Trade policy stability brings time for better import planning

U.S. trade actions have shifted from escalation to stabilization in recent months. Tariff relief and exemptions announced since mid-October signal a pause in pressure, likely creating a six-to-12-month window for businesses to do better import planning and execution. Shippers may have fewer surprises and more time to optimize sourcing strategies.

One exception to relative trade stability is India. As both China and the United States vie for India’s loyalties, a trade deal has remained elusive and U.S. tariffs on many goods from India remain at 50%. More volatility is expected regarding India trade policy than with other countries.

The U.S.–China trade war has entered what appears to be a truce. While both economies have taken hits, both sides have paused tariff hikes and offered concessions: the United States on tariff rates and maritime fines, and China on rare earth exports. This détente is scheduled to hold for a year, giving businesses breathing room to solidify tariff mitigation strategies and sourcing diversification.

C.H. Robinson customers are moving steadily along the sourcing hierarchy: first diversifying from China to nearby markets like Vietnam, then friendshoring, then nearshoring into North America, and possibly reshoring. In this environment, advanced customs brokerage and compliance services have emerged as critical supply chain advantages. Increased scrutiny on country of origin and valuation and potential elimination of foreign importer of record is expected in 2026.

The White House's focus is now shifting to the U.S.-Mexico-Canada Free Trade Agreement (USMCA). With the scheduled 2026 review already well under way, the public negotiating style of the U.S. administration may create some temporary shocks. Once settled, some potentially important adjustments could be made in certain sectors such as automotive, energy, or agriculture.

U.S. Supreme Court tariff case

The Supreme Court is expected to decide in December or January whether the president’s broad tariff actions under the International Emergency Economic Powers Act (IEPPA) will stand or face limits. If the court narrows executive authority, it is anticipated that the administration will lean more on established authority to impose commodity-specific and country-specific tariffs. While importers hope for relief through IEEPA refunds, U.S. Customs and industry associations have tried to temper expectations of any timely or robust refund process.

Trade deal reduces U.S. tariffs on imports from South Korea

Following a deal announced in November, a December 3 notice provided guidance on reduced duties for goods of South Korean origin. Reciprocal tariffs, 232 tariffs on automobiles and auto parts, and 232 tariffs on wood products will be capped at 15% for goods with a Column 1-General or Column 1-Special rate less than 15%. Where these rates are greater than 15%, those reciprocal and 232 tariffs will have a duty rate of 0%. Also, qualifying civil aircraft, their engines, parts, and components will be exempt from any reciprocal or 232 tariffs.

The revised rates will be retroactive for goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern time November 14, 2025.

Expanded U.S. tariff exemptions on imports from Brazil

An executive order in November modified the scope of tariffs imposed on Brazilian goods in a July executive order. Changes to the annexes added hundreds of agricultural products including coffee, fruits, and spices as well as energy products and aircraft parts that are exempted from the 40% reciprocal tariff. The exemptions are retroactive for goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern time November 13, 2025.

Exclusions to 301 China tariffs extended

The 178 exclusions to the Section 301 China tariffs have been extended. These retaliatory tariffs are connected to China's technology transfer and intellectual property practices. Exclusions for certain products of China origin had been set to expire on November 29, 2025, and will now continue until November 10, 2026.

CPSC mandatory filing still on track for mid-year 2026

Reminder that the Consumer Product Safety Commission (CPSC) will have mandatory reporting on imports effective July 8, 2026. The government agency will flag approximately 2,500 Harmonized Tariff Schedule (HTS) codes that will require a certificate data filing or disclaim message with the customs entry filing of each flagged product. CPSC has created a Product Registry where importers can store and manage their product certificate data.

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