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July deadline for eFiling US product compliance

Jun 24, 2026 | , , , , , , , , , , , ,

From 8 July, regulated consumer products entering the US must be supported by electronic compliance certificates filed at the time of customs entry, turning missing or inaccurate information into a direct threat to supply chain continuity.

This is not a change to the underlying safety rules, but to how they are enforced in practice. Paper or PDF certificates kept “on file” will no longer be enough; instead, compliance data must travel with the goods through US Customs and Border Protection’s Automated Commercial Environment (ACE), creating a new operational dependency on clean master data and structured product records.

What is changing in July

The US Consumer Product Safety Commission (CPSC) is rolling out mandatory electronic filing of Certificates of Compliance for regulated consumer products from 8 July, covering finished goods already in scope of existing CPSC requirements.

Importers (or their customs brokers) must now submit defined certificate data elements electronically via ACE with every applicable customs entry, including low-value and de minimis consignments. Shipments into US Foreign Trade Zones benefit from a longer transition, with mandatory eFiling pushed back to January 2027, but they will ultimately be brought into the same regime.

The new rules will be felt most acutely in sectors with broad product ranges, frequent line changes and complex safety obligations.

Fashion, retail, toys, consumer electronics, nursery products, homeware and household goods are all directly affected, particularly where products require either a Children’s Product Certificate (CPC) or a General Certificate of Conformity (GCC). 

For brands with high-volume direct-to-consumer flows and seasonal collections, the inclusion of de minimis parcels means that even small data gaps can disrupt launches and delay customer deliveries.

From paper certificates to digital compliance

For each shipment, importers must transmit a structured set of data points, including product identifiers (such as SKUs), details of the certifying party, the specific safety rules applied, manufacturing dates and locations, test dates and locations, and contact details for the laboratory and record keeper. 

Importers can choose between two methods of submitting compliance data:

1. Full PGA Message Set

Under this option, all certificate data is filed directly into ACE for every shipment. Required information includes:

  • Product identifiers such as SKU or GTIN
  • Applicable CPSC safety standards
  • Manufacturing dates and locations
  • Manufacturer or assembler details
  • Testing dates and testing facility information
  • Laboratory details
  • Contact details for the party maintaining compliance records

This approach is generally more suitable for importers handling smaller product ranges or irregular shipments.

2. Reference PGA Message Set

For businesses importing the same regulated products regularly, the CPSC Product Registry offers a more streamlined alternative.

Product certificate information can be pre-registered in advance, allowing customs brokers to submit only:

  • Certifier ID
  • Product ID
  • Certificate Version ID

This method can significantly reduce repetitive data entry and support faster customs processing.

Both approaches rely on accurate, pre-prepared data that aligns exactly with the physical shipment.

New operational and data challenges

Importers now need to manage the intersection of multiple requirements at SKU level, for example combining US flammability rules for clothing, chemical restrictions on substances such as lead and phthalates, and labelling standards for fibre content, care instructions and safety warnings.

For fashion and lifestyle brands, that means building robust testing programmes, maintaining complete technical files and ensuring master data can be translated into CPSC-compliant certificate records without manual rework at the point of entry.

Regulators have signalled that they expect full compliance from the implementation date, with no broad indication of delayed enforcement.

Incorrect or incomplete eFilings can trigger automated customs holds, manual inspections, potential seizure or refusal of non-compliant shipments, and even civil penalties where systemic failures are identified. For time-sensitive sectors such as fashion and retail, where margins and calendars are already under pressure, even short delays at the border can undermine entire seasons or promotional campaigns.

Why exporters and origin teams matter

Although legal responsibility for eFiling sits with the US importer, a significant proportion of the required information resides with exporters, manufacturers and upstream partners.

Testing records, manufacturing details, lab certifications and product specifications are typically held at origin, and without structured access to this data, importers may struggle to complete mandatory filings accurately and on time. Exporters targeting the US market therefore need to map CPSC scope with their customers and embed electronic information sharing into standard shipping processes so certificate data is available well before cargo departs.

Turning compliance into an advantage

Businesses that invest early in mapping their CPSC exposure, closing testing gaps, building digital certificate libraries and rehearsing eFilings in test environments will move through the new regime with fewer delays and lower risk. 

Those that treat compliance as a last-minute paperwork exercise risk finding that missing or inconsistent data becomes a bigger threat than tariffs, capacity constraints or transport disruption.

Metro is already working with customers in fashion, retail, consumer goods and wider international trade to align product data, testing records, documentation and customs processes across origin and destination teams. 

If you import into the United States and want to turn the new CPSC eFiling rules into a competitive advantage rather than a source of disruption, EMAIL our Managing Director, Andrew Smith, directly. 

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US tariff volatility puts planning under pressure

Jun 24, 2026 | , ,

US trade policy is once again shifting, and this time the uncertainty is centred not just on what duties apply, but how long they will last and what might be added next. 

Importers face a confusing mix of “temporary” measures that refuse to go away, new proposals linked to forced labour concerns, and the ever-present risk of retaliatory action from major trading partners.

A “temporary” tariff that keeps dragging on

The 10% blanket tariff on most US imports was introduced as an emergency measure, but it has quickly become a structural cost in many supply chains.

Despite a trade court ruling against the measure, success in the ongoing appeals process means the surcharge remains in force, leaving businesses paying higher duties today without a clear view of whether, or when, it might be rolled back. 

That creates a planning dilemma. Tariffs are real and immediate, yet the long-term framework is unresolved, and there is a possibility that some duties could eventually be refunded if legal challenges succeed.

Compounding this, there are indications that tariff levels may increase further in the near term, adding another layer of complexity for forecasting, pricing and contract negotiations.

New forced-labour duties widen exposure

Alongside the existing blanket measure, proposals for forced-labour-related tariffs are poised to reshape the risk landscape.

If implemented, these duties could add up to 12.5% on imports from a broad group of economies, including key partners such as the EU and UK. Crucially, these measures would apply at a country level rather than being targeted at specific non-compliant supply chains, meaning even businesses with robust labour and ethical sourcing standards could still face higher landed costs purely due to origin.

This raises the prospect of multiple tariff layers applying to the same product, significantly inflating total duty paid and forcing companies to reconsider how, where and from whom they source.

Rethinking sourcing and compliance

The combined effect of existing and proposed tariffs is already driving change in global sourcing and production strategies.

Businesses are:

  • Reassessing sourcing locations and production footprints to reduce tariff exposure.
  • Exploring tariff engineering opportunities, including product reclassification and component changes where appropriate and compliant.
  • Tightening due diligence on labour practices and supply chain transparency as forced-labour measures gain momentum.

At the same time, the risk of retaliatory tariffs from affected partners adds further complexity, particularly for companies operating multi-directional flows between the US, Europe and other key markets.

Planning when the rules keep changing

With legal appeals ongoing and new policy proposals still moving through the system, the US tariff landscape is likely to remain fluid through the second half of the year and beyond.

Key variables include:

  • The final outcome of the appeals process and the future of the 10% blanket tariff.
  • The timing, scope and country coverage of forced-labour-related duties.
  • Potential countermeasures from other economies and their impact on cross-border trade.

In this environment, waiting for clarity is not a strategy. Businesses need to understand their exposure now, scenario-plan for different tariff outcomes, and build flexibility into their supply chains, contracts and pricing structures.

How Metro helps you stay ahead

Metro teams on both sides of the Atlantic work with importing and exporting customers across multiple sectors to overcome exactly this type of uncertainty, combining customs expertise, regulatory insight and technical brokerage solutions to keep goods moving while controlling cost and risk.

We help importers:

  • Map current and potential tariff exposure at product and lane level.
  • Evaluate alternative sourcing, routing and customs strategies that balance cost, speed and compliance.
  • Integrate trade, customs and logistics planning so tariff changes do not automatically translate into supply chain disruption.

If your business is exposed to US imports and you want to protect a customer or turn a volatile tariff environment into a managed risk rather than a threat, EMAIL our Managing Director, Andrew Smith, directly. The most effective responses to policy change are the ones you prepare before the next round affects your supply chain.

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UK steel tariff changes reshape import costs

Jun 9, 2026 | , , , , , , ,

The UK’s incoming steel trade measures are set to reshape import dynamics almost overnight, with significant cost and compliance implications for manufacturers, construction firms, and industrial supply chains.

From 1 July 2026, the UK will replace its current steel safeguards with a far more restrictive tariff rate quota (TRQ) system. Tariff-free quotas will be cut by around 60% overall, with some key product categories seeing reductions of up to 90%. At the same time, the duty applied to volumes above quota will double to 50%.

The measures apply across approximately 20 steel product categories, including flat products, bars, and pipes, and notably apply regardless of origin, including imports from EU and other trade agreement partners.

While positioned as a move to protect domestic steel production, the reality for importers is a much tighter and more punitive operating environment.

Why this matters for importers

For UK businesses reliant on imported steel, including automotive, machinery, construction, and engineering, the changes introduce both immediate cost risk and ongoing supply uncertainty.

The most significant shift is how quickly quotas are expected to be exhausted. With volumes sharply reduced, many categories could run out within days or weeks of each quarter opening, rather than lasting the full period. Once quotas are filled, any additional imports will face a 50% duty, creating a substantial and potentially unmanageable cost increase.

At the same time, domestic supply is unlikely to fill the gap. Many manufacturers rely on specific grades or forms of steel that are not readily available in the UK, meaning substitution is not always viable.

Rising costs and supply chain pressure

Industry bodies are already warning of widespread disruption. Higher input costs are expected to ripple through supply chains, increasing production costs and reducing competitiveness for UK manufacturers.

There is also growing concern around material availability. In sectors such as construction, limited domestic capacity combined with tighter import restrictions could lead to shortages of key products, delaying projects and adding further cost pressure.

For exporters, the impact is twofold: higher input costs at home and increased competition from overseas producers who are not subject to the same tariff burden.

Operational complexity increases

Beyond cost, the new regime introduces a more complex and time-sensitive import process.

The TRQ system will continue to operate on a first-come, first-served basis, with quarterly allocations managed through HMRC. This puts significant pressure on timing, both in terms of shipment planning and customs entry.

If a shipment is declared after a quota has been exhausted, it will immediately fall into the higher duty bracket, regardless of when it was shipped. This makes accurate forecasting, documentation, and coordination between supply chain partners critical.

Importers will need to pay close attention to:

  • Entry timing versus quota availability.
  • Correct tariff classification and documentation.
  • Coordination between forwarders, brokers, and internal teams.
  • Monitoring quota usage in near real time.

Even small missteps could result in substantial, avoidable duty exposure.

Behavioural shifts already underway

In response, many importers are already adjusting their strategies. There are signs of front-loading shipments ahead of the July deadline, alongside contingency planning based on higher landed cost scenarios.

Some businesses are modelling worst-case pricing as a baseline, while others are reviewing sourcing strategies or considering inventory increases to mitigate risk.

However, these are short-term responses. Longer term, the market may see shifts in sourcing patterns, pricing structures, and even production locations if cost pressures 

persist.

With additional measures such as the UK’s Carbon Border Adjustment Mechanism (CBAM) due to follow in 2027, importers face a longer-term trajectory of rising complexity and cost.

The new steel regime will penalise those who don’t plan ahead and prepare. Metro’s customs and compliance experts are already supporting clients with quota planning, tariff classification, and import strategy to minimise risk and control costs.

For tailored guidance on how these changes will affect your business, EMAIL Andy Fitchett, Metro’s Head of Customs & Compliance.

Investigation

US Customs and Border Protection to target undervaluation and DDP abuse

Jun 9, 2026 | , , , , ,

President Trump’s new customs enforcement drive is turning DDP and other seller‑controlled models into a high‑risk area, especially where duties are undervalued or the true importer of record is unclear.

The 3 June 2026 “Strengthening Customs Enforcement” executive order marks a significant tightening of how US Customs and Border Protection (CBP) vets and polices importers of record. It directs CBP to raise minimum asset and bond requirements, collect more detailed data at registration, and classify importers into risk‑based tiers linked to their compliance history.

Importers will have to disclose anticipated import volumes, beneficial ownership, business affiliations and domestic assets, and maintain a defined “good standing” status to continue importing or appointing a customs broker. Foreign‑based importers face additional restrictions, including limits on informal entries and tighter conditions for using continuous bonds.

Why DDP and DAP are in the spotlight

Higher tariffs in Trump’s second term have nudged contract terms towards Delivered Duty Paid (DDP) and similar structures, where the seller takes responsibility for duties, taxes and customs clearance. On paper, this can simplify life for buyers, but it also shifts control of declarations and valuations to the party with the strongest incentive to cut landed costs.

CBP has highlighted undervaluation, mis-declaration and opaque importer structures as priority enforcement areas. In a DDP or DAP model with a foreign importer of record, there is a heightened risk that declared values are artificially low, classification is aggressive, or the nominal importer is a thinly capitalised shell with few US assets. These are exactly the patterns the new regime is designed to catch.

Delivered Duty Paid arrangements often rely on overseas documentation and invoicing that CBP cannot easily verify at the border. Low‑value or informal entries have historically been harder to police, and this has created room for abuse, such as splitting shipments, manipulating invoice values or using rebates that never appear on the customs invoice.

Under the new enforcement approach, CBP is explicitly targeting misclassification, undervaluation and duty‑avoidance schemes. With higher tariffs in play, the financial upside of under‑declaring value is greater, but so is the downside: higher penalty floors, fewer mitigation options, and an increased likelihood of audits, holds, and retrospective assessments if patterns look suspicious.

Foreign IORs and “shell” structures

The executive order draws a sharper distinction between US and foreign importers of record, and seeks to close loopholes that have allowed foreign entities to mimic US presence using shell companies. To qualify as a US importer, entities will need a genuine US footprint: incorporation under US law, a principal place of business in the US, tangible domestic assets and identifiable US beneficial owners.

Foreign IORs will be barred from using informal entries and will face stricter bond and vetting requirements for formal entries, often needing validation via trusted trader programmes or a validated US customs broker. This makes it more difficult for lightly capitalised overseas sellers to hide behind complex structures when operating DDP models into the US.

Higher penalties, more data, more audits

The enforcement framework is also being hardened across the board. CBP is moving to set minimum penalty and liquidated damages floors, reduce mitigation options, particularly for repeat offenders, and expand the use of audits and data‑driven targeting. Brokers that turn a blind eye to high‑risk clients, or fail to exercise due diligence, can expect higher penalties and closer scrutiny.

Importers will be required to submit additional documentation, including the same export paperwork filed with the foreign customs authority, supply chain certifications and more detailed product specifications. This expanded dataset supports CBP’s increasing use of analytics and AI to flag unusual trade patterns, valuation anomalies, and sudden shifts in importer or routing behaviour.

If your US trade relies on DDP, DAP or foreign importer‑of‑record models, this new enforcement environment demands a fresh look at your structures, contracts and declarations before CBP does it for you.

To review your current arrangements, assess your exposure and design a compliant, resilient approach to US customs under the new rules, please EMAIL Andy Fitchett, Metro’s Head of Customs & Compliance.

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