Global Trade

Informal Entries, Section 321, and Why “Refunds Later” Is a Procedural Assumption U.S. Customs and Border Protection recently announced that it has collected more than $1 billion in duties following the suspension of duty-free de minimis treatment under Section 321. The announcement highlights the scale and speed with which duties are now being collected on

Informal Entries, Section 321, and a Procedural Gap in the Case Law Recent litigation over tariffs imposed under the International Emergency Economic Powers Act (IEEPA) has focused on a recurring procedural question: if the tariffs are ultimately held unlawful, can importers recover the duties they paid?  In addressing that question, courts have declined to halt

Part One of a Three-Part Series on Section 338 The Real Tariff Tools in a Post-IEEPA World The Supreme Court may soon decide whether presidents can continue using IEEPA as an all-purpose tariff machine. If the Court rules against that practice, it will limit a tool that has become a convenient shortcut.  The executive branch

Section and Chapter Notes: Where the Real Classification Rules Live Most importers know what an HTS code looks like. Fewer know what it means. And almost no one reads the part that tells you how it should be interpreted in the first place. Welcome to the Section and Chapter Notes. These aren’t filler pages or

General Notes in the HTSUS: What They Are and Why They Matter Most importers flip straight to the tariff code. A few get as far as the chapter notes. But almost nobody starts in the General Notes of the Harmonized Tariff Schedule of the United States (HTSUS), where the real money-saving opportunities live. Tucked neatly

The Notes Nobody Reads (But Everyone Should) If you’re relying on a keyword search or a code look-up tool to classify your imports, you’re playing a risky game. HTS classification isn’t just about matching a description, it’s about following a legal framework built on layers of fine print that most people never bother to read.

Duty rates aren’t set in stone. They’re set in law. Like most legal frameworks, they come with nuance, exceptions, and opportunities. Understanding how those rates are calculated (and how they can be lowered) is less about beating the system and more about understanding it better than the next importer. If your duty rates seem higher

Customs brokers play an essential role in international trade. They process entries, deal with forms most people never want to read, and help keep your goods moving. But as any seasoned importer will tell you: not all brokers are created equal – and not all of them get your HTS classification right. While it’s tempting

If you’re an importer in 2025, you know that tariffs don’t just live in headlines. They live in your landed costs, your margin reports, and your CFO’s nightmares. The tariff rollercoaster is ramping up. With rising geopolitical tensions, renewed Section 301 and 232 actions, and a steady undercurrent of protectionist trade policy, we’re firmly in