Simply Trade

Host: Lalo Solorzano

Why wait until January to fix the trade compliance problems you can start addressing today? In the kickoff to 90 Days Until 2027, Lalo Solorzano launches a 13-part Simply Trade [TIPS] series with Miriam Name of Cacheaux, Cavazos & Newton (CCN). Their starting point: the documentation behind your USMCA certifications of origin.

As companies prepare supplier solicitations and next year’s blanket certificates, Miriam asks a more important question than whether the paperwork has been signed: can you support it? Drawing on her experience with audits involving Mexico, she discusses what happens when invoices disappear, qualification calculations leave with a former employee, or the person signing a certification does not understand its basis.

Lalo and Miriam explore why collecting documents is only part of the job. Those records also need to be accessible and available when someone asks how a product’s origin was determined. They discuss the limitations of scattered emails and manual workflows, along with the role software can play in supporting the process.

This opening episode sets the tone for the series: practical improvements now, rather than another compliance resolution in January. Start with your USMCA files—and find out whether your team can back up what it signs.

The first preparation task is to review your USMCA origin documentation before the next certification cycle. The conversation connects supplier solicitations, qualification methodology, signer knowledge, and accessible supporting records.

Miriam also cautions exporters against assuming that a commercial agreement assigning import costs to a customer resolves the risks associated with certifications they have issued. Her closing recommendations focus on self-audits: checking certification details against importer and shipment information, reviewing methodology consistency on blanket certificates, and declining to certify when origin is uncertain.

• Start before renewal season becomes a scramble. Begin supplier solicitations early and review the documentation supporting the products you plan to certify.

• Know who is signing—and what they understand. Miriam urges companies to confirm that the signer understands the basis for the certification and not to issue one when origin is uncertain.

• Keep the evidence accessible. Review supplier documents, raw-material invoices, and qualification calculations rather than relying on one person’s inbox. For Mexico, Miriam recommends retaining supporting documentation for at least five years.

• Self-audit the details. Cross-check certifications against importer and shipment information. Miriam also recommends consistency in the methodology used for blanket certifications and considering separate certificates for products using different methodologies.

• Global Training Center

• Miriam Name — LinkedIn

• Cacheaux, Cavazos & Newton (CCN)

• USMCA Management Software - RAIZ

The 90 Days Until 2027 companion playbook is in development, with practical resources planned to grow alongside the series. Follow Simply Trade for release updates.

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Host: Lori Mullins & Karen Damon

The pace of change in international trade isn’t slowing down—and customs brokers, freight forwarders, importers, and compliance professionals need to know what’s coming next.

In the October NCBFAA President’s Recap, presented in partnership with Simply Trade and Global Training Center, Lori Mullins sits down with NCBFAA President Karen Damon following the association’s sold-out Government Affairs Conference.

Karen takes listeners behind the scenes of NCBFAA’s advocacy efforts on Capitol Hill and explains why transparency and advance notice remain critical when new tariffs and regulatory requirements are introduced. The conversation also examines CBP’s increasing focus on enforcement and why licensed customs brokers are being viewed as an important “force multiplier” in protecting revenue, improving data accuracy, supporting security, and keeping legitimate trade moving.

They also tackle a deadline licensed customs brokers cannot afford to overlook: the 2027 triennial report and continuing education requirements.

Finally, Karen looks ahead to what could dominate trade conversations over the coming months—including supply-chain tracing, CTPAT obligations, enhanced importer responsibilities, and CBP’s push for greater supply-chain visibility.

This month’s President’s Recap focuses on a trade environment increasingly shaped by enforcement, supply-chain transparency, regulatory change, and industry advocacy.

Following NCBFAA’s Government Affairs Conference, Karen discusses the importance of bringing the trade community’s perspective directly to policymakers. She also explains why predictable implementation timelines are essential when tariffs and other requirements change. Brokers and importers need time to understand new rules, educate their teams, update software, and transmit accurate information.

The conversation then turns to CBP enforcement and the evolving responsibilities of importers and customs brokers. Karen describes brokers as an important “force multiplier” capable of helping CBP facilitate legitimate commerce while supporting security, accurate data, revenue collection, and compliance.

Licensed customs brokers should be preparing now for the 2027 triennial reporting cycle.

Karen emphasizes the importance of maintaining documentation supporting continuing education credits. Lori challenges listeners to contact fellow licensed customs brokers—and importer colleagues who hold licenses—to make sure they are preparing as well.

Karen identifies two issues she believes the industry will still be discussing six months from now: supply-chain tracing and CTPAT obligations affecting customs brokers.

She encourages importers, exporters, customs brokers, and other trade professionals to pay attention to CBP’s developing supply-chain visibility requirements and participate in the regulatory process when opportunities for public comment arise.

• NCBFAA’s Government Affairs Conference gives industry professionals an opportunity to educate policymakers about trade facilitation and the practical impact of regulatory changes.

• Advance notice for tariff and regulatory changes is essential for compliant implementation, including updates to CBP systems and brokerage software.

• Customs brokers increasingly serve as a “force multiplier” by supporting CBP’s security, trade facilitation, data accuracy, and revenue-collection missions.

• Brokers and importers should closely monitor evolving requirements involving importer records, ownership information, bonds, foreign importers, and supply-chain transparency.

• Licensed customs brokers need to prepare for the 2027 triennial report and retain documentation supporting their required continuing education credits.

• NCBFAA committees and volunteers continuously monitor regulatory developments and create alerts, articles, FAQs, toolkits, and other resources for members.

• Supply-chain tracing and evolving CTPAT obligations are likely to remain major issues for the trade community.

• Global Training Center

• NCBFAA

• Lori Mullins - LinkedIn

• Karen Damon - LinkedIn

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Host: Cindy Allen

What should trade teams watch when tariff negotiations, court challenges, and customs procedures are all moving at once?

In this October 2 edition of Simply Trade—Cindy’s Version, Cindy Allen uses Taylor Swift’s “My Boy Only Breaks His Favorite Toys” as the starting point for a discussion about trade relationships and operational uncertainty. She examines developments involving China, Canada, and Mexico, alongside the questions they raise for importers, customs brokers, and cross-border supply chains.

The update moves from proposed Section 301 tariff reductions and the U.S.–China trade truce to international discussions about excess capacity and steel melt-and-pour information. Cindy also reviews tariff litigation before turning to practical matters: continuing education records, importer-of-record status, CTPAT validation, low-value postal entries, and pharmaceutical tariff reporting.

Throughout the episode, Cindy connects policy discussions with the follow-through required of trade professionals. Her closing message is to prepare for further changes rather than assume temporary arrangements will settle long-term planning questions.

For listeners balancing developments in Washington and abroad with day-to-day customs responsibilities, this episode offers a focused overview of what Cindy is watching—and the operational details she encourages listeners to review.

Topics Cindy discusses in this episode:

• China trade developments: Proposed Section 301 tariff reductions, an anticipated comment period, and the U.S.–China trade-truce extension.

• Global trade and the courts: Excess-capacity discussions, steel melt-and-pour transparency, and tariff challenges involving Sections 301 and 122.

• CBP updates: Broker education and applications, importer records, CTPAT, Entry Type 13, and pharmaceutical tariff reporting.

• North America and transportation: Canadian product restrictions, USMCA negotiations, and shipping concerns involving the Strait of Hormuz.

The central discussion is how evolving trade relationships intersect with everyday customs work. Cindy uses this week’s song as an organizing theme for examining U.S. trade relationships with Canada, Mexico, China, and other trading partners.

She connects that broader discussion with operational readiness: monitoring tariff proposals and court cases, maintaining broker education documentation, checking importer records, and following CBP filing guidance. The episode brings policy developments and administrative details into the same conversation, encouraging listeners to account for both when planning their next steps.

• Watch the process, not just the announcement. Follow comment periods and implementation guidance as proposed tariff changes develop.

• Keep broker education records current. Review completed credits and supporting documentation ahead of the next triennial reporting cycle.

• Review importer and broker readiness. Pay attention to importer-of-record status, Form 5106 information, and applicable CTPAT requirements.

• Prepare for continued change. Keep trade negotiations, tariff litigation, steel-origin information, and CBP reporting guidance on your monitoring list.

• Global Training Center

• USTR: Section 301 Investigations

• CBP: Customs Broker Continuing Education

• CBP: Customs Trade Partnership Against Terrorism—CTPAT

• Episode song: Taylor Swift, “My Boy Only Breaks His Favorite Toys.”

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Host: Andy Shiles

What does “free” truck parking really cost when a driver has to travel miles out of the way to reach it? In this episode of Simply Trade, Andy Shiles talks with Evan Shelley, founder of Truck Parking Club, about treating parking as an operational decision—not simply an expense to avoid. Their conversation explores the trade-offs between parking fees, unnecessary mileage, available driving time, and driver stress.

Evan explains how Truck Parking Club connects drivers, dispatchers, and fleet managers looking for parking with property owners who have suitable space available. The discussion goes beyond overnight stops to cover trailer drop-offs, multiday stays, and longer-term equipment storage. Along the way, Andy and Evan consider why access to the right parking location can matter as much as the price of the space itself.

There’s another side to the conversation for warehouse operators, trucking terminals, repair shops, and other businesses with unused room. Evan describes how those spaces can become parking opportunities—and why a property doesn’t necessarily need to be large or located beside a major interstate to meet a driver’s needs. For anyone managing trucks, coordinating freight, or overseeing commercial property, this episode offers a practical look at an often-overlooked part of transportation operations.

Andy and Evan explore truck parking from both sides of the marketplace: helping drivers and fleets find suitable places to stop while helping property owners put unused capacity to work. Evan describes the platform’s booking tools, property information, and support for parking operators. At the time of recording, he reports more than 6,300 locations across all 50 states.

The following timestamps mark discussion segments in the transcript.

• 02:48 — How the marketplace works: Connecting parking demand with available property space.

• 12:13 — Finding and booking a spot: Using availability, photos, reviews, and amenities to evaluate locations.

• 13:05 — Pricing and membership options: Marketplace rates, volume discounts, and loyalty benefits.

• 17:32 — Beyond overnight parking: Multiday stops, trailer drop-offs, and longer-term storage needs.

• 21:18 — The fleet business case: Evaluating parking through safety, efficiency, out-of-route miles, and driver experience.

• 30:45 — Opportunities beyond major markets: Why rural properties and smaller locations can still meet meaningful parking needs.

• Compare the whole trip—not just the parking fee. Andy and Evan discuss how a free space farther away may involve additional fuel, mileage, and time compared with a nearby paid option.

• Parking needs extend beyond overnight rest. The conversation includes trailer drops, multiday parking, and longer-term equipment storage—not just finding somewhere to sleep.

• Suitable unused space can create a revenue opportunity. Evan explains how warehouses, trucking terminals, repair shops, and other properties can participate, including locations with only one available space.

• Location value depends on the driver’s needs. Evan highlights how a rural property could help a local driver park closer to home, even when the site is not near a major interstate.

• Global Training Center

• Truck Parking Club

• Connect with Evan Shelley on LinkedIn

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Host: Lalo Solorzano

DDP can sound like the perfect solution for a customer: the seller handles everything and delivers the goods. But for the seller, Delivered Duty Paid can bring obligations and costs that aren't always obvious when the deal is made.

In the final installment of this four-part Simply Trade Tips series, host Lalo Solorzano and Arthur O’Meara return to Incoterms® to examine DDP. Arthur, an Incoterms® instructor certified by the International Chamber of Commerce, explains why sellers need to understand a destination country's importer-of-record requirements before agreeing to DDP.

Using Canada as an example, Arthur explores non-resident importer registration and the potential impact of GST. He also explains an important distinction: free trade agreements may address duties, but that doesn't mean other taxes disappear.

The conversation then flips the scenario to U.S. imports, where Arthur explains why having a foreign supplier act as importer of record doesn't automatically reduce the dutiable value or eliminate the U.S. buyer's exposure to Customs questions.

The series ends with a straightforward lesson: do your homework before something goes wrong. Edit-16---Arthur-Lalo-Take-04 (…

This episode focuses on DDP (Delivered Duty Paid) and the obligations sellers can assume when agreeing to this Incoterms® rule.

Arthur explains that DDP places extensive responsibilities on the seller, including obligations surrounding import customs clearance. That can create an immediate complication when selling into countries that require an importer of record to maintain an in-country presence.

Even where non-resident importer provisions exist, additional tax considerations may arise. Arthur uses Canada to illustrate how an American seller could become a non-resident importer and still encounter GST obligations that are separate from customs duties.

Lalo and Arthur also discuss the importance of educating departments outside trade compliance—particularly sales and purchasing—so Incoterms® aren't selected simply because they make a transaction easier to close.

Finally, Arthur addresses the misconception that using a foreign supplier as importer of record into the United States automatically creates a lower dutiable value. His broader point: the Incoterms® rule and importer-of-record structure should be chosen strategically, not simply because they appear convenient. Edit-16---Arthur-Lalo-Take-04 (…

• DDP creates significant seller obligations: Understand what you're agreeing to before promising a customer that you'll “take care of everything.”

• Check importer-of-record requirements: Countries can have different rules governing whether a foreign seller can serve as importer of record.

• Duty-free doesn't necessarily mean tax-free: Arthur emphasizes that free trade agreements address duties, while other taxes such as VAT or GST can still apply.

• Train sales and purchasing teams: Incoterms® decisions shouldn't exist only within the trade compliance department. Commercial teams need to understand the consequences of the terms they negotiate.

• Don't assume changing the importer of record reduces dutiable value: Arthur explains why making the foreign supplier the importer of record does not automatically mean duties will be calculated using the supplier's production cost.

• Do your homework: “This is how we've always done it” isn't a substitute for understanding the transaction and preparing before something goes wrong.

• Global Training Center

• Incoterms® Training — Explore training on Incoterms® rules, buyer and seller responsibilities, risk, costs, and international transactions.

• Import Compliance Training — Training for professionals responsible for U.S. import compliance and Customs requirements.

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Host: Lalo Solorzano

The writing has been on the wall for a while. This week, some of those warnings turned into dates, duty rates, filing requirements, and even an import prohibition.

With Cindy Allen traveling for the NCBFAA GAC conference, Lalo Solorzano takes over the weekly trade update — swapping Taylor Swift for Iron Maiden and looking at several developments that trade professionals can no longer leave in the “watching” category.

At the top of the list are new restrictions affecting certain Canadian goods. Beginning September 29, covered packaged alcoholic beverages, dairy products, and motorcycles face exclusion from importation into the United States under Section 338 — moving the conversation beyond the earlier 50% additional duties.

Lalo also covers CBP’s upcoming electronic export manifest test for truck cargo, important AD/CVD developments involving products from China, Mexico, and India, and the October 6 launch date for Phase 3 of CBP’s CAPE process for certain finally liquidated IEEPA entries.

The message for trade professionals is straightforward: go back to your watch list. Yesterday’s developing issue may now have a deadline, a rate, a filing requirement, or a direct impact on whether goods can enter the country.

This week’s developments demonstrate how quickly trade issues can move from proposals and preliminary actions into operational requirements.

Beginning September 29, certain Canadian packaged alcoholic beverages, dairy products, and motorcycles will be excluded from importation into the United States. The exact product coverage and HTS classification matter, and goods imported before the effective date may receive different treatment under the earlier 50% Section 338 duty.

For importers, this creates immediate questions around classification, shipment timing, entry status, sourcing, and product eligibility.

CBP will begin a roughly two-year electronic export manifest test for truck cargo on October 23, initially involving nine carriers.

Participating carriers will provide certain export-manifest information through ACE at least 24 hours before departure, with the complete manifest due no later than two hours before arrival at the final port of export.

The test reinforces a broader direction: CBP wants export information earlier, potentially requiring carriers, forwarders, USPPIs, and other parties to adjust their processes.

Commerce preliminarily determined that certain compacted graphite iron brake drums from China constitute later-developed merchandise circumventing existing AD/CVD orders.

Other developments include a preliminary 56.43% dumping margin in the administrative review of seamless refined copper pipe and tube from Mexico and final affirmative ITC injury determinations involving oleoresin paprika from India.

The lesson: AD/CVD exposure is not static. Product scope, rates, circumvention findings, and cases can change after a sourcing decision has been made.

CBP says CAPE Phase 3 is scheduled to open October 6 for certain finally liquidated entries tied to litigation.

This does not apply broadly to every importer with finally liquidated IEEPA entries. According to the episode, the phase currently applies to importers that filed their own lawsuit and have a court order permitting those entries to be reliquidated.

Affected companies should review entry coverage, importer-of-record information, and ACH refund information.

• Review Canadian imports now if your company handles products potentially covered by the September 29 Section 338 prohibition.

• Prepare for an environment where CBP increasingly expects export information earlier in the shipment process.

• Monitor AD/CVD cases continuously — product coverage, circumvention decisions, duty rates, and sourcing economics can change.

• Revisit your company’s compliance “watch list.” Developing issues may now have firm dates, rates, requirements, or restrictions requiring action.

• Global Training Center

• U.S. Customs and Border Protection (CBP)

• U.S. Department of Commerce

• U.S. International Trade Commission (ITC)

• Automated Commercial Environment (ACE)

• Customs Automated Processing of Entries (CAPE)

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Host: Lalo Solorzano & Andy Shiles

CBP has put 64 questions before the trade community—but are they really just questions, or a preview of where U.S. import compliance is headed?

In this episode, Lalo Solorzano and Andy Shiles sit down with licensed customs broker Humberto Caballero of XP Logistics & Trade to unpack what these questions could mean for importers, customs brokers, manufacturers, and trade compliance teams.

Drawing on his experience with both U.S. and Mexican customs, Humberto boils the discussion down to three critical concepts: right to make entry, traceability, and accountability.

The conversation explores why CBP may increasingly expect importers to understand what happens before goods reach the U.S. border—including foreign export documentation, transaction values, supplier information, manufacturer identification, sourcing, and payment records.

The team also digs into the challenges surrounding Manufacturer Identification Numbers (MIDs), supplier due diligence, CTPAT, and the growing need for trade compliance professionals to have a seat at the table before sourcing and purchasing decisions are finalized.

The message for importers is clear: start preparing now rather than waiting for new requirements to arrive.

CBP's 64 questions point toward a potentially significant evolution in how importers document, verify, and demonstrate compliance.

Humberto organizes the underlying issues into three areas: right to make entry, traceability, and accountability. Importers may need greater visibility into their foreign suppliers, export documentation, transaction history, sourcing, manufacturer information, and the parties receiving the economic benefit of a transaction.

The discussion also highlights the increasing importance of aligning trade compliance with purchasing, sourcing, logistics, and foreign operations. Instead of bringing compliance professionals in after a problem occurs, companies should involve them before suppliers are approved and transactions begin.

Particular attention is given to foreign documentation and Manufacturer Identification Numbers (MIDs). Inconsistent manufacturer information can create complications when companies, customs brokers, and government programs are trying to establish who actually manufactured or exported merchandise.

The episode also examines how U.S. compliance expectations appear to be moving toward greater traceability and how those expectations compare with practices Humberto has experienced in Mexico.

• Humberto summarizes the themes behind CBP's 64 questions as right to make entry, traceability, and accountability.

• Importers should understand not only what they are importing, but also who they are doing business with and how their suppliers source materials.

• Foreign export documentation, purchase orders, invoices, payment records, transaction values, and manufacturer information could become increasingly important parts of demonstrating traceability.

• Manufacturer Identification Numbers can become inconsistent when different parties construct an MID differently or use different addresses for the same company.

• Supplier due diligence should involve trade compliance—not just sourcing and purchasing.

• Companies should consider maintaining reliable supplier data such as foreign tax IDs, DUNS information, manufacturer details, and applicable MIDs in their internal systems.

• CTPAT continues to evolve beyond its original security focus, making traceability and trade compliance increasingly important considerations for participating companies.

• A strong trade compliance function can be a competitive advantage, particularly when compliance professionals are involved before transactions occur rather than being asked to fix problems afterward.

• Global Training Center

• Humberto Caballero on LinkedIn

• CBP's 64 questions and proposed import disclosure concepts discussed during the episode

• CTPAT and evolving trade compliance expectations

• Executive Order 14411, as discussed during the episode

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Host: Lalo Solorzano

Recordkeeping may not be the most exciting part of trade compliance, but Arthur O’Meara has one word for what can happen when companies get it wrong: draconian.

In Episode 3 of this Simply Trade Tips series, host Lalo Solorzano and Arthur tackle an often-overlooked part of import compliance: keeping the records you may need when Customs comes asking. Arthur explains why the A1A recordkeeping list can initially seem intimidating—and why compliance doesn't necessarily mean copying every document into one massive entry file. Instead, companies should understand what records are required, know exactly where those records are maintained, and periodically verify that they remain accessible.

The conversation also addresses a practical challenge facing trade professionals: when tariffs, classification changes, and other urgent issues consume your time, routine compliance tasks can slip down the priority list.

Arthur's recommendation? Make recordkeeping part of your annual compliance goals. It's a manageable exercise that can help protect the company before a CBP request puts your records to the test.

This episode focuses on establishing a practical and sustainable approach to trade recordkeeping.

Arthur explains that companies don't necessarily need to duplicate every required document and store everything alongside their entry records. Using purchase orders as an example, he suggests documenting where the records are maintained—such as within purchasing or procurement—and periodically confirming that the responsible department continues to retain them.

The important question is whether the company can produce the required records when they're requested.

Arthur also discusses what can happen when CBP sends a CBP Form 28 Request for Information. At that point, the trade compliance professional may suddenly need to locate marketing literature, transaction documentation, or other records while working against a response deadline.

His preferred approach is proactive: periodically review the company's recordkeeping practices before a government request arrives.

• Don't let the A1A list overwhelm you: Understand which records actually apply to your transactions rather than assuming every item on the list belongs in every file.

• Know where your records live: A document doesn't necessarily have to be duplicated into one centralized file if you can identify where it's maintained and retrieve it when necessary.

• Periodically verify accessibility: Don't assume another department is still retaining a record simply because it was there the last time you checked.

• Prepare before a CBP Form 28 arrives: A request for information is not the ideal time to discover gaps in your recordkeeping process.

• Make recordkeeping an annual goal: Arthur describes it as an “easy win” that doesn't have to consume significant time but can help protect the company.

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• Lalo Solorzano

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Host: Cindy Allen

International trade keeps changing—but are businesses, policymakers, and trade professionals changing with it?

In this episode of Simply Trade Cindy’s Version, Cindy Allen uses Taylor Swift’s “Right Where You Left Me” as the lens for a packed week in international trade. Cindy covers developments ranging from CBP refund processing and importer-of-record enforcement to the Jones Act, rail export manifests, trucking challenges at the southern border, ocean freight congestion, and ongoing uncertainty surrounding global shipping.

She also turns to the bigger question facing the trade community: Are we still approaching tariffs and trade policy as if the world hasn’t changed?

Cindy shares her perspective on when tariffs may serve a strategic purpose, including national security and critical supply chains, while questioning whether broad tariffs by themselves can accomplish larger policy objectives. Her message for businesses is straightforward: regardless of where the policy debate goes next, companies need to prepare for an international trade environment that looks very different from the one they knew a decade ago.

The challenge isn’t just keeping up with the latest regulation. It’s recognizing when the assumptions behind your trade strategy need to change.

• CBP refund processing, CAPE Phase 3, and ACE refund account challenges

The central question this week is whether the trade community is “right where you left me”—holding onto assumptions about tariffs, sourcing, supply chains, and trade policy that were formed in a very different environment.

Cindy discusses her view that tariffs can be one tool for addressing specific national security, health, and supply-chain concerns, but argues that tariffs alone cannot create domestic manufacturing capacity or solve broader economic challenges.

Using pharmaceuticals and metals as examples, she explains why incentives, investment, production capacity, and long-term strategy need to work alongside trade policy.

The broader takeaway for importers and trade professionals: the operating environment has changed. Rather than waiting for international trade to return to an earlier version of “normal,” companies should evaluate what the current environment means for compliance, sourcing, investment, and long-term planning.

• Importers should review the information associated with their importer-of-record numbers and ensure their CBP records are accurate and current.

• Refund processing can still create operational challenges, particularly when importers do not have the necessary ACE refund information established.

• Global logistics remain exposed to congestion and geopolitical disruption, making continued supply-chain monitoring important.

• Trade strategy should focus not only on individual tariff actions, but also on the larger business objective: what problem needs to be solved, and what combination of tools can address it?

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Host: Lalo Solorzano and Andy Shiles

Tariff engineering isn’t just a compliance exercise—it can become a powerful strategy for reducing landed costs, improving sourcing decisions, and strengthening profitability.

In this episode of Simply Trade, Lalo Solorzano and Andy Shiles welcome back Hal Berman and John Petitte of Trade Insight for a practical discussion about how companies can approach tariff engineering as a cross-functional business initiative.

The conversation explores why successful duty optimization requires much more than finding a different tariff classification. Engineering, sourcing, procurement, finance, operations, tax, supply chain, and compliance may all hold pieces of the information needed to determine whether a change actually makes financial sense.

Hal and John share examples involving product design, component sourcing, final assembly, free trade agreements, and duty exposure to illustrate how relatively small changes can potentially produce meaningful savings. They also discuss the role of AI as a research and productivity tool for trained trade professionals—not as a replacement for human judgment.

The bigger lesson: companies can get more value when trade considerations enter the product lifecycle earlier, rather than waiting until goods reach the border.

Tariff engineering is the process of evaluating how legitimate changes to a product's design, materials, sourcing, manufacturing, assembly, or supply chain can affect tariff treatment and overall landed cost.

The discussion emphasizes that effective tariff engineering requires a holistic view. A lower duty rate alone doesn't necessarily make a change worthwhile. Companies must consider supplier agreements, manufacturing costs, labor, logistics, tax implications, compliance requirements, and other costs before determining the actual return on investment.

Compliance may help lead the analysis, but the necessary information often lives throughout the organization. Engineering understands product design. Procurement and sourcing understand suppliers and contracts. Finance can evaluate ROI. Operations and supply chain understand manufacturing and logistics constraints.

Executive sponsorship can help these groups work toward the same objective instead of leaving compliance to pursue optimization opportunities alone.

Rather than reviewing every SKU at once, the conversation suggests identifying products associated with significant duty spend and evaluating specific opportunities.

Even when the first project doesn't uncover savings, the exercise can establish a repeatable framework: which questions need to be asked, who owns the information, what constraints matter, and which stakeholders need to participate.

Over time, tariff considerations can move earlier in the product lifecycle and potentially become part of product and supply-chain design.

AI and technology can help trade professionals research classifications and analyze much larger product libraries, but the episode stresses the importance of human involvement and transparent reasoning.

The objective is to give trained professionals better tools, clearer supporting rationale, and greater capacity—not simply automate away the compliance function.

• Tariff engineering goes beyond finding a lower duty rate; companies should evaluate total landed cost and overall ROI.

• The strongest opportunities can involve product design, materials, sourcing, manufacturing location, final assembly, free trade agreements, and other special tariff provisions.

• Compliance cannot effectively execute tariff optimization alone. Engineering, finance, sourcing, procurement, operations, supply chain, tax, and other stakeholders may need to participate.

• Executive sponsorship can help transform tariff optimization from an isolated compliance project into an ongoing cross-functional business process.

• Starting with high-duty products can create a manageable pilot project and establish a framework that can later be repeated across additional SKUs.

• Bringing trade considerations into the product-development process earlier can give engineers and sourcing teams additional information when making design and supplier decisions.

• AI can expand research and classification capacity, but trained trade professionals and human judgment remain central to defensible compliance decisions.

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