
Recommendation: Reallocate procurement for automobiles and raw materials now: map top HTS lines, negotiate clauses that give price relief if duties rise, and identify suppliers that can shift production within 60–90 days to avoid stoppages. Pause nonessential capital projects that rely on vulnerable imports and implement weekly landed-cost reviews to detect tariff shocks early.
march 2018 marked the first major move when the administration imposed 25% tariffs on steel and 10% on aluminum under Section 232; those measures then triggered retaliatory measures abroad. On July 6, 2018 the U.S. applied a 25% duty on a $34 billion list of Chinese goods under Section 301, followed by a $16 billion list on August 23, 2018. A wider $200 billion list began at 10% on September 24, 2018 and soared to 25% by May 2019; the administration later signaled potentially similar duties on automobiles and auto parts.
Measureable impacts followed: targeted imports fell in several categories while domestic prices for steel and some metals rose, and global sourcing patterns shifted to Southeast Asia and Mexico. That shift sits in recent history as a clear structural change for supply chains; internal scenario runs (codename howard) show margin compression of 3–8% on affected product lines if duties remain at current levels. Track monthly import data, update price books about each tariff adjustment, and run two contingency plans for immediate and 90-day responses.
Engage the commerce secretary‘s office and trade counsel with concise briefs: list the top 20 HTS lines by import value, quantify landed-cost increases under current tariffs, and propose targeted relief or compensation. Some firms are already pausing production runs and rerouting components; give operations clear trigger points for pausing orders and start negotiating supply agreements that include duty adjustment clauses to stabilize margins.
January 20: Specific Tariff Actions, Notices and Immediate Targets
Notify customers and customs brokers immediately: prioritize imports affected by january 20 tariff notices, reallocate at-risk stock to protected domestic suppliers, renegotiate delivery windows and short-term contracts to protect cash flow and supply continuity with effective written notices.
On january 20 the administration released targeted controls and tariff actions–Section 232 (25% on steel) and 10% on aluminum, plus Section 301 levies of 10–25% on selected Chinese goods; firms found importing listed HS codes must expect new duties and the government can impose additional finance restrictions tied to anti-trafficking and sanction screening.
These measures echo trumps campaign trade posture and target the metals sector, solar components and select electronics; expect protected producers to be somewhat insulated while import-dependent firms face declining margins and pressure on working capital.
Action plan: within 0–7 days notify banks and insurers to help secure trade finance, file immediate exclusion requests for critical inputs, and work together with major suppliers to hedge shipments; within 7–30 days renegotiate pricing and terms, switch some orders to alternative suppliers, and monitor customs entries for stock discrepancies found after the notices.
Expect short-term progress if firms use inventory loans and tariff-bond strategies; where Canada remains a major source, analyze whether exemptions apply or whether partners in canada can import under quota to prevent supply shocks.
What tariff rates and HS codes were introduced or changed on January 20?
No tariff rates or HS codes were formally changed on January 20; the administration signaled trade policy shifts that created a trail of measures later implemented by the Department of Commerce and USTR.
The January 20 development suggests policy intent rather than immediate legal changes. Subsequent actions that grew out of that direction included: Section 232 steel and aluminum tariffs (March 23, 2018) – 25% on many steel products (HS chapter 72, commonly cited HTS headings 7206–7229) and 10% on many aluminum products (HS chapter 76, HTS 7601–7607); and Section 301 tariffs on Chinese goods (2018) – 25% on multiple 6‑digit HTS lines across Lists 1–3 (effective dates July 6, 2018; September 24, 2018 for broader lists). Those later measures increased costs for materials and machines and affected semiconductor supply chains (HS 8541 and related subheadings), wooden goods (HS chapter 44 and HTS 9403 for furniture), and other competing product lines in US markets.
Actionable recommendations: classify your imports to the proper 6‑digit HTS codes (focus first on HS chapters 72, 73, 76, 84, 85, 44, 94), model tariff impact by SKU, and file for a CBP binding ruling where needed. Coordinate together with purchasing, legal and customs teams to evaluate alternative suppliers and tariff‑engineering options for machines and semiconductor components. Monitor Federal Register notices from the department and USTR, submit exclusion requests where promising, and prepare documentation that demonstrates security or supply‑chain risk if you seek to overturn applied duties. Taking these steps now reduces exposure if measures later increase or expand to additional HTS lines.
Which countries, exporters and product lines were directly designated on that date?
Recommendation: Prioritize immediate review of shipments and contracts from China, the EU, Canada, Mexico, South Korea, Japan, Vietnam and specific US exporters of pork and semiconductors; reprice exposures to the announced levies and secure finance lines to absorb swift shocks.
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China (Section 301)
- Designated products: semiconductors, textiles, electronics, machinery and a dozen other industrial and consumer categories; the full lists covered roughly $200–250 billion in imports and in some rounds shifted from 10% to 25% rates.
- Designated exporters: large coastal manufacturers and many state-affiliated suppliers supplying chips and finished electronics where competing suppliers exist in emerging Asian markets.
- Impact and advice: data suggests supply chains shifted toward Taiwan and South Korea; buyers should lock contracts, identify alternate suppliers, and verify tariff classification codes immediately.
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Steel and aluminum (Section 232)
- Designated countries: EU, Canada, Mexico, South Korea, Brazil and others faced a same levy structure initially – steel at 25% and aluminum at 10% – though exemptions and quotas created an on-again, off-again pattern.
- Designated exporters: major mills in the EU, South America and Asia that supply construction, automotive and industrial sectors.
- Impact and advice: domestic buyers should assess inventory positions and hedging; anticipate wider price volatility if markets plunge or investigations continue into circumvention.
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Solar panels, washing machines and other targeted tariffs
- Designated products: solar modules, certain household appliances and specialty components were singled out with specific levy schedules that escalated over initial years.
- Designated exporters: Chinese OEMs and affiliated assemblers, plus some Southeast Asian firms acting as intermediate exporters where origin rules in term filings suggested circumvention.
- Impact and advice: verify country-of-origin paperwork; expect customs scrutiny and potential investigations that continue after the initial designation.
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Retaliatory measures and affected US exporters
- Designated foreign retaliations: China and several trading partners imposed counter-tariffs targeting US agricultural lines – pork, soy and others – and select industrial goods.
- Designated US exporters: pork processors and grain exporters in the Midwest saw immediate demand shocks; pork shipments to key buyers plunged after retaliatory duty announcements.
- Impact and advice: US agricultural firms should diversify markets toward emerging buyers, use export credit facilities for liquidity, and prepare for disputes or attempts to overturn retaliatory measures in trade fora.
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Financial and legislative context
- Congress and finance agencies discussed a tariff relief bill and targeted support for affected regions; political power shifts and legal challenges took several tariff actions into court where petitions seek to overturn rules.
- Impact and advice: monitor pending bills and court rulings, because outcomes can change levy rates or restore past treatment; maintain flexible pricing clauses in contracts to absorb movements.
Operational checklist:
- Map exposure by supplier, SKU and tariff code to the designated lists and calculate the new landed cost with announced levy rates.
- Engage alternate suppliers in competing jurisdictions and secure letters of credit or bridge finance to cover short-term working capital gaps.
- Document origin and supply-chain steps to withstand customs investigations; keep audit-ready records where classifications suggest potential dispute.
- Monitor markets and price signals: if import volumes plunge or wider markets react, adjust procurement cadence and inventory buffers toward resilience.
How should importers update invoices, customs entries and tariff classifications immediately?
Amend invoices and customs entries within 48 hours: correct HTS/HS codes, state the applied duty rates, and mark any line items subject to previously-imposed tariffs so brokers and customs officials see the basis for collection or refund requests.
Send corrected commercial invoices to your customs broker and carrier (for example, maersk) with a clear timestamp and reference number; instruct the carrier to tag affected cargo and to hold or divert shipments if a reclassification would change duties by more than 5% of invoice value.
File formal entry corrections where permitted: in the U.S. submit a post-entry amendment or protest within the liquidation window; in europe and canada follow local refund/recovery procedures. Check rulings from the trade commission and attach those citations to entries to accelerate processing.
Segment at-risk goods by sector: classify microchips under specific semiconductor headings rather than general electronics headings, list agricultural lines separately for agriculture credits or exclusions, and flag chinese origin items that may carry extra duties. Treat colombian or other country origins according to the specific Rules of Origin; certify origin on invoices where preferential programs apply.
Quantify impact: run a rates comparison for most SKUs and produce a delta report within 72 hours showing duty change per SKU, total landed-cost impact, and how a wave of tariff adjustments (for example, tariffs effective in january) would change margins. If duties increase >10% on a SKU, seriously consider temporary price adjustments or purchase-order renegotiation.
Update internal systems: push corrected tariff classifications and duty rates into ERP, invoicing, and EDI feeds so future declarations carry the new codes. Train procurement and logistics teams to apply the new classifications this week and to alert compliance when anomalies appear.
Create and retain documentary back-up: supplier invoices, Bills of Lading, origin certificates, and broker correspondence. Keep records for at least five years and prepare a packet to support refunds or challenges from customs authorities.
Coordinate with partners: notify customers and importers of record in state and foreign markets if duties affect delivery terms; inform others in your supply chain (forwarders, insurers, maersk, 3PLs). If leadership asks for scenarios, present a base case, a 10% shock, and a 25% shock so they can weigh commercial decisions somewhat faster.
Monitor enforcement and trade policy: subscribe to customs bulletins and the trade commission advisories for changes that make a code or exclusion effective retroactively. There will be appeals, administrative reviews and possible rollback requests led by industry leadership, so document calculations now to support future claims or adjustments.
Act now on three specific items: (1) reclassify high-risk SKUs and update invoices, (2) file corrective entries and attach legal citations, and (3) notify carriers and buyers about adjusted landed costs. Doing so reduces revenue leakage from new barriers, limits disputes over duty allocation, and positions your team to respond to additional tariff waves that would affect supply chains between europe, canada, the U.S. and chinese suppliers.
What short-term supply chain steps (shipping reroutes, inventory holds, alternative sourcing) should businesses take in the 48–72 hours after January 20?

Immediately pause outbound noncritical shipments, hold inbound high-value inventory for 48–72 hours, and reroute critical lanes to pre-approved alternative carriers and ports.
Shipping reroutes: within 4–6 hours notify primary carriers and freight forwarders; request reroute quotes and space confirmations for at least two alternate ports per lane. Prioritize ports with lower congestion and existing customs relationships; aim to move high-tariff-exposed containers to those ports within 24–48 hours. If tariffs were recently passed or a presidential announce increases duties, tag affected SKUs by HTS code and mark them for separate handling. Use a second carrier on high-risk lanes and cap daily exposure (e.g., no more than a dozen TEUs per lane until tariff clarity arrives).
Inventory holds and buffers: hold finished goods with projected margin squeeze and increase safety stock for critical components by 20–40% for the coming 14 days. Convert days-of-cover to unit counts immediately: if lead time = 10 days and daily demand = 1,000 units, raise safety stock from 10k to 12–14k units. For chipmakers and other constrained suppliers, extend holds to 72 hours and segregate lots for fast re-export if tariffs escalate.
Alternative sourcing and procurement: contact second- and third-tier suppliers within 6–12 hours and confirm capacity and lead times. Move urgent purchase orders to suppliers that are allowed under existing free-trade rules or 90-day carve-outs. Where possible, shift at least one component per SKU to an American or nearshore supplier to reduce FX exposure and potential steeper duty increases. For vehicle parts and specialty goods (bourbon, electronics), identify at least one domestic alternative and one regional (EU/NA) backup.
Pricing, finance and cash: instruct finance to hedge exposed currency positions (euros, dollars) and forecast a worst-case 10–25% tariff-driven cost increase for the first year; run scenarios with steeper 40% duty spikes for high-risk SKUs. Freeze promotional spend tied to affected products and prioritize working-capital preservation. Expect short-term growth drag in affected economies and flag cash needs to treasury within 24 hours so suppliers and carriers see timely payment.
Compliance and communication: update customs brokers and legal within 12 hours, attach documentary evidence for any pausing decisions, and prepare tariff-dispute packets for shipments already in transit. Notify sales and top customers about 48–72 hour holds and expected delivery windows; provide SKU-level impact and replacement options to citizens/customers who ask.
Who owns what (owners and KPIs): assign a single cross-functional lead for each lane–logistics, procurement, finance, compliance–and track three KPIs: days-of-cover, reroute cost delta per TEU, and order fill rate. Require hourly status updates for the first 24 hours and twice-daily thereafter until normal flow resumes.
| Timeframe | Action | Owner | Target metric |
|---|---|---|---|
| 0–4 hours | Pause noncritical shipments; notify carriers and brokers | Logistics | Notifications sent, 0 new exports |
| 4–12 hours | Reroute critical containers; confirm alternate ports and carriers | Logistics / Procurement | 2 alternate ports confirmed per lane |
| 12–24 hours | Contact second suppliers; secure short-term capacity | Procurement | Backup PO for ≥30% of urgent demand |
| 24–48 hours | Increase safety stock; segregate high-risk lots | Operations | Safety stock +20–40% |
| 48–72 hours | Hedge FX exposure; finalize customer communications | Finance / Sales | Hedge positions set; customer notices sent |
Expect quick public statements (press or official) to affect market sentiment; if a presidential decision–referenced in press or linked to Donald-era precedent–announces steeper measures, trigger your second wave contingency within 6 hours. Track effects daily and re-assess allowed exemptions and 90-day measures that might let companies avoid immediate tariff hits. These steps help business leaders preserve margins, maintain supply continuity, and give time for longer-term sourcing changes that will let businesses grow again after the initial shock.
How to file exclusion requests, submit public comments and prepare administrative or judicial challenges tied to the January 20 measures?

File an exclusion request with the Office of the U.S. Trade Representative (USTR) immediately if you import goods hit by the January 20 measures: identify the precise HTSUS 10-digit code, supply chain entries, product photos, and three commercial invoices showing the value and volume of recent imported shipments.
Find the controlling Federal Register notice and docket on regulations.gov (источник: Federal Register entry for the January 20 action). Note the docket number and deadline; public comment windows for these tariff announcements generally close about 30 days after announcing but verify the exact date posted on the 19th or in the notice.
Prepare two versions of each submission: one redacted for public posting and one confidential version marked CBI with supporting exhibits. In exclusion requests include: clear product description, technical specs (dimensions, machines used in production), country of origin, HTSUS code, quantity and value by entry, downstream U.S. uses, and sworn declarations from importers or U.S. buyers showing lost revenue or growth impacts if exclusions are denied.
Frame legal and economic arguments around statutory criteria cited in the notice: lack of domestic availability, disproportionate economic harm to U.S. industries (agricultural and textiles examples), and tangible downstream effects on semiconductors, manufacturing machines, and processors. Quantify harms – e.g., revenue plunged X% after duties, Y jobs at risk, Z% higher input costs – and attach spreadsheets and supplier affidavits.
Submit public comments on regulations.gov with a short executive summary, then attach exhibits. Use clear headings so agency reviewers can find HTS codes, sample invoices, and expert reports. When submitting sensitive trade secrets, provide a public summary and claim CBI in the confidential submission.
If an exclusion request is denied or the rule is issued without adequate process, file administrative rehearing or reconsideration petitions promptly with the named agency (USTR or Department of Commerce), supplying any new facts within the statutory deadline stated in the denial. Ask the agency for a meeting to present evidence and request expedited review if immediate commercial harm would follow.
For customs entry issues, protest entries with U.S. Customs and Border Protection within 180 days of liquidation; preserve entries, entry summaries, and protest receipts. For policy-level challenges to the tariff action, prepare to file in the U.S. Court of International Trade (CIT) under the applicable venue statute, typically seeking review under the Administrative Procedure Act on arbitrary-and-capricious grounds.
Draft a litigation package that includes: the administrative record, declarations from affected U.S. firms and importers, economists quantifying impact on trade with us-china partners and other foreign nations, and evidence of retaliation or wider political consequences (for example, retaliation threats from mexico or other trading partners). Request preliminary injunctive relief when immediate injury – lost contracts, finance disruption, or supply-chain crisis – would occur before full review.
Coordinate counsel and trade experts early: assign one attorney to manage deadlines, one economist to model lost output and growth, and one industry expert to document supply-chain specifics (textiles, agricultural inputs, semiconductor components). Label exhibits clearly to avoid delays at the agency docket clerk and in court filings.
Track related rulemakings and exemptions lists posted soon after announcing duties; monitor for new exclusions or retroactive relief, and file supplemental comments or new exclusion petitions if new HTS lines or imported variants appear. Keep stakeholders informed – procurement, sales, and finance – so company revenue projections do not plunge unexpectedly during the race to secure relief.