Transship Tariffs: New Customs Pain
- Madni Laghari
- Jul 19
- 4 min read
Updated: Jul 20
New U.S. tariffs target “transshipped” goods—but what counts as transshipment? Here’s what every compliance professional must know.
If you work in Customs Compliance, you’ve probably seen the buzz around the new U.S. “transshipment tariffs.” As an expert in customs, export controls, and sanctions for the EU, UK, and USA, I’ve fielded a barrage of questions about these ambiguous rules. For importers, exporters, and customs consultants, this development brings both opportunity and risk. Let’s unpack what’s at stake—and how to protect your business.
Top Tip 1: You can break down a paywall by becoming a Premium plan subscriber. |
Top Tip 2: For our weekly free newsletter on all matters customs cost savings and compliance, plus latest updates, practical tips and free explainer videos, invitation to live trainings and webinars, leave your e-mail at www.customsmanager.info. |
Key Questions Covered in This Blog
What are “transshipment tariffs” and why are they so ambiguous?
Who could be impacted—logistics, e-commerce, or traditional manufacturers?
How will CBP enforce these tariffs and determine Country of Origin (COO)?
Are all shipments routed through third countries at risk?
What does this mean for compliance and supply chain strategy?
Abbreviations Used In This Blog
CBP: U.S. Customs and Border Protection
COO: Country of Origin
CTPAT: Customs Trade Partnership Against Terrorism
“The real risk isn’t just higher duties. It’s the uncertainty—when every routine shipping decision might trigger a 50% tariff, every trade professional must be on alert. Navigating this ambiguity is the new core skill for U.S. customs compliance.” Arne Mielken, Managing Director, Customs Manager |
Fancy a Call?
Book a free expert consultation on how transshipment tariffs may affect your business at www.customsmanager.org → Book Expert Call.
Get Weekly Game-Changing Updates with The Customs Watch USA
Stay ahead of every customs, export, and compliance trend with our flagship magazine—The Customs Watch USA. Get curated insights, regulatory alerts, and compliance tips straight to your inbox. Sign up at www.customsmanager.info.
What are “transshipment tariffs” and why are they so ambiguous?
Transshipment tariffs, introduced in the latest U.S. trade deals, are designed to target goods “transshipped to evade tariffs.” But here’s the problem: there’s no clear legal definition of transshipment in this context. Customs professionals, compliance officers, and import/export specialists are left scratching their heads. Is it when goods are split, stored, or packaged in a third country? Is it just a penalty for changing the route, or only for those trying to mask their true COO? The government’s language is broad, and for now, “transshipment” could include everything from basic logistics to deliberate duty evasion.
Who could be impacted—logistics, e-commerce, or traditional manufacturers?
Let’s walk through real scenarios. Imagine you manufacture in Vietnam, then split your shipment—some go to Europe, some to a warehouse in Singapore before heading to the USA. Or you ship via air or ocean, with a third-country stopover. Or, as an e-commerce business, your postal carrier reroutes packages through a country with lower duties. Each scenario seems ordinary, but under the new tariffs, any of them could theoretically be penalized. The target is clear: goods routed through another country to disguise their origin and avoid tariffs. But in reality, supply chains are complex, and legitimate businesses could be collateral damage.
How will CBP enforce these tariffs and determine Country of Origin (COO)?
Enforcement is the elephant in the room. U.S. CBP must now decide if a shipment truly tries to dodge duties or if it’s just using efficient logistics. Historically, enforcement relied on paperwork and trust—declared origin, invoices, certificates. Now, CBP may dig deeper, scrutinizing routing patterns, warehousing, and even packaging locations. For violators, the risk is huge: not just repaying the duties, but facing a punitive 50% tariff on “illegally” transshipped goods. For compliant businesses, proving innocence will require meticulous documentation and possibly a revamp of partner screening and routing strategies.
Are all shipments routed through third countries at risk?
The short answer: not yet. The new rules specifically mention goods transshipped to evade tariffs—so the intent to avoid duty is key. But here’s where ambiguity bites: how will CBP prove intent? For now, “traditional” transshipments—like splitting inventory or basic warehousing—may not be the target. But if your supply chain closely resembles routes commonly used for evasion, expect extra scrutiny. And as the guidance evolves, more routine scenarios could be swept up in enforcement.
What does this mean for compliance and supply chain strategy?
The days of “set-and-forget” logistics are over. With so much at stake, compliance officers must audit every link in the supply chain. If you’re a customs consultant or compliance manager, advise your clients to:
Map out every shipping route and document every handoff.
Review your Country of Origin determination process—and back it up with evidence.
Update risk management protocols to flag unusual transshipment patterns.
Remember: the greatest cost isn’t always the tariff—it’s the unpredictability and compliance burden these new rules create.
Arne’s Takeaway
Ambiguity in customs law always favors the enforcer. If you rely on third-country logistics, now is the time to shore up your compliance, document your process, and stay informed. A single misstep could cost you dearly, not just in duties but in lost trust and business opportunity. If you’re unsure, seek advice before the auditors come knocking.
Expert Recommendations
Conduct a supply chain risk assessment for transshipment vulnerabilities.
Review all contracts with third-party logistics and fulfillment partners for compliance.
Subscribe to official CBP updates and professional trade publications—knowledge is your best shield.
When in doubt, consult a customs consultant with proven expertise in U.S., EU, and UK import regulations.
Sources & Further Information
U.S. CBP: Trade Newsroom
U.S. Trade Representative: Press Releases
Official explainer and weekly updates: www.customsmanager.info (sign up for tailored alerts)
Disclaimer
This blog is for educational purposes only and does not constitute legal advice. For case-specific guidance, consult a licensed trade compliance professional.
