is lawful.

and that they are focused on eliminating fraud and evasion of duties, specifically some of the trade remedy duties that are out. And I think this just underscores the entire focus that CBP has now. They have renewed their focus and even come out even more clear that their mission is to identify areas of concern.

specifically those trade remedy actions and they are working to ensure that they have the tools necessary to do that. So what does this mean for you as importers, as customs brokers? Well, you’re going to have to beef up your audit processes. Companies that don’t have an audit process are going to be seen to be not exercising responsible care and supervision if you’re a customs broker or reasonable care if you’re an importer.

You need to know your supply chain from the CTPAT and the security perspective. This is as we’ve seen these recent types of actions are going to be really important for you to know that supply chain, the physical movement of goods, and also know your value chain. Who are you doing business with? Who are you actually buying your goods from? Are they valued correctly? Are they giving you the right information that is

that you’re using to make your determinations and your classifications moving forward. Do you have enough information about the origins of those products? As we’ve talked about before, AI analysis tools are very prevalent in CBP and they’re using them even more now. They’re continuing to invest in additional tools. We’ve seen lots of reports of conversations of CBP.

enhancing their capabilities and signing contracts with software firms that have the ability to give them the information and the analysis on that vast amount of ACE data that they’ve had over the past 30 years. So there is an expectation by CBP that you’re going to do that as well, that you are going to have that focus. The specific focus I think is on HTS classification.

It’s on application of the trade remedies. Have you applied the right tariffs in the right manner and paid the right amount of duty? And remember, ACE doesn’t have edit checks. So customs brokers have to rely on their systems to properly file these very complex, very, duty rates that have no ability to be edit checked other than your own understanding.

And NCBFAA, the National Customs Brokers Association, has given its members some tools to help them with that. But it is very much a manual process right now because these systems are still being developed both on custom side and some of the software that customs brokers use. Also of concern is valuation. Is the value of the good correct? This is not just true in the…

the elimination of de minimis where CBP is focusing on what I believe is their renewed focus on eliminating cheap Chinese goods from coming into the United States. They thought that eliminating de minimis would have a bigger impact and it hasn’t. People are still ordering online. They’re still ordering goods coming in in the e-commerce environment. Although some of the volumes on that

is down from an air perspective, we are seeing continued orders from that into the United States. So that has created an environment where CBP wants to make sure that the valuation of those goods are correct. And we’re seeing that across not just the e-commerce areas, but also companies who are resellers in the United States and ordering in bulk. So shore up your valuation, make sure you have visibility and can

that from an audit perspective that those goods are valued accurately. And the last is country of origin. Really, CBP wants to make sure that there’s no true transshipment of goods. And these are where you source goods from, let’s say, China and bring it into Vietnam and are not doing any manufacturing processes to it, are not transforming it in any way, but merely relabeling it. That is the true definition of transshipment.

CBP wants to make sure that there are no instances of that in the supply chain. To do that, they have to ask some pretty pointed questions and ask for manufacturing records going back for the country of origin that you’ve determined. So if you’re a compliant importer, you want to make sure that you have that information available to you.

Submit to CBP if there is a request and that you’re doing your due diligence upfront and exercising that reasonable care in making sure that those country of origin processes are moving forward. Also very, very concerning is the component level tariffs. We have to know what the component level country of origin and valuation are.

So specifically for steel and aluminum and some of the automotive, you have to know where that component was produced. And to know that, you have to know the downstream supply chain. So again, CBP has some of these tools. They have the mapping tools that make that information available to them. So they want to make sure that you have the available opportunity to do that. just know there is a renewed focus at CBP on this. And they just…

want to know you better. For those of you listening in the United States, I want to wish everyone a happy Thanksgiving. I hope it is surrounded by family and friends and that you have full bellies at the end of the day. And with that, we’ll talk to you next week.