Bramvia — Business Central Experts

Tariffs changed three times this year. Your landed cost didn't — and that's the problem

IEEPA tariffs struck down in February, a flat 10% until July, and since July 24 a two-tier Section 301 rate by country of origin. $166B in refunds is being processed. If your system doesn't hold origin, classification and duty per item, you are quoting on numbers that expired.

Short answer: US import costs have been rewritten three times in 2026, and most companies' landed-cost figures are still from the first version. 20 February: the Supreme Court ruled 6-3 that IEEPA does not authorize tariffs, invalidating the reciprocal and trafficking tariffs. 24 February: a flat 10% Section 122 surcharge replaced them. 24 July: Section 122 hit its 150-day statutory limit and expired the same moment USTR's Section 301 forced-labor action took effect — a two-tier 10% / 12.5% duty across roughly 60 economies, about 99.4% of US imports, with the 12.5% tier covering China, Vietnam, India, Thailand, Japan and South Korea. EU-origin goods sit outside it, at the 15% all-inclusive ceiling from the July trade deal. Section 232 duties are untouched: steel and aluminium at 50%, autos and parts 25%, copper 50%, semiconductors 25%, and patented pharmaceuticals at 100% — for all remaining companies from 29 September 2026. Two consequences no spreadsheet handles: your duty now depends on origin and exact classification per item, not a flat rate; and if you paid IEEPA duties, you may be owed a refund from a pool of roughly $166 billion, of which $86.3 billion had been repaid by July.

The 2026 timeline, in one table

Reduced rates exist in places — a 20% pharmaceutical rate for companies with a Commerce-approved US onshoring plan, for example. Which is exactly the point: the rate is now a per-product, per-origin question.

Why the flat model broke

Under Section 122 you could add 10% to almost everything and be roughly right. That is over. The replacement sets the rate by country of origin, with exemptions by product, on top of MFN duties and any Section 232 or 301 layer that applies to the commodity itself.

So the same part number, bought from two suppliers in two countries, now carries two different landed costs. If your pricing still uses one standard cost per item, some of your products are being sold below cost right now and nothing in your system is telling you which.

This is the same pattern as the fuel surge: the shock doesn't create the blind spot, it makes it expensive. Diesel hit a record $5.90 a gallon on 8 September. Freight and duty moved in the same quarter, in the same direction, on the same products.

The refund nobody has claimed

This is the part most companies have not acted on. Because IEEPA tariffs were ruled unlawful, importers of record are in principle entitled to refunds plus interest on duties paid under them. CBP's own court filing put cumulative repayments at $86.3 billion by July 2026, out of a pool of roughly $166 billion. June alone was $49.1 billion.

Two practical notes:

• If you were the importer of record, the claim is yours. If you bought DDP and someone else imported, your recourse is contractual, not with CBP.
• The mechanics were left unresolved by the Court and worked out through the lower courts, so process matters. This is work for a licensed customs broker or trade counsel — not for us, and not for your ERP consultant.

What your ERP can do is answer the first question: what did we actually pay, on which entries, over which period? Companies that can produce that in an afternoon are the ones filing. Companies whose duty data lives in PDFs from a broker are still guessing.

Canada and Mexico: USMCA is now the main lever

For North American trade the picture improved and got more technical at the same time:

• USMCA preference survived. Compliant goods continue to enter at 0%, and the preference also exempts them from the merchandise processing fee — worth claiming even when the general rate is already 0%.
• The IEEPA tariffs on Canada and Mexico are gone (they were 25-35% for non-compliant goods).
• Section 232 duties still apply to Canadian steel, aluminium, autos and lumber, under a different legal authority that the ruling did not touch.
• For goods with Chinese components assembled in Mexico, USMCA qualification is often the only route to reduced duty exposure.

Which means the value of qualifying has gone up — and qualifying is a data problem: bill of materials, origin per component, regional value content, and the certification to back it. If that lives in a spreadsheet somebody updates occasionally, you are leaving the preference on the table or claiming it without support. Neither is comfortable.

What your system needs to hold

Six data points. If any is missing, your landed cost is an estimate:

1. Country of origin per item — and per supplier. Not "where we buy it", where it was made.
2. HTS classification at the level that determines the rate.
3. Duty and fees per receipt, captured against the purchase, not pasted from a broker PDF at month-end.
4. Inbound freight allocated to the item, which at current rates is no longer a rounding error.
5. Landed cost recalculated when any of the above changes — and a trigger to review prices when it does.
6. USMCA qualification evidence per finished good: BOM, component origins, and the certification.

Business Central handles all six natively (item charges, origin, and tax engine integration with Avalara or Vertex); most systems can be made to. The question is whether yours is configured to, which is usually the honest answer to "why don't we know our real margin".

What to do in the next 30 days

1. Pull what you paid in duties since January 2025, by entry. This is the refund question and the landed-cost question at once.
2. Re-rank your products by contribution margin with current duty and freight. The list will have changed more than you expect. The six numbers that matter.
3. Check the 12.5% tier against your supplier list. China, Vietnam, India, Thailand, Japan, South Korea. If a key component comes from there, model the alternative origins now.
4. If you import pharmaceuticals, 29 September is next week's problem, not next year's.
5. Audit your USMCA claims — both the ones you make and the ones you could be making.
6. Talk to a customs broker about refunds. Then talk to whoever can extract the data they'll ask for.

What we do and don't do here

We are not customs brokers and we don't give trade advice — that's a licensed profession and the refund process needs one. What we do is the data side: get origin, classification, duty and freight into your system so landed cost is a number rather than a guess, and analyse what you already have to show which products and customers changed sides.

That analysis is a fixed-fee engagement that works on any ERP: the Profit Leak Audit. If you'd rather start smaller, the free assessment tells you in five days whether your data can answer these questions at all.

FAQ

Are the tariffs gone? No. The IEEPA ones were struck down; Section 232, Section 301 and the new forced-labor action remain, and the last has no statutory expiry.

What rate applies to my imports today? It depends on origin and classification: 10% or 12.5% under the Section 301 action for most of the ~60 covered economies, 15% all-inclusive for EU-origin goods, plus any Section 232 commodity duty. Confirm specifics with your broker — rates and exemptions have moved repeatedly this year.

Can we really get money back? If you were the importer of record and paid IEEPA duties, in principle yes, with interest. The process runs through CBP and licensed professionals. We can help you produce the data; we can't file for you.

Does this mean we need a new ERP? No. It means whatever system you run must hold six data points. If it can, configure it. If it genuinely can't, that's a finding worth quantifying before deciding anything.

Not sure what your real landed cost is right now? Free assessment, no commitment — first reply within one working day.

Bramvia · bramvia.net