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🔒 Financial institutions must identify, freeze, restrict, and report assets linked to designated persons to meet UK sanctions obligations.

🔒 EU–India FTA| EU Iran Sanctions Back | U.S. UK Deal | EU Biometric Borders Launch | Steel ADD | Auto Update | AI in Customs | UCC e-customs Report & new slides | VAT & WTO Rulings Edition 35 - Week 41/2025 Period Covered: 30 September 2025 – 06 October 2025 Published: 07 October 2025 Colleagues, In this edition, we have four special focus reports:

🔒 232 Wood Tariffs | Gov Shut!  | U.S.–EU Trade | CBP Updates | Trade Docs & AI | BIS 50% Rule | FDA Alerts | Incoterms Simplified | Sections 232 Updates Edition 32 - Week 41/2025 Period Covered:   29 September 2025 – 06 October 2025 Published: 06 October 2025

🔒 U.S. imposes Section 232 tariffs on timber, lumber, and derivatives starting Oct. 14, 2025, with rates rising in 2026. Let's explore

🔒 A U.S. government shutdown halts or slows key trade functions. Customs continues, but many regulatory and licensing services freeze. We explain. A federal government shutdown that began October 1 has disrupted trade and customs operations across several U.S. departments and agencies. Some functions are continuing under “excepted” or essential designations, while many routine activities have been suspended. CBP / DHS The Department of Homeland Security and U.S. Customs and Border Protection (CBP) will continue core activities, including tariff collection, cargo and passenger processing, law enforcement, and operations tied to safety and property protection.Non-essential functions such as planning, R&D, policy, auditing, and training are paused.CBP has stated that all its operations, including ruling requests, petitions, and penalty processing, remain active. However, delays are possible where partner government agencies (PGAs) are involved. Traders facing PGA-related clearance issues are advised to contact the respective PGA first, then CBP at the port if needed. USTR The Office of the U.S. Trade Representative remains largely operational. Negotiations and activities essential to maintaining or implementing trade agreements will continue.Non-essential engagements, such as trade and investment framework discussions and routine administrative work, are suspended. DOC The Department of Commerce has halted most International Trade Administration and Census Bureau activities, along with work by the Bureau of Economic Analysis and Economic Development Administration.Export enforcement and national security-related investigations under Section 232 will continue. ITC The U.S. International Trade Commission will keep the Harmonized Tariff Schedule current and continue litigation-related work.Suspended activities include antidumping and countervailing duty (AD/CVD) investigations, intellectual property and safeguard proceedings, and technical support to USTR and Congress. USDA The Department of Agriculture will maintain import and export operations funded by user fees, participate in select trade negotiations, and continue animal and plant health emergency programs.Most Foreign Agricultural Service operations and regulatory work are on hold. FMC The Federal Maritime Commission has furloughed all employees and suspended all core functions. This includes the processing of service contracts, licensing, financial responsibility certifications, and complaints.FMC’s online databases remain viewable but will not be updated. DDTC (State Department) The Directorate of Defense Trade Controls has sharply reduced services. License and registration processing, advisory opinions, and jurisdiction requests are paused. Only activities directly tied to national security or essential foreign affairs will proceed. CPSC The Consumer Product Safety Commission has suspended nearly all operations, including import surveillance, compliance checks, recalls, and civil penalties, unless an imminent threat to human safety exists. Additional updates may appear on agency websites. A compiled reference list is available from the Federal News Network. Conclusions and Recommendations CBP remains operational , but expect slower processing due to PGA shutdowns. Exporters and importers should plan for delays  in licensing, certification, and trade documentation where partner agencies (USDA, FMC, DDTC, CPSC) are involved. Engage proactively  with CBP and PGA contacts at the port level to troubleshoot clearance problems. Hold off on new filings  with agencies like FMC and DDTC until normal operations resume. Monitor official channels  for agency-by-agency reopening notices and updates.

🔒 U.S. 50% BIS Rule | UN & EU Snapback on Iran | AML Enforcement Surges | UK & EU Russia Measures Refined Edition 32-2025 - Week 40-2025 Period Covered: 26 September 2025 - 02 October 2025 Published: 03 October 2025

HMRC and BSI are shaping a new UK customs standard — PAS 41201. Here’s why you must review it before 3 October 2025. UK Customs is on the brink of a significant shift. HMRC has sponsored the development of PAS 41201 , a Publicly Available Specification drafted by the British Standards Institution (BSI), aimed at improving the quality, consistency, and professionalism of customs intermediaries. This is not a law, but if you work in customs, trade compliance, or logistics, it could set the operational benchmark for years to come. And right now, it’s open for public consultation until 3 October 2025 . Arne’s Takeaways PAS 41201 could shape the future of UK customs intermediary standards. Read the draft. Submit your feedback. Don’t miss the chance to influence it. Who We Are – Customs Manager Ltd. We help businesses master customs, trade compliance, and export controls in the EU, UK, and US. Our Trade Intelligence Service  at www.customsmanager.info  keeps professionals fully up to date with actionable insights. Key Questions Covered in This Blog What is PAS 41201 and why is HMRC backing it? Which operational areas does the draft cover? Why should customs intermediaries care? How and when can you give feedback to BSI? Abbreviations Used in This Blog PAS  – Publicly Available Specification HMRC  – His Majesty’s Revenue and Customs CPD  – Continuing Professional Development SOPs  – Standard Operating Procedures "Standards like PAS 41201 set the tone for how the UK’s customs sector operates. Ignore them at your own risk."Arne Mielken, Managing Director, Customs Manager Fancy a Call? Book a free consultation on how PAS 41201 could affect your operations: www.customsmanager.org → Book Expert Call Get Weekly Game-Changing Updates with The Customs Watch UK Stay ahead of every customs and compliance change in the UK with our free and premium updates. Sign up at www.customsmanager.info What is PAS 41201 and why is HMRC backing it? PAS 41201 is a fast-track, consensus-building standard  produced by BSI, the UK’s national standards body. HMRC’s sponsorship signals that it sees a need for higher, more consistent professional standards in customs intermediary work. While not legally binding, PAS 41201 could become the go-to reference  for demonstrating compliance, competence, and due diligence. Which operational areas does the draft cover? The PAS sets expectations in six areas: Due diligence  – checking the accuracy of data and legitimacy of clients. Continuing professional development  – keeping staff skills current. Systems, processes, and data  – ensuring secure, efficient workflows. Complaints resolution  – handling client issues professionally. Standard operating procedures  – documented steps to minimise errors. Transparency  – clear communication and disclosure with clients. Bold recommendation:   Audit your current procedures now against these six points. It’ll make adoption easier later. Why should customs intermediaries care? This PAS is designed for organisations that prepare and submit customs declarations for others — including customs agents, freight forwarders, express operators, and warehouse providers. By aligning with PAS 41201, you could: Improve operational quality and reduce compliance risk. Demonstrate professionalism to clients and HMRC. Differentiate yourself in a competitive marketplace. It’s also relevant to importers and exporters who rely on intermediaries — you’ll know exactly what good practice looks like. How and when can you give feedback to BSI? The public consultation  is running now until 3 October 2025 . To review the draft and submit comments: Go to the BSI Standards Development Portal . Create a free account if you’re a new user. Submit your feedback electronically — only online comments will be considered. BSI recommends that each organisation consolidate its comments to avoid duplication. All feedback will be reviewed before finalising the PAS. Bold recommendation: Don’t wait until the deadline. The sooner you comment, the more time you have to refine your position internally. PAS 41201 Focus Area What It Means Actions to Take Now Due diligence Verifying client identity, data accuracy, and legitimacy before submitting declarations. - Create a checklist for client onboarding.- Validate EORI, VAT, and licensing details before filing.- Keep proof of checks for audit defence. Continuing professional development (CPD) Ongoing training to keep staff up to date with customs rules and systems. - Set mandatory annual CPD hours.- Track completion through a training log.- Subscribe to trusted trade intelligence services. Systems, processes, and data handling Secure, efficient handling of customs data and declaration workflows. - Map your current declaration process.- Review system security and backup protocols.- Introduce version control for key documents. Complaints resolution Transparent, timely handling of client issues. - Document a complaints policy.- Set clear timelines for resolution.- Log and analyse complaints for recurring issues. Standard operating procedures (SOPs) Clear written processes for all key customs activities. - Write SOPs for each step of the declaration process.- Include who is responsible and when checks occur.- Review SOPs annually or after major regulatory changes. Transparency Clear communication about services, limitations, and responsibilities. - Update client terms of engagement.- Provide written service scope before starting work.- Share compliance responsibilities in plain English. Recap & Next Steps PAS 41201 could reshape UK customs intermediary standards. Whether you’re a service provider or a client, now’s the time to read the draft and have your say. If you ignore this consultation, you may have to live with a standard you could have influenced.

Passing customs clearance doesn’t mean you're safe. Learn what customs really checks—and how to avoid costly audits. Navigating Customs: Understanding the Checks Beyond Clearance to Avoid Expensive Audits. Customs compliance  in the EU , UK , and USA  is not just a box-ticking exercise. It’s a strategic necessity. Many companies think, "We got through clearance—we’re compliant." Unfortunately, that's a myth that can cost millions. In my role as a Customs Consultant , I’ve seen it all: delayed shipments, sky-high penalties, and broken supply chains—all because someone underestimated what customs authorities care about. Key Questions Covered in This Blog Why is customs classification more than just assigning a code? How does customs valuation go beyond intercompany pricing? What really determines the country of origin? Why is poor recordkeeping a ticking time bomb? What role does restricted party screening play in compliance? What are the most common customs myths that put you at risk? What should be on your customs pre-audit checklist? Abbreviations Used in This Blog FTA  – Free Trade Agreement BTI  – Binding Tariff Information BOM  – Bill of Materials WTO  – World Trade Organization CBP  – U.S. Customs and Border Protection UCC  – Union Customs Code "Passing customs clearance is not proof of compliance. It’s merely the beginning of scrutiny. Real compliance means being audit-ready, always." — Arne Mielken, Managing Director, Customs Manager Fancy a Call? Book a free customs compliance consultation  to assess your risk exposure or simulate an audit at www.customsmanager.org  → Book Expert Call Get Weekly Game-Changing Updates with Customs Watch Stay ahead of regulations with our trusted weekly magazines. Get expert summaries, insights, and tips for EU , UK , and USA  trade professionals. Sign up now at www.customsmanager.info Why is customs classification more than just assigning a code? It’s tempting to rely on your broker to pick the HTS codes. After all, they do this every day, right? But customs doesn't care who typed it in. You are the importer of record . If your code is wrong, you pay.

🔓 Ensure FSFE compliance by correctly reporting first-sale entries and knowing when to request a CBP ruling for audit protection. First-Sale for Export (FSFE) allows importers to declare the value of goods based on an earlier sale in a chain of transactions, potentially lowering duties. For customs managers, implementing FSFE correctly requires a structured approach that covers identification, reporting, documentation, and optional CBP rulings. Here are the steps to take: Step 1: Identify Qualifying Transactions The first step is to review all incoming shipments and determine whether a chain of sales exists. FSFE applies only if there are multiple sales between the manufacturer and the U.S. importer. If a foreign seller sells directly to the U.S. buyer, FSFE does not apply, and no declaration is required. Determine which sale in the chain qualifies as the first or earlier sale. Typically, this is the sale from the manufacturer to the first intermediary, not the final sale to the U.S. buyer. Step 2: Prepare Entry Documentation Once qualifying transactions are identified, gather all supporting documentation. This includes commercial invoices from the first sale, contracts detailing the series of sales, payment records, shipping documents showing the movement of goods, and any correspondence that confirms pricing or terms. Each document should clearly demonstrate that the customs value is based on the first-sale transaction rather than the last sale. Step 3: Report FSFE in CBP Entry When preparing CBP Form 7501 or its electronic equivalent, flag each line item using FSFE with an “F” indicator. This line-level flag communicates to CBP that the transaction value reflects a first-sale basis. Omitting the “F” indicator can lead CBP to assume the last-sale value is used, which may result in rejection of the declared value or audit complications. FSFE is only reported for items using transaction value; other valuation methods do not require the “F” flag. Step 4: Optional CBP Ruling Request For complex transactions or unusual chains of sales, consider submitting a binding ruling request to CBP under 19 C.F.R. Part 177. A ruling confirms that FSFE applies to the specific transaction and provides legal certainty for audits. Prepare a full description of the transaction, including all parties involved, ports of entry, and the sequence of sales. Include all supporting documentation: invoices, contracts, shipping records, and payment confirmation. Note any previous guidance received from CBP. Submit electronically via the eRulings template to the National Commodity Specialist Division in New York. Acceptable formats include Word, Excel, PDF, text files, images, and MP4 videos. Compressed files are not allowed. CBP generally issues rulings within 30 days. Complex cases requiring lab analysis or inter-agency consultation may take up to 90 days. Once received, the ruling or control number should be filed with the entry documents. Step 5: Maintain Records for Audit Regardless of whether a ruling was requested, retain all FSFE documentation for at least five years. This includes invoices, contracts, shipping records, payment confirmations, correspondence, and, if applicable, the CBP ruling. Proper record-keeping ensures readiness for any audit or valuation inquiry. Step 6: Review and Compliance Check Before submitting entries, verify that: The “F” indicator is applied to all qualifying line items. Documentation clearly supports the first-sale valuation. Any CBP ruling has been included or referenced. All records are organized and complete for potential review. Conclusion Implementing FSFE correctly requires a disciplined, step-by-step approach. By identifying qualifying sales, documenting the first-sale transaction, flagging entries properly, and using CBP rulings where necessary, customs managers can ensure compliance while optimizing duty payments. Recommendations Identify all multi-sale transactions early and determine the first-sale candidate. Collect and organize invoices, contracts, payments, and shipping documents before entry. Flag each FSFE line item with an “F” on CBP Form 7501 or the electronic entry. Consider a CBP ruling for complex or high-value transactions to gain certainty. Maintain all documentation and rulings for at least five years for audit readiness. Review entries before submission to ensure accuracy and compliance. FSFE training We offer comprehensive FSFE training designed for customs professionals who want to master First-Sale for Export compliance. The program covers identifying qualifying transactions, maintaining robust supporting documentation, and understanding when and how to request a CBP ruling for complex cases. Participants will also learn practical strategies to minimize audit risk and optimize duty savings while ensuring full regulatory compliance. To book your spot, visit www.customsmanager.org/events  for next dates. FSFE Updates Our Trade Intelligence service monitors updates to CBP laws and regulations on a weekly basis, including First-Sale for Export (FSFE) guidance. This ensures you stay ahead of changes that could impact valuation, entry reporting, or audit risk, helping your team maintain full compliance and make informed decisions. Stay informed with our free newsletter, delivering the latest insights on customs, CBP regulations, and FSFE updates. Visit www.customsmanager.info  and enter your email to start receiving updates—you can unsubscribe anytime. Call? We offer bespoke consulting, advice, and support tailored to your business, helping you navigate customs compliance, FSFE valuation, and CBP regulations with confidence. Start with a free call. Visit www.customsmanager.org ⇾ Book Expert Call

🔒 EUDR delay proposed | US implements EU-US Trade Deal | EU–Indonesia CEPA | EU CBAM simplifications approved + massive update | UK TRA Reviews Ironing Boards | HMRC Issues Major CDS & Tariff Updates Edition 34 - Week 40/2025 Period Covered: 23 September 2025 – 29 September 2025 Published: 30 September 2025 Colleagues, The past week brought major trade and customs developments across the EU and UK, with important implications for businesses navigating compliance and market access.

🔓 Is your management worried about paying for trade intelligence? Discover why the PRO Plan is worth it, addresses common concerns, and protects your business. Why Trade Intelligence Feels Expensiv e Many professionals hesitate to pay for trade intelligence . Questions like “Do I really need it?” or “Can’t I get this for free?” are common. After all, free newsletters, online alerts, and marketing emails promise updates. The problem is these sources are often incomplete, biased, or outdated. Relying on them can leave gaps in your compliance strategy—gaps that can be costly for your business. Objection 1: “I can get updates for free.” Free sources may seem convenient, but they’re rarely curated for accuracy or relevance. They often overwhelm you with information that isn’t actionable. The PRO Plan solves this by providing expertly curated updates, reviewed by Mr. Arne Mielken, CEO of Customs Manager Ltd, with over 20 years of experience. Each update is vetted for relevance, accuracy, and practical application, giving you only the information you need to act confidently. Objection 2: “It’s too expensive.” At less than the cost of half a coffee per day, the PRO Plan is a small investment compared to the cost of fines, delays, or compliance errors. Members also benefit from discounts on consultancies, training, and customs services—meaning the PRO Plan often pays for itself within weeks. Objection 3: “I don’t have time to read updates.” Time is the one resource trade professionals never have enough of. That’s why the PRO Plan is designed for efficiency. Weekly updates are presented in a format that can be scanned in 15 minutes, including executive summaries and direct links to legislation, guidance, and original sources. Objection 4: “How do I know the information is reliable?” Unlike automated alerts or AI-generated summaries, every PRO Plan update is reviewed by a real customs manager who understands the challenges you face. This ensures that the information is accurate, actionable, and trustworthy—so you can make decisions with confidence. Objection 5: “I’m not sure it’s relevant to my business.” The PRO Plan focuses on content relevant to customs, export controls, and sanctions professionals. Each update highlights the changes that matter most and includes executive summaries so you can immediately see how it affects your business. Objection 6: “I can’t justify it to my management.” The PRO Plan isn’t just a subscription—it’s a risk management tool. By reducing compliance errors, shipment delays, and fines, it protects your company’s bottom line. The time saved and access to actionable intelligence make it a sound investment for management approval. Objection 7: “I already have internal resources.” Even the best internal teams struggle to track every regulatory change. The PRO Plan complements internal resources, providing curated, up-to-date intelligence and links to original sources that your team can trust, saving hours of research. Objection 8: “I worry it will be too technical or complicated.” Every PRO Plan update is written to be practical and scannable. Executive summaries, clear highlights, and direct links to original legislation or guidance make it easy to understand, even under time pressure. Conclusio n Subscribing to the PRO Plan isn’t just a purchase—it’s protection for your business. It saves time, reduces risk, and provides real, practical insights from an experienced trade professional. Free sources might give a false sense of security, but the PRO Plan ensures you’re truly up to date and compliant. Next Steps Upgrade today at https://www.customsmanager.info/plans-pricing . Take advantage of weekly updates, expert insights, and member-only benefits to keep your business compliant and ahead of regulatory changes. LinkedIn: Customs Manager Ltd YouTube: Customs Manager Channel

Why the EU is standing its ground against Trump's tariff talk, why it offers an FTA and what it means for your trade strategy. World trade is in flux, and if you're involved in Customs , Import , or Trade Compliance , then President Trump's proposed "reciprocal" tariff policy should be on your radar. The European Commission's stark opposition to this approach marks a defining moment for global trade relationships. Understanding the EU's stance can help you adapt your business strategy, especially if you are a Customs Consultant , compliance officer , or engaged in Export Compliance  across the EU , UK , and USA . Top tip 1: You can break down a paywall by becoming a Premium plan subscriber.Top Tip 2: For personalized updates and advice on how these changes could affect your business, sign up for email alerts at www.customsmanager.info . Key Questions Covered in This Blog What is the EU's position on Trump's "reciprocal" tariff policy? Why does the EU claim tariffs hurt domestic economies? How do tariffs affect Customs Compliance  and trade operations? Olive Branch: Why did the EU offer Trump a “Good Deal”? What is the Two-Pronged Strategy? Dialogue and Defence Will we get an EU-US FTA? What does this mean for EU, UK, and US trade relationships? How should trade professionals prepare? Download Statement from the EU Commission "World trade thrives on transparency and low barriers. When tariffs rise, everyone pays the price—from the factory floor to your dinner table." — Arne Mielken, Managing Director, Customs Manager Abbreviations Used In This Blog EU : European Union UK : United Kingdom US/USA : United States of America FTA : Free Trade Agreement WTO : World Trade Organization Fancy a Call? Book a free consultation on trade strategy, tariffs, and customs compliance: www.customsmanager.org  → Book Expert Call Get Weekly Game-Changing Updates with Customs Watch EU&UK Stay ahead of regulatory changes, case law, and customs updates affecting your business in the EU and UK. Sign up at www.customsmanager.info .