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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.

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.

USMCA

USMCA renewal talks critical for North American manufacturing supply chains

Jun 9, 2026 | , , , , , ,

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.

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