Investigation

US Customs and Border Protection to target undervaluation and DDP abuse

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.

Rotterdam sunset

Port congestion spreads as delays ripple through global supply chains

Port congestion in North Europe and East Asia is increasingly a two-ended problem: weather and capacity issues at origin delay departures, and when those same vessels finally reach port in Europe, they miss their planned berths and are forced to wait again, magnifying disruption throughout supply chains.

Congestion across key container gateways in Asia and Northern Europe is once again creating significant disruption with delays at Shanghai, Ningbo, Rotterdam and Antwerp increasingly feeding into one another and extending transit uncertainty across the entire east-west trade.

While individual delays at a single port are not unusual during peak season, the current challenge is the growing “cascade effect” developing across vessel schedules, inland transport networks and terminal operations.

In simple terms, disruption at one end of the trade lane is now directly increasing congestion at the other.

Weather disruption and vessel bunching hit China exports

Shanghai and Ningbo are both experiencing elevated congestion levels as heavy seasonal demand combines with poor weather, vessel bunching and continued schedule disruption linked to longer Cape routings.

Dense fog and adverse weather conditions around China’s east coast have already caused berth delays ranging from two to seven days at some Shanghai terminals, while Ningbo is also experiencing extended waiting times and increasing yard density pressure.

The knock-on effect quickly spreads through carrier schedules.

When vessels are delayed departing China, they frequently miss planned arrival windows into Northern Europe. Once that happens, carriers can lose their allocated berth slots, forcing vessels to wait offshore for new availability.

That creates a compounding cycle where both origin and destination ports become congested simultaneously.

Container equipment shortages are also worsening across major Asian export hubs as carriers struggle to reposition empty containers back into loading ports quickly enough to meet demand.

Rotterdam and Antwerp under mounting pressure

Northern Europe’s largest container hubs are now facing growing operational strain as delayed vessel arrivals collide with already congested inland transport networks.

Rotterdam and Antwerp are both reporting severe inland barge disruption, with waiting times regularly stretching towards four days. Yard utilisation remains extremely high across several terminals, while reduced crane availability, feeder delays and weather-related stoppages continue limiting operational fluidity.

Strong winds across Northern Europe have added further intermittent disruption, particularly at Antwerp, where terminals are struggling with vessel bunching and rising container dwell times.

The challenge extends far beyond the quayside.

As terminals prioritise delayed deep-sea vessels, inland barges often face secondary status within the operational flow, creating additional delays for hinterland cargo movement. In some cases, containers are remaining on terminals significantly longer than operationally ideal, increasing storage pressure and reducing yard efficiency.

Road and rail networks are also coming under increasing pressure as shippers divert cargo away from delayed barge services to avoid demurrage, detention and missed supply chain deadlines.

Inland transport disruption adds to the congestion cycle

The wider Northern European inland network is also becoming increasingly fragile.

Rail disruption across Germany, including infrastructure works, route closures and operational bottlenecks around Hamburg, is further complicating cargo flows into and out of the ports. Delayed trains, missed vessel connections and network overload are creating additional uncertainty for importers trying to maintain reliable inventory flows during an already volatile peak season environment.

This means delays are no longer isolated to one transport mode.

A weather delay in China can now create missed vessel berthing windows in Europe, which then impacts inland barges, rail schedules, feeder services and final cargo delivery timelines across multiple countries.

What this means for shippers

The current market reinforces how interconnected global container networks have become.

Longer transit times around the Cape of Good Hope have already reduced schedule reliability, while peak season demand and equipment shortages are tightening operational flexibility across both Asia and Europe.

For shippers, this creates growing importance around earlier booking windows, flexible inland transport planning and close coordination across origin, ocean and destination operations.

Importers moving time-sensitive cargo may increasingly need contingency planning around rail, road and barge options as congestion conditions continue evolving across Northern Europe during the summer peak period.

Metro combines global ocean freight expertise, proactive shipment management and integrated inland transport coordination to help customers minimise disruption and maintain cargo flow during volatile market conditions.

To discuss your supply chain planning, routing options or congestion mitigation strategies, EMAIL Managing Director Andrew Smith.

USMCA

USMCA renewal talks critical for North American manufacturing supply chains

The United States-Mexico-Canada Agreement (USMCA) is the legal and operational backbone of a $31 trillion North American trading bloc, and its renewal process is a live strategic risk factor for manufacturers and automotive brands active in the region.

Renewal negotiations are one of the most strategically important issues facing North American manufacturers, automotive brands and industrial supply chains.

While the agreement itself is not due to expire immediately, the failure to secure a straightforward 16-year renewal by the July 2026 review milestone is creating growing uncertainty across sectors heavily reliant on integrated US, Mexican and Canadian manufacturing operations.

The negotiations are particularly important for automotive, machinery, steel, aluminium and advanced manufacturing supply chains that have spent years restructuring production around the USMCA framework.

Why USMCA matters

The USMCA effectively underpins North America’s position as a highly integrated manufacturing bloc, supporting nearly $2 trillion in annual trade and deeply interconnected cross-border production networks.

The agreement provides the legal and operational framework that allows manufacturers to build complex regional supply chains with long-term investment certainty, streamlined customs processes and unified rules governing trade across all three countries.

That stability has become increasingly valuable as global manufacturers continue reducing dependence on long-distance Asian supply chains and accelerating near-shoring strategies closer to North American demand centres.

Mexico, in particular, has become a major beneficiary of this shift, offering shorter transit times, lower logistics risk and strong manufacturing integration with US production.

Automotive supply chains remain at the centre of negotiations

USMCA rules already require 75% of vehicle content to originate within North America for tariff-free treatment, helping drive major investment into regional automotive manufacturing and supplier networks.

Modern automotive production across North America is now deeply interconnected, with components often crossing borders multiple times before final vehicle assembly.

A single component may be stamped in Mexico, machined in the US and assembled into a finished vehicle in Canada or back in Mexico. That level of integration means even relatively small tariff or rules-of-origin changes can have significant operational and commercial consequences.

The Trump administration is now reportedly pushing for even higher US content requirements within vehicles as part of the renewal process, alongside broader efforts to bring more manufacturing activity back into the United States.

At the same time, steel, aluminium and automotive tariffs remain major areas of disagreement between the three countries.

Negotiations becoming more complex and politically sensitive

Formal negotiations between the US and Mexico are now under way, while Canada is still waiting to enter full trilateral discussions with Washington.

Current expectations are that the July review deadline will pass without a full agreement, triggering an extended review and negotiation period rather than an immediate collapse of the agreement itself.

In practical terms, USMCA would remain operational, but uncertainty around future rules, tariffs and investment conditions could persist for months or even years.

That uncertainty matters.

Manufacturers making long-term investment decisions around factories, tooling, supplier sourcing and critical minerals need confidence that North American trade rules will remain stable over the life of those investments.

The White House is also increasingly using separate bilateral negotiations alongside the formal USMCA review process, creating additional complexity around tariffs, automotive rules, steel, aluminium, labour standards and critical minerals.

For many manufacturers, the agreement is now viewed not simply as a trade deal, but as a strategic foundation for North American industrial resilience.

What this means for manufacturers and importers

For businesses operating across North America, the current environment reinforces the importance of supply chain flexibility, customs planning and close monitoring of trade policy developments.

Automotive, industrial and manufacturing sectors remain particularly exposed to any changes involving rules of origin, tariffs, customs procedures or regional content requirements.

While the direction of negotiations remains uncertain, all three governments continue publicly supporting the importance of maintaining a trilateral North American trade structure.

The challenge now is whether that shared strategic interest can overcome increasingly difficult political and economic negotiations.

Metro helps customers manage complex cross-border logistics, customs compliance and North American supply chain strategies across the US, Mexico and Canada.

To discuss your North American logistics requirements or USMCA-related supply chain planning, EMAIL Managing Director Andrew Smith.

container lorry queue

Capacity tightens and rates surge as peak season pressure builds

Asia–Europe and transpacific market conditions have shifted sharply in recent weeks, as strong demand tightens available space and enables carriers to push through higher spot rates and surcharges, even on shipments moving under long-term contracts.

Recent index data shows steady week-on-week gains, but forward indicators suggest a much steeper rise ahead. Pricing for early June shipments is already high and market signals indicate that rates could climb as high as $6,000–$7,000 per 40ft in the coming weeks, particularly as space tightens in the second half of June.

This demand spike is being driven by large-volume shippers accelerating shipments ahead of new bunker adjustment factors (BAFs) due to take effect from 1 July. These revised fuel charges are expected to increase significantly, prompting a surge in June volumes that is now placing further strain on capacity.

At the same time, carriers are increasing peak season surcharges (PSS) and signalling ongoing reviews. Initial increases are already being implemented in early June, with further upward revisions likely through the summer. Importantly, these surcharges are not being capped, creating continued upward pressure.

On the transpacific, the situation is following a similar trajectory. Capacity reductions, most notably the withdrawal of a key Asia–US East Coast service, have tightened supply, while carriers are taking a more aggressive stance on rate increases. Although recent index movements have been moderate, multiple general rate increases (GRIs) have been announced for June, pointing to a much firmer market ahead.

Contract conditions are also shifting. Previously available rate offers are being withdrawn or replaced with higher-priced agreements, and in some cases, revised terms are becoming commercially unviable. Across both major east–west trades, current expectations are that elevated rate levels and constrained space will persist through June and July, with the potential to extend into August.

For shippers, this creates a highly compressed and competitive freight environment. Securing space is becoming increasingly dependent on rate acceptance, and delays in booking or pricing decisions are likely to result in higher costs or missed sailings.

Metro’s Advice

If you have upcoming shipments, early planning and rapid booking decisions are critical.

  • Expect continued upward pressure on both spot and contract rates through June and into July
  • Allow for additional surcharges, particularly PSS and revised fuel costs
  • Plan for reduced flexibility, with limited space availability on key sailings
  • Anticipate further volatility as carriers adjust pricing in line with demand

Metro’s teams are actively monitoring capacity, pricing movements, and carrier strategies to secure the best possible options for our customers.

Contact your Metro account manager today to review your shipping forecast, secure space, and minimise cost exposure in an increasingly constrained market.

This story was first reported in The Loadstar and can be viewed HERE