Advocacy Update: Tariffs, Trade Uncertainty, and Key Compliance Reminders

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The trade and tariff landscape remains fluid, with several developments—and non-developments worth monitoring. While there haven’t been many substantial changes since our last update, we want to ensure you remain informed about issues that could impact your business. Even periods of uncertainty or inaction can have real implications for planning and compliance. Below is a snapshot of where things currently stand and what we continue to monitor on your behalf.

U.S.–India Trade Agreement Update

As reported by The Washington Post, the United States and India have reached a trade agreement that could result in lower tariffs on Indian goods. While official guidance from U.S. Customs and Border Protection has not yet been issued, current understanding suggests the following:

  • The regular reciprocal tariff on goods from India is expected to decrease from 25% to 18%
  • The additional 25% tariff tied to India’s purchases of Russian oil appears to remain in effect for now

Importantly, no implementation date has been announced, meaning existing duty rates remain in place until official notice is provided. As with all trade matters, these details remain subject to change, and HFA will share updates as soon as Customs guidance is released.

Ongoing Tariff Threats and Executive Actions

  • Additional Tariffs Linked to Greenland
    Recent indications suggest that the threat of new tariffs on countries that do not support the U.S. position regarding Greenland is no longer imminent. That said, trade policy remains highly dynamic, and this situation could change with little notice.
  • Potential Tariffs on Countries Doing Business with Iran
    Earlier in January, the President stated via social media that additional tariffs could be imposed on countries “doing business with Iran.” To date, no formal announcement, executive action, or additional guidance has followed this statement.
  • Executive Order Targeting Oil Supplied to Cuba
    The President has issued an Executive Order outlining a process that could lead to additional tariffs on countries supplying oil to Cuba. The EO initiates a multi-agency review involving the Departments of State, Treasury, and Commerce, as well as the U.S. Trade Representative.
    At this time, the EO appears to establish a framework for evaluation rather than immediate enforcement. Based on current understanding, clear guidance or near-term action is unlikely, but this remains an area to watch closely.

Important Compliance Reminder for Importers

HFA strongly encourages all importers to ensure they are fully set up in the U.S. Customs and Border Protection (CBP) ACE Portal, a critical tool for trade compliance and financial visibility.

  • The ACE Portal provides importers with secure access to years of import records, including:
    • HTS codes used
    • Shipment values
    • Supplier information
    • Duties paid
  • ACH Refund Enrollment Is Now Required
    CBP no longer issues paper refund checks. All duty refunds are processed exclusively via ACH, and importers must enroll through the ACE Portal to receive refunds.

Helpful Links:

Ensuring your account is active and properly configured can help avoid delays and missed refunds.

Supreme Court & IEEPA Tariffs

The Supreme Court has not yet ruled on the legality of tariffs imposed under the International Emergency Economic Powers Act (IEEPA). Because the Court is currently in recess until February 20, no decisions will be issued during this period. Once the Court reconvenes and issues a ruling, HFA will closely monitor the outcome and provide members with timely updates on any implications for importers and retailers.

While many of these issues remain unresolved, they reinforce the importance of staying engaged and informed as trade policy continues to shift. Even when changes are slow to materialize, behind-the-scenes developments can quickly translate into real-world cost and compliance impacts for retailers. HFA will continue to monitor these issues closely, advocate for fair and predictable trade policies, and keep members updated as new information becomes available.

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