Issue link: https://iconnect007.uberflip.com/i/1531014
38 SMT007 MAGAZINE I JANUARY 2025 son for why some companies got them, and some didn't. Right now, most of the exclusions have gone away. Mainly, they're on solar manufacturing equipment, and now they're accepting com- ments on domestic manufacturing equipment. I can imagine if you are a semiconductor fab in the U.S. and you need special equip- ment to produce semiconductors, you could request an exclusion for that equipment and poten- tially receive it. at exclu- sion process will only last until May 2025. We don't know what will happen aer that. Will Trump extend that process or open it up to other types of products? My guess is that the exclusion process will be expanded. Usually, with the announce- ment of tariffs comes the opportunity to request exclusions, so I would be surprised if that doesn't happen this time. For most companies, import compliance is an afterthought, which can trip them up when it comes to cost, so what should they do and when? It's not an aerthought anymore, especially with all that's happening. It's at the forefront of everyone's minds, and if it isn't, it definitely should be. So, what can you do? We've been getting this question oen as companies get scared hearing about potential tariffs. ey want to be ready if the other shoe drops. We do an import risk profile/analysis for companies, where we take all the import data—when and how much you imported, what classification you used, country of ori- gin, value, etc.—and assess risk areas. Maybe classifications have changed, and a company hasn't reviewed that for a while. e Harmo- nized Tariff Schedule gets updated regularly. Maybe you need to re-examine the origin of your products because if there's an argument for substantial transformation, it could help you get a lower tariff. ose are some things to look at. U.S. Customs has a process where companies can ask for a ruling to find out what Customs thinks the classification or the ori- gin of a product should be. at's where this analysis can be really helpful. It gives you more certainty to move forward and do some planning around your supply chain. Do I need an attorney to help with the risk analysis? While companies can defi- nitely do it themselves, and all importers have access to their own import data, they might not be aware of all the issues. So, it can be helpful to have an expert who understands the risk areas, how to look at that import data, and devise strategies for saving on tariffs. Our firm and other advisors and consultants do that. If you import a lot, you should con- sider your risk areas and prepare around them. Do you have any closing thoughts? is is a very fluid and fast-changing area. It can be overwhelming to keep track of, so hav- ing a good advisor who understands this area is important. I do this daily, and it's almost impossible to keep track of everything happen- ing, but we do our best. We put out a monthly newsletter on trade and customs covering top- ics that companies should be aware of, which can be a helpful resource. If you're looking ahead in 2025, make sure trade and tariff risk assessment is part of your agenda. It's better to take proactive steps to prevent this rather than end up in a situation where you're caught in the net of a customs investiga- tion or inquiry. It's just good to be prepared as best as you can. James, this has been informative, as always. Thank you. ank you. SMT007