U.S. importers are adjusting to two significant customs developments that could impact their cost exposure and compliance risk
An expansion in the number of Harmonised Tariff Schedule (HTS) codes allowed per entry line, and widespread confusion around how transshipped goods are treated under the latest round of U.S. tariffs.
CBP Increases HTS Codes Per Line from 8 to 32
As of this week, U.S. Customs and Border Protection (CBP) has increased the number of HTS codes that can be listed on a single entry summary line from 8 to 32, applying to both standard and reconciliation entries.
This change is intended to improve data efficiency and modernise the Automated Commercial Environment (ACE). However, many see it as a sign of rising complexity in customs enforcement, particularly in a year marked by shifting trade policies and frequent updates to duty rates.
While the technical capability to submit more codes can improve speed and reduce the number of lines per entry, it also significantly raises the risk of misclassification, documentation errors, and compliance gaps, especially for shipments with dozens or even hundreds of SKUs.
Transshipment Confusion Undermines Tariff Clarity
At the same time, nearly 100 shipper and logistics associations have written to CBP and the Department of Homeland Security (DHS) requesting clearer guidance on how transshipped goods are treated under the new IEEPA tariffs announced in April.
Specifically, the trade community is seeking confirmation that goods which departed their origin before the April 5 deadline, but were transshipped through another country, should not be subject to the new tariffs. The industry points to longstanding CBP precedent that eligibility for exemption should be based on the original country of export, supported by bills of lading and export documentation.
However, CBP’s responses have been inconsistent, creating confusion for importers and brokers alike. With further tariff reviews expected later this summer, including a possible extension of the 90-day pause on reciprocal duties, the need for clarity and consistent guidance is becoming more urgent.
How Global Forwarding Helps Importers Navigate Change
With growing complexity in both classification and routing rules, many importers are confused and uncertain. At Global Forwarding, our customs brokerage services are designed to help businesses not just keep up, but stay ahead of change.
We’re already adapting our systems and workflows to accommodate the 32-code structure. Whether your entries include 10, 100, or 1,000 SKUs, we ensure accuracy and speed through a mix of automation, rule-based logic, and hands-on expertise.
Our centralised product databases, integrated classification tools, and experienced team mean that your entries are processed quickly and compliantly, minimising the risk of delays, audits, or penalties.
We continuously monitor CBP guidance and rulings to ensure that transshipment routes, bills of lading, and supporting documents align with tariff exemption criteria. Our team understands how to structure entries and provide the documentation needed to demonstrate U.S. destination intent, ensuring you avoid costly misinterpretation.
In short, we help you take advantage of what’s possible, without getting caught out by what’s unclear.
Compliance Confidence Starts Here
From tariff strategy and duty optimisation to multi-line entry automation, Global Forwarding brings the systems, scale, and support importers need to manage complexity and grow with confidence.
Discover our customs brokerage services and see how we can help your business stay compliant, agile, and in control.
