Navigating the Evolving U.S. Tariff Landscape: Strategic moves for importers in 2025

June 30 marked the end of the first half of 2025, marking a good time to reflect on the first six months of the year as well as to prepare for the rest of 2025 and beyond. For logistics and supply chain professionals, particularly those in the U.S. responsible for importing goods to support U.S. operations, both evaluations might become confusing and challenging.

During President Trump’s second term beginning 2025, the U.S. government introduced unprecedented and sweeping tariffs on imports from nearly all countries through multiple mechanisms. Here’s a recap of where we stand as of June 30:

• Section 301 (China): Tariffs on China-origin products, ranging from 7.5% to 25%, with certain categories reaching as high as 50% or even 100%. These tariffs were first introduced in 2018 during President Trump's term and were expanded under President Biden’s administration.
• Section 232: Elevated tariffs to 50% on steel and aluminum that have been expanding to related products such as canned beer and household appliances. An additional 25% was applied to vehicles and parts, with special provisions for USMCA qualifying goods.  Investigations have also been initiated into other commodities and industry sectors such as copper, pharmaceuticals, and semiconductors
• International Emergency Economic Powers Act (IEEPA) Fentanyl Tariffs: Initiated February 2025, these include 20% on Chinese (and Hong Kong) goods and 25% on non‑USMCA Canada and Mexico imports except Canadian energy products, which have a 10% rate.
• IEEPA Liberation Day Tariffs: On April 9, a 10% global baseline tariff was implemented, to be followed by country-specific “reciprocal” tariffs, ranging from 11% to 70%, effective after a 90-day pause. The pause expires on July 9, with the administration currently signaling that additional time may be granted in cases where the origin country is actively negotiating with the U.S. regarding trade

In addition to the ad valorem tariff applications, the IEEPA Fentanyl tariff executive order also revoked de minimis eligibility for all shipments from China (including Hong Kong). Now, even goods under $800 from China and Hong Kong are subject to full tariffs, where before Feb. 4, the low-value shipments were allowed to enter the U.S. duty-free and tax-free—without going through formal customs clearance

Tariffs are adding up

Indeed, all of these various tariffs and applications add up. The administration has issued instructions regarding which tariffs stack, and which are mutually exclusive. And this, too, has evolved over time. To give one glimpse of the impact of all the tariff activity, a 2025 study published in the Journal of Supply Chain Management estimates that U.S. importers paid $19.3 billion in duties in April 2025—about 3.5 times the average monthly duties collected at the peak of the 2018-2019 trade war.

Legal challenges to the tariffs, particularly those imposed using the IEEPA, are being processed in the courts. Members of Congress have introduced a handful of bills to curtail the tariffs, but none have made progress. This is due, in part, to the fact that since early April 2025, the House has effectively barred itself from voting on resolutions to terminate the national emergency declarations that underpin Trump's tariffs (imposed under IEEPA and the National Emergencies Act). 

If public pushback grows over consumer costs or small businesses, Congress might revisit procedural rules or pass new oversight measures. Any House vote remains off the table until post-September, so debate on tariffs could intensify in the fall session after Congress has completed the massive reconciliation package commonly referred to as the “One Big Beautiful Bill.”

While the country-specific reciprocal tariffs are on hold, the administration is negotiating trade deals with individual countries with the indication that the final reciprocal tariff amount could be lowered or possibly eliminated.

The framework for one such deal was completed with the U.K., and while the details and implementation is still being provided by the administration, it seems that the 10% baseline U.S. tariff remains on most U.K.-origin goods with some exceptions or tariff rate quotas put in place for automobiles, steel and aluminum, aerospace, and agriculture. 

If this framework is indicative of the direction for other trade deals, the U.S. importing community might face a complicated patchwork of tariffs based not only on commodity, but also country of origin. 

The administration is also concerned about the transshipment of goods being used to circumvent this tariff regime. Transshipment refers to the practice of routing goods from one country through another on its way to the ultimate destination. 

In these cases, the country of origin to be reported is that of the original country in which the good was wholly obtained, manufactured, produced, or underwent substantial transformation.  Importers might erroneously report the transshipment country as the country of origin in order to avoid tariffs levied on the actual country of origin.

As a result of this concern, Customs and Border Protection (CBP) is taking strong enforcement measures regarding the reported country of origin and value. CBP is prioritizing inspections on goods from Vietnam, Thailand, Malaysia, Indonesia, and Mexico—countries flagged as high-risk for acting as transshipment hubs. CBP is also scrutinizing invoices and other import documentation for signs of undervaluing goods. 

Some Chinese exporters are allegedly circumventing U.S. tariffs by setting up shell companies within the United States. These entities import goods on a Delivered Duty Paid (DDP) basis, claiming responsibility for duties and customs compliance.

However, after the goods are cleared and sold, the shell company fails to remit the required duties to U.S. Customs. In many cases, these companies then dissolve or vanish, leaving U.S. authorities unable to collect unpaid tariffs or enforce penalties. CBP is actively pursuing those that are exploiting this loophole in enforcement mechanisms.

What’s an U.S. importer to do?

In today’s fragmented and volatile tariff landscape, businesses must adopt proactive, layered strategies to protect operations and maintain cost competitiveness. To effectively manage tariff-related risks, companies should begin by conducting a thorough analysis of their tariff exposure.

Know HTS Classification: This involves mapping each product’s Harmonized Tariff Schedule (HTS) classification to identify all applicable tariff layers, including Section 232, Section 301, and IEEPA tariffs. Many U.S. companies have done this already, but it’s important to maintain that mapping in a flexible manner so that impact can be reassessed with each change to tariffs.

Evaluate Accuracy: Beyond product classification, businesses must also evaluate the accuracy and implications of their country-of-origin declarations, particularly in cases involving indirect sourcing or third-country assembly—common in regions such as Vietnam and India—where origin rules and transformation thresholds can be complex.

Monitor Legal Developments: Firms should actively monitor evolving legal and regulatory developments that may affect tariff obligations. This includes staying up to date with trade litigation, new announcements in the Federal Register, and changes in enforcement or policy from agencies such as the U.S. Trade Representative (USTR), Department of Commerce, and U.S. Customs and Border Protection (CBP). 

Manage Internal Expectations: However, it’s essential to manage internal expectations when responding to media reports about tariffs. Until official guidance is released—such as an Executive Order published on the White House website or formal rulemaking posted in the Federal Register—any meaningful assessment remains premature and often unwarranted.

Optimize Pricing & Inventory: To optimize pricing strategy and inventory planning in a volatile tariff environment, companies should incorporate a range of tariff assumptions—such as 10%, 20%, or 40%—into their product cost models, budgeting forecasts, and customer pricing structures. Proactive measures like forward purchasing and strategic inventory buffering can help hedge against anticipated tariff increases or regulatory disruptions.

Utilize a U.S. FTZ: Additionally, storing goods in a U.S. Foreign-Trade Zone (U.S. FTZ) offers a valuable layer of flexibility, allowing companies to defer certain duties until goods enter U.S. commerce. And if the goods are ultimately sold into other markets and are exported from the U.S. FTZ, no duties, taxes or fees are owed. This not only enhances cash flow management, but also enables tactical deployment of inventory based on tariff developments.

Engage with Stakeholders: Engaging with advocacy networks and industry stakeholders is a critical component of a comprehensive trade strategy. Companies should actively participate in trade associations relevant to their sector to help shape coordinated industry responses and influence regulatory and policy outcomes.

Offer Input: When and where available, businesses should file comments when Section 232 investigations are announced when the administration solicits input. Additionally, organizations should closely monitor legal developments and consider supporting judicial challenges to potential regulatory overreach

What’s ahead

The trade landscape is poised for significant developments in the coming months. By early August, reciprocal tariffs are scheduled to take effect unless last-minute agreements are reached with trading partners.

From mid-July through September, negotiations are expected to intensify with 18 major economies—including the EU, Japan, South Korea, India, Canada, and Mexico—as the U.S. seeks to recalibrate tariff arrangements and avoid further escalation.

Meanwhile, ongoing legal challenges could eventually undermine the long-term use of IEEPA-based tariffs. However, the administration is already indicating other possible avenues the President can use to levy tariffs if IEEPA is no longer available. Importers should anticipate continued enforcement while appeals are underway, meaning compliance obligations will remain in full force.

At the same time, enhanced enforcement will raise the compliance bar even further. Businesses should expect tighter scrutiny around origin verification and routing, signaling the need for stronger internal controls and documentation across global supply chains.

This moment presents a valuable opportunity for trade compliance professionals to elevate their visibility and impact within the organization. By implementing a structured, agile, and well-informed approach, U.S. importers can manage the complexities of the current tariff environment.

Melissa Irmen, AZS, CZS, is director of advocacy and strategic relations for the National Association of Foreign-Trade Zones (NAFTZ). She can be reached at [email protected]