[Cindy’s Version]: The Life of a Trade Girl

Machine Operated Script:

Cindy Allen  00:02

Taylor Hello. Today is October 3, 2025 it’s a huge day in the Swifties world. Taylor Swift released her new album The life of a show girl this morning. Was I one of the Swifties who woke up at midnight to listen to my already downloaded album playlist, no, but did I open it up immediately when I woke up at six o’clock and start playing and listening to her new music? Yes, I did. I’m Cindy Allen. I’m CEO of trade force multiplier and international trade consultancy firm. Welcome to simply trade Cindy’s version, where I base a international trade update on a Taylor Swift song, and I come to you in association with global Training Center. So today we’re not going to focus on a song. We’re going to focus on the album, the life of a show girl, or in this case, the life of a trade girl, because that’s what I am today. I have all of my orange life of a show girl color and all of my bling on for the trade girl podcast today. So and I also have the big hair brought me back to my 1980s teenage days where we used to make our hair as big as possible, not actually as easy as it used to be, because they did take the fluorocarbons out of the hairspray. So we can’t make our hair as big as we used to. So my apologies, and I couldn’t find my tiara because I was going to wear that today, in solidarity with all the Swifties who are blinging out in orange today. So what’s going on this week? So we have the it’s showtime. We have another shutdown. We haven’t had a shutdown since the first Trump administration, and this is the day three of the trade shut down on the first October 1, CBP hosted a webinar for the trade that was broadly participated in over 1000 participants called in where CBP was adamant that it was normal times they were at work, in force. They struggled to identify any area where the trade, or trade processing, or passenger processing would be affected, leading us to believe that very few of the CBP staff were actually were actually for furloughed. This is a significant change from times past, where up to half of CBP was actually furloughed and only the most essential personnel were actually at work, and that would be the guys in the blue shirts, the guys in the green shirts, the cbpo officers and then Border Patrol and a lot of the Office of trade functions were not considered essential, and so they were not at work. But times have changed, and almost all of DHS was considered essential, and have showed up to work. So we do not expect any delays in processing, any delays in clearance, any delays in any normal trade function, any outreach that you have with the centers, any communications all of the trade processes will likely flow. There were a few exceptions. Paper checks may be impacted because of Treasury. Those are actually issued by US Treasury, and even though they have a very broad set of individuals who are at work, there was some confusion to whether that would impact the check processing moving forward. The other area of concern is the other government agencies, if you have goods that are subject to FDA, USDA, EPA, D, o, t, all of those other government agencies, it was unknown at that time how they would process freight at the border, but more importantly, how they would address exams. We believe that freight at the border isn’t going to be stopped. However, if there is an exam required, there was still some uncertainty of how that would be handled. We’ve since learned that a lot of the agencies do have inspection staff that will remain through the shutdown, but we do expect some delays in that area. So what are some of the other shiny new things that are going on today in the in the world of show business? Well, we have a section 232,

Cindy Allen  04:07

investigation that is turned into duties, and that will take effect on October 14. And that is for lumber. It is for kitchen cabinets. It is for vanities. There is a yet another tariff annex that we have to comb through and correlate to all of the chapter 99 numbers that are afflicted and impacted by these section 232 duties. But that is a shiny new thing that has come out. What caused a lot of consternation last weekend was an announcement by the president that there would be section 232 duties on pharmaceuticals as well. To date, as of this morning, October 3, we have not received any additional information about the section 232, is on pharmaceuticals. There have been a few articles in the trade press indicating that the administration is. Attempting to negotiate with pharmaceutical companies and ensure that they do bring manufacturing back to the US as a national security issue, and to encourage that, they have delayed the section 232, duties on pharmaceuticals that not only covers pharmaceuticals, it also covers medical devices and some other medical equipment that is going to be impacted. We haven’t seen the tariff numbers. We haven’t seen the annexes. We don’t know what’s included, what’s not included. We do know from some of the press releases that if a pharmaceutical company has broken ground on manufacturing facilities in the US, they will be exempted from the proposed 100% duties on pharmaceuticals. We don’t know how companies will be tagged as that. We don’t know if there will be a list of companies. We don’t know if companies that already have manufacturing facilities here, or that are US based companies like Eli Lilly will be exempt from the tariffs for goods that they’re bringing in. We also know that this is only for name brands, name brand pharmaceuticals. So companies that import pharmaceuticals are going to have to start making a distinction between generics and name brand articles so that they do not pay duties on the generic brands. I think there was some surprise to learn that Ireland and Switzerland are going to be some of the most affected areas in of importing because Ireland actually has the largest prescription selling drug in the world. That’s Keytruda, as I mentioned on the last podcast. So we are waiting to see how that is going to be impacted. Like the rest of you, we’re awaiting the details of what the new shiny thing is going to look like. So today, I wanted to focus I haven’t learned all of the lyrics from all of the songs yet or understood the implications, but I do know one of the songs on the new album, The Life of show girl, is called Elizabeth Taylor, and one of the lyrics that stood out to me today is, oftentimes, it doesn’t feel so great to be me. And I know I talked a little bit about this, the trade professionals that are continuing to muddle our way through how to apply the duties correctly, and what is exempted, what has layering tariffs? What is, what is just one tariff, what is all 10 of them? It seems like that are out. And I would say that sometimes it doesn’t feel so great to be a trade a trade person. We also noted that this week that CBP and ICE and HSI have indicated that they are increasing enforcement to ensure that the correct amount of duties are paid. We’ve also heard some rumblings from importers that some customs workers are not applying the duties correctly. They’re getting valuations incorrect. And I resonated with that lyric. Sometimes it doesn’t feel so great to be me, because we have very little guidance right now, but we have very little in writing that specifically looks at how layers of duties are determined. I spoke with an association earlier this week who were trying to understand new duties that would be applied to their goods and how that would be impacted. And one of the questions that I loved was, well, if I make a country of origin determination, is that going to be the same for all of the duties? And alas, it’s not. We know that country of origin determinations when we’re looking at goods that are imported into the United States, there’s a country of origin determination. It’s made here. There was a substantial transformation. Here’s how that article was made. There’s lots of rulings on country of origin determinations and how things have to be marked when it comes into the United States. However, what we know now is that that country of origin determination doesn’t necessarily apply to a free trade agreement. Some free trade agreements require you to go through a qualifying step that has to do with the country of origin. So the country of origin may be the same, but to qualify for that free trade agreement, you have to make a different type of determination, and sometimes that does impact how the country of origin is reported on the entry, then you have country of origin determinations, including how US goods that are incorporated into an article may or may not allow that us good to be or portion of that us good to be exempted from some of the 232 duties that has made. That means we have to make a third determination of country of origin or applicability for Section 232 duties. And if you have different section 230 Two duties, and they were released at different times. They may not have the same exact language. So now we may have to make four or five determinations. Is this the same country of origin for reporting purposes, especially when you’re looking at aluminum and steel. So if you have aluminum and steel, and let’s say you have two different country of origins in the steel that are imported in your article, and three different aluminum country of origins. And it’s a downstream product. It has aluminum and steel in it, but it isn’t a slab of steel or roll of aluminum coming in. It’s something made with those two not only do you have to determine where that good last underwent a substantial transformation for your normal HTS, and if there’s a substantial transformation that may or may not have made it applicable for usmca, you have to determine what this country of origin for each of those articles of the steel, those two different countries of origin, and list the mill where that steel was actually produced on the entry. And then the same thing for the aluminum, you have to know where it was port or cast. You have to know any processing, and that has to be reported three different times, because you have three different countries of origin. So sometimes that’s very difficult for us to determine. And as customs brokers, this is our expertise, we eventually figure it out. Many of us have massive spreadsheets layering on which 99 number applies in what circumstance, if you have one, does it exempt you from another? Because some of them, especially in the automotive world, or if you qualify for usmca, you have different numbers and different circumstances where something may apply or something may not apply based on whether you qualify for usmca. So all of these processes are extremely confusing, and imagine trying to explain that to a new importer who has just ordered a bunch of machinery from Europe and is trying to determine how much duty am I going to pay? And before where we could get out our Tariff book, look up that number, give them a duty rate and say, may or may not be subject to anti dumping duty. Now we have to do all of the research and read each section, 232, applicability, and understand if that good actually qualified. So oftentimes it doesn’t feel so great to be me, and that’s really the life of a trade girl. We’ll see you next week.