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New Tariffs Causing Insufficient Bonds

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U.S. Customs Border and Protection (CBP) recognizes that Section 232 and 301 tariffs are having a significant impact on continuous bond amounts and expect to see an increase in insufficient bonds in the coming months. In the meantime, CBP is urging importers, brokers, and sureties to be mindful when determining bond sufficiency based on Section 232 and 301 tariffs.

How Bonds are Being Impacted

Continuous bonds—for dutiable goods that are not subject to a participating government agency (PGA)—are normally based on 10% of the projected amount of duties, taxes, and fees that an importer is expected to pay over a 12-month period. This means, a company’s predetermined bond may now be insufficient due to duty increases related to the new tariffs. One steel importer stated they had a bond that went from $200,000 to $11 million, according to the JOC.

To assist brokers, sureties, and importers, CBP will be sending an email—to each surety—to discuss helping them with their long-term projections, to ensure importers will be sufficiently bonded for the 12-month period.

Insufficient bonds can hamper an importer’s ability to release their cargo at U.S. ports and cause them to incur demurrage, because CBP can hold shipments that have an insufficient bond.

This bond issue is expected to escalate as importers across a range of sectors determine whether the additional $200 billion in tariffs from China affect their goods. It is crucial to make sure your company has sufficient Customs bonds in place. If you need assistance, contact Mohawk Global Trade Advisors.



CTPAT – To Participate or not to Participate


Is your company still on the fence about participating in Customs Trade Partnership Against Terrorism (CTPAT)?

Are these benefits not enticing enough?

  • less CBP examinations
  • front of the line inspections
  • possible exemption from Stratified Exams
  • shorter wait times at the border
  • assignment of a Supply Chain Security Specialist
  • access to the Free and Secure Trade (FAST) Lanes at the land borders
  • a secure supply chain (hence your reputation)

Here are a couple of incentives that may sway your company’s mind: Trusted Trader status and the loss of business opportunities.

Trusted Trader Status

Trusted Trader is the integration of the CTPAT and (ISA) Importer Self-Assessment Program. Although Trusted Trader status is not operational yet, it may be as early as the fall of 2018.

This status will consist of multiple tiers, and importers who participate in both CTPAT and ISA will be at the highest tier and have the maximum Trusted Trader status. Currently, an importer cannot apply for ISA unless they are CTPAT certified. Participating in CTPAT is the first level of Trusted Trader status and the first step to gaining the full benefits listed above.

A Loss of Business Opportunities

U.S. Customs strongly advises all CTPAT partners to encourage their business partners to participate in CTPAT. Many importers have taken this message to heart and are requiring importers they purchase from domestically to also be CTPAT certified, in order to do business with them. Why? A well-recognized company does not want to be linked with a supplier who experienced a security breach within their supply chain, no matter how small the supplier.

As U.S. Customs continues to mutually recognize the supply chain security programs of other countries*, we are seeing more foreign participants requiring their international trade partners to participate in their own country’s supply chain security program. Foreign manufacturers understand inspection of their cargo is minimal when their entire supply chain is certified in mutually recognized supply chain programs, resulting in quicker processing time of their cargo and availability of their product in the market.

Doing business with companies certified in mutually recognized supply chain programs lessens the burden of work when assessing your supply chain. You don’t have to assess a business partner that is already certified in a supply chain program–they’ve already done that for you, and their Customs agency has confirmed that they’ve done their due diligence by certifying and validating them.

Instead of thinking about whether your company should participate in C-TPAT, ask yourself this: can we afford additional exams because we are not a Trusted Trader? Can we afford to lose business opportunities because we aren’t certified?

*U.S. Customs & Border Protection mutually recognizes the following foreign supply chain programs: Canada, Dominican Republic, EU, Israel, Japan, Jordan, Korea, Mexico, New Zealand, Singapore, and Taiwan.

By Beverley Seif, Vice President and General Manager


China Goes Head-to-Head with Additional Tariffs on U.S. Goods

China goes head to head 580

In response to the Trump administration’s recent proposed tariffs on $200 billion worth of Chinese goods, China has announced their own proposed list of additional 10 percent tariffs. Some of the major items by value on this 10 percent tariff list are food preparations, lasers other than laser diodes, and cast glass sheets.

These are China’s current lists of U.S. goods to be affected by tariffs.

The implementation dates will be announced separately, according to China’s announcement. However, it has been confirmed  that the 25 percent tariffs on additional $16 billion worth of imports from the U.S. will be imposed August 23.

International Trade Centre Data tweeted that China has removed crude oil and some chemicals from its updated $16 billion retaliation list and has added items such as cars, waste products, coal, and medical instruments.

If you have questions about these tariffs and how they may affect your business, reach out to your Mohawk customer service representative.

By Danielle Leonard


USTR Announces Official Second List of Section 301 Tariffs

Second list of section 301 tariffs 580

The Office of the United States Trade Representative (USTR) has finalized list two of Section 301 tariffs on Chinese products. The list contains 279 tariff lines—about $16 billion worth of imports from China—and will be subject to a 25 percent additional tariff. Customs will start collecting these additional duties on August 23, 2018. A Federal Register notice will also announce a process to request product exclusions for items subject to these additional duties.

If you have questions about these tariffs and how they may affect your business, reach out to your Mohawk customer service representative.

You can find the official announcement here.

Section 301 Product Exclusion Request Form

By Danielle Leonard

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