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Supply Chain Updates—March 20, 2025 Newsletter

March 20, 2025

CUSTOMER TARIFF ADVISORY: Updates on Steel & Aluminum Import Duties

As of March 12, 2025, U.S. Customs and Border Protection (CBP) has implemented updated Section 232 tariffs on aluminum and steel imports. A 25% duty now applies to most products, with specific tariff classifications under HTS codes. Russian-origin materials remain subject to a 200% duty. Importers must comply with new reporting requirements, including smelt, cast, and melt data. Exclusions and quotas expired on March 11, 2025, and Foreign Trade Zone entries now require “privileged foreign status.” Full compliance is expected to avoid enforcement actions. Contact us for assistance with import strategies and compliance requirements.

Compliance Tips for Importers:

  • Verify HTS classifications and duty rates before shipping.
  • Ensure accurate reporting of smelt, cast, and melt data for steel and aluminum.
  • Check exclusion validity if your product qualifies under an importer-specific exclusion.
  • File quota entries on time to avoid delays or rejections.

Need help? Read our updated tariff fact sheet or contact our team for guidance on compliance and import strategies.

Importers of goods subject to tariffs on steel and aluminum products (Section 232), Chinese-origin goods (Section 301), and sanctions-driven trade restrictions (IEEPA) should reassess their projected import values and 12-month average duty liabilities to ensure adequate bond coverage. Since customs bonds are set at 10% of annual duties, any importer expecting to exceed $500,000 in duties and tariffs should consider increasing their bond beyond the standard $50,000 minimum to avoid compliance issues. Please consult with our customs brokers to prevent supply chain disruptions due to insufficient bond coverage as regulatory reviews and renewals increase.

The International Longshoremen’s Association (ILA) and the United States Maritime Alliance (USMX) have finalized a historic six-year contract, granting union members a 62% wage increase and job protections against automation. This agreement, following a brief strike in October 2024, ensures labor stability across East and Gulf Coast ports, balancing technological advancements with workforce security.

The recent fluctuations in trade policies, including the imposition of tariffs on major trading partners, have introduced significant uncertainty in supply chain planning. This environment necessitates agility and proactive strategies to mitigate potential disruptions.

The fashion industry’s commitment to sustainability is being tested by rising tariffs and geopolitical tensions.Brands are encouraged to maintain their environmental and social initiatives despite these challenges to protect their reputation and ensure long-term viability.

Blank sailings on the Europe to North America trade lane are decreasing, leading to more stable capacity, with most carriers having postponed the March Peak Season Surcharge (PSS) to April. However, European ports are facing increasing congestion due to a surge in Chinese exports, winter storms, and ongoing labor disputes in Rotterdam, France, and Antwerp, impacting vessel schedules and port operations.

Companies are increasingly adopting artificial intelligence and machine learning to achieve real-time visibility across their supply chains. These technologies enable proactive management of disruptions and optimization of operations, leading to more resilient logistics networks. With our ATLAS visibility platform, you can gain real-time tracking, predictive analytics, and actionable insights to keep your shipments on track and your supply chain running smoothly. Learn more about ATLAS here.

The UK’s logistics landscape is evolving with the introduction of high-speed rail freight services, offering faster and more sustainable alternatives to traditional trucking. Companies are repurposing decommissioned passenger trains to transport essential goods, such as food and medical supplies, at speeds up to 100 mph, with current routes operating between Birmingham and Glasgow and plans to expand to London.

Tariff Updates & Trade Compliance Updates 
  • CBP (U.S. Customs and Border Protection) is moving fully electronic: After nearly 28 years of issuing paper checks, CBP will transition all refunds to electronic payments beginning February 6, 2026, with only limited exceptions.
  • Act Now to Avoid Delays: With a short window to prepare, importers should act now to prevent disruptions to duty drawback claims, Post Summary Corrections (PSC), and other post-entry refunds. Importers already enrolled in the electronic refund program should review their setup to ensure payments are received without interruption.
  • Supreme Court Update – Value of Services (VOS) Selections: While no decision has been issued, importers may want to prepare for potential changes. If favorable, IEEPA tariffs could no longer apply, though refunds would require documentation and follow-up. Keeping detailed records and ensuring electronic refund information is current can help you stay ready.
Helpful U.S. Customs and Border Protection (CBP) Resources to Get Started:
  • CBP Trade Portal Account: Use this portal to manage your trade account, update company information, and oversee electronic transactions with CBP. This is the primary platform for maintaining refund eligibility.
  • Modernized Automated Commercial Environment (ACE) Importer Account ApplicationThis application allows importers to establish or update their trade account, a required step for enrolling in electronic refund payments.
  • Automated Clearing House (ACH) Refund Enrollment Guidance: U.S. Customs and Border Protection’s official guidance explains how to enroll in ACH for electronic refunds, including key requirements, timelines, and system updates importers should be aware of.
How Imperative Logistics Can Support You:
  • Electronic Refund Readiness: We provide guidance to help ensure your trade portal access and ACH electronic payment setup are ready for CBP’s new electronic refund process. The trade portal is U.S. Customs and Border Protection’s online system for managing import and export activity, while ACH is the banking network used to receive refunds electronically.
  • Refund & Post-Entry Guidance: Our team can help clarify how to track refunds and manage post-entry processes under CBP’s updated electronic-only refund requirements.
  • Third-Party Authorization Support: For importers who work with brokers or other third parties, we provide guidance on properly designating authorized parties under CBP rules.
  • Keeping You Informed: We monitor CBP notices, Federal Register updates, and regulatory trends, turning complex information into clear, actionable guidance so your business can stay compliant and prepared.

Have questions about how these tariff changes affect your shipments? Our team of experts is ready to provide guidance, please Contact Us anytime. For further details, please consult the latest Tariff Update and Reciprocal Tariff List for comprehensive information.

View the latest Tariff Information:

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