One Year In, Cindy’s Version Asks: Are You “…Ready For It?”
A year ago, Cindy’s Version launched with one goal: make trade news make sense, one Taylor Swift song at a time. This week’s anniversary episode keeps that spirit alive and asks companies a hard question. Are you actually ready for what’s next?
This Week in Trade
CBP is sorting through feedback on proposed de minimis changes and postal parity concerns. Enforcement recovered more than $1 billion through Enforce and Protect Act investigations. USMCA talks continue, with friction over Section 232 and 301 tariffs still unresolved. And new Section 232 rules bring added reporting duties for pharma importers.
Four stories. One shared lesson.
What a Real Trade Playbook Looks Like
A trade playbook isn’t a binder on a shelf. It’s a cross-functional process compliance, finance, legal, procurement, sales, and leadership working from the same page before the next action lands. A working playbook identifies affected products, evaluates financial exposure, checks contractual obligations, and keeps suppliers and customers informed.
The Bottom Line
Preparation beats prediction, every time. Cheers to one year of Cindy’s Version making trade news make sense. Here’s to another year of Taylor Swift needle drops and playbooks that actually hold up when the next tariff drops.
Transcript
Cindy Allen – Trade Force Mult (00:03.886)
Hello, today is Friday, July 31st. Welcome to one full year of Simply Trade Cindy’s version, where I, Cindy Allen, also known as the Taylor Swift of Trade, base an international trade update on a Taylor Swift song. I’m Cindy Allen, CEO of Trade Force Multiplier Global Trade Consultancy Service. I am bringing this podcast in association with Global Training Center, whose brainchild simply trade.
Cindy’s version was so welcome. Today’s song is Are You Ready for It? First, what happened in international trade. I’ll get to that in a moment, why we chose Are You Ready for It? So a lot happening actually in international trade this week. First I want to focus on comments that were made on the elimination of the de minimis rule.
As you know, CBP has indicated that they want to indefinitely suspend de minimis until the July 1st, 2027 date when the Big Beautiful Bill takes effect, which eliminates De Minimus by law at that point. There were hundreds of comments. some of them were highlighted in the press. The Express Association of America not fully in in
In support of completely suspending De Minimus, but they more focused their comments on the postal parity, which actually postal moved about 8% of the de minimis traffic. And what their process is right now is submitting a spreadsheet. And the EAA has indicated that that really has impacted their companies who have to participate in the entry type 11 or entry type 01, formal entry or informal entry.
For any article that’s over one cent, and that that does not provide parity with the Postal Service. It also limits the data that CBP has for targeting, as the Postal Service is only giving a spreadsheet of the data, not directly into a system, and the Express couriers have to file entry summary level information for all shipments. And this has created some issues.
Cindy Allen – Trade Force Mult (02:21.13)
CBP has actually indicated that they are going to be rolling out entry type 13 for postal service shipments that does require some additional information. The interim step is just a more fulsome Excel with data. So that has not completely been integrated into ABI and the full entry summary entry process been indicated in this. So there are still some parity issues with that.
this is not yet in effect, the entry type 11, so it has created some additional issues. Some other comments that I think were interesting were that one commenter suggested that CTPAT importers should be allowed to participate in De Minimus, that they have met a higher degree of security concerns, and that they should be allowed to take advantage of no duty and less information coming in for their shipments.
the Coalition for Prosper America, which has supported no change, praised the administration for not making any changes to that. And they do believe that this is the right course. If you recall, the Coalition for Prosperous or CPA has basically been against trade programs, anything that simplifies trade or alleviates a duty payment in the past decade.
NCTO which is the National National Council of Textile Organizations, also indicated that CBP has collected more than 1 billion duties across 246 million low value shipments since May of 2025. So that is going to be an argument that the cost offsets for collecting the additional information and the additional duty, which was the intent of Section 321.
in the law to begin with was to ensure that CBP was not expending more dollars and more effort than it was going to get back collecting that information. And this stat, 1 billion duties, does have does present an issue in in meeting that criteria that CBP’s costs are going to exceed the cost of the duty that they’re going to receive. So I really don’t expect us to go anywhere soon.
Cindy Allen – Trade Force Mult (04:40.296)
some organizations did call out the old adage: garbage in, garbage out, you know, bad data on the invoices is going to equal bad data on entries, and that the requirement for more data and more information doesn’t necessarily mean that it’s going to be better data or better information, in that the underlying data quality issues are still going to be rampant, especially in a low-value e-commerce type environment.
Where people are just ordering off of the internet. They don’t understand international trade. They don’t necessarily know what they’re ordering, where the country of origin is. And that information is going to be fed all the way through that international trade data system and that the shippers who mainly are just resellers for products that are manufactured in areas of the world are gonna have an issue getting
Real quality data, like if you bought from a brick and mortar store. So I think that this continues to be an issue that’s going to be faced by CBP. But we do see an opportunity for CBP to continue their enforcement efforts, which which has been increasing all along. in that vein.
CBP has announced that it has uncovered over $1 billion in duty evasion under the Enforce and Protect Act. So that means that the enforcement efforts that we’ve seen increasing as international trade participants has paid off. A billion dollars is a lot of money. It’s paying for some of that automation and it’s justifying that expense that CBP and the government has made in enhanced enforcement capabilities, both from a technology perspective.
and a person or personnel investment perspective are paying off. So if you are a company in importing, our advice has been all along you need to invest in a good compliance program. You need to ensure that you are looking at all of the information and vetting and verifying as much as you can, all the way back to the raw materials of the goods. As we have seen a lot of these section 232 cases and forced labor
Cindy Allen – Trade Force Mult (06:53.046)
Actually, it rests in the component level compliance and component level information. It’s going to be more important than ever that you invest in technology or invest in understanding your supply chain all the way back to the raw materials of the goods. So, welcome to Complex International Trade Today. the CPSC, which recently rolled out the additional information required for.
That agency are not seeing the mass detentions or significant problems that had been anticipated. There are some problems that are occurring during the phased enforcement timeline. However, those are being resolved and shipments are continuing to move during this phased enforcement. Now just be cautious that CBP and CPSC is likely.
Collecting the data and we’ll be using that to identify trends and patterns and make sure that you aren’t an anomaly in that process and that you have your information going forward. So if you are subject to the CPSC new information requirements, make sure that you’re spending some time with your supply chain and your brokers, making sure that information is accurate.
USMCA negotiations, according to a fellow at the CSIS Americas program, he’s indicated that there is a standoff in the negotiations. even though everything looks rosy from the government perspective, both Mexico, US, and Canada have indicated that the negotiations are ongoing. this individual indicated that there is a Mexican demand.
That the US hasn’t agreed to specifically that Section 232 and Section 301 duties on Mexican products should be alleviated in the USMCA. That if it qualifies for USMCA, those products shouldn’t be subject. And further, any country of origin with some specific guidelines should not be subject to that due to the close trading partnership. So
Cindy Allen – Trade Force Mult (09:05.4)
The US reportedly is not in agreement with this, so we know that lots more talks will go on. also the big news this week, big big news, the section 232 for patented pharmaceuticals has been released. These apply to 15 companies with patented pharmaceuticals. There are two effective dates, one of today and then one of in later in September.
The companies that are subject and the products that are subject must report the 99 number, even if there is zero duty on these products. Details can be found in Annex 3 for this section 232 announcement. There are both tariffs and companies and products that you have to look for. So if you are a customs broker, you now need to know.
on your invoice or on the information transmitted to you by your client, the importer of record. If this is a subject tariff product, which okay, we have tariff numbers. If this is a generic or a patented pharmaceutical, which most invoices don’t contain that information, most databases don’t contain that information. A drug is a drug. The information that is required for an invoice and required for duty
is regardless of whether it’s patented or not. So now you have to split that apart. If you have a generic and you have a patented item that falls within the same tariff number, then you will have to split that line out. Further, that information is going to have to be available to you. So if you are an importer or you are a supplier of the pharmaceuticals, you now need to indicate it’s patented or if it’s generic because that’s going to be important.
You also, as a customs broker, will have to ensure that you have databases for these named companies, these 15 companies that have been specifically named as having some sort of manufacturing process in the United States, or are building manufacturing processes in the United States, or have agreed to make additional investments.
Cindy Allen – Trade Force Mult (11:23.052)
So one of the things that I think is really interesting about the pharmaceutical industry is they kind of got ahead of the Section 232 discussion. They sat down with the government as individual companies and also kind of at coordinating, you know, outside of antitrust, but coordinated through their trade associations and said, What are we willing to do here to ensure that we’re working with the administration and their goal?
Of increasing investments in the United States and alleviating some of the 232 duties that have plagued some of our other competitive industries, such as automotive or steel and aluminum. We’re seeing some of those being alleviated now for manufacturing in the United States, which was also announced this week, but also offset programs that happen after the fact. So the pharmaceutical industry got ahead of that. They met
Company by company by company with the administration, and we’re able to alleviate some of the duty concerns. So if you are an industry and you know the administration is looking at your particular industry, you may want to collectively talk about approaches that may alleviate some of these duty in in the in the future. So that kind of brings me to why I chose Ready for It. Ready for It is often
Of Taylor Swift’s Reputation album, which, if you know Taylor Swift, it’s as close to a rock album as you’re gonna get. It was highly influential when it came out and a favorite of many of the Taylor Swift Swifties. it’s it’s one of my favorite songs, it really has a great beat to it, but I think as it applies here, what I really want to focus on today is that.
You need to have a plan in place. You need to be ready for these trade actions. We’ve seen this over and over and over again. We’re seeing trade actions come out at least once a month, if not more times than once a month, more often than that. And although the actual trade actions themselves, whether they’re the 338 trade actions that were announced a few weeks ago for Canada.
Cindy Allen – Trade Force Mult (13:39.447)
Or it’s the 301 actions that were announced for the 60 countries for lack of enforcement of forced labor within their own country, or it’s a 232 action on specific industries. You need to have in place a playbook. So when something happens, you know what needs what you need to do. You may not know the specific action, you may not know how it’s going to impact you, but you’ll have a playbook in place.
To sit down and say, okay, we have an action. Who needs to be at the table for these discussions? We need to one have a data poll. We need to know are we going to be impacted by this action? Because you may not be impacted by everyone. You need to know what products are going to be impacted, what suppliers are going to be impacted, what core raw materials are going to be impacted. Is this going to impact your customers then on the other side of things? How is it going to impact your customers?
You need to have that data to begin that conversation. And to have that data, you need to know where you need to go. There should be some sort of communication plan in place that you have now to be able to get that information, to do outreach, get that information. And then you start your internal assessments. You bring in finance, you bring in legal. What contracts is this going to impact? Do I have an ability to raise prices if if I
have a contract in place if I’m going to be impacted. What is my contract with my suppliers? What are my contract with my clients? How can we do we have room to adjust for pricing should that be required? If you’re subject to a 50% duty rate on your entire product, you may have to raise your prices and you may need to know what your parameters are. If it on the other hand, if you have a 50% duty for a Canadian part that’s going to be, you know, only
$5 of your $1,000 item, that extra $250 in duty may not require you to look at a price adjustment. You may be able to absorb that. But you also need finance at the table to walk through those scenarios. You need sales at the table to walk through how the impact is gonna be. You need marketing at the table so that they can begin to understand how to communicate both internally within your company.
Cindy Allen – Trade Force Mult (16:02.434)
to your suppliers, to your clients, and then to any board that you may have. As we’ve talked about before, trade professionals profile has been raised exponentially in this environment, whether you like it or not. So you need to have a good solid playbook that will be sustained no matter which trade action happens and that you can run that playbook all the way through. Okay, we have a 338
What products do we have? Let’s do the data poll. What’s our pricing? What is that going to impact? Is it going to impact my raw materials? Is it going to impact the price of my product overall? Where is the impact? Who’s going to be impacted? How do we communicate that? And then what action do we need to take internally? What alternate supplier options do we have? Can we change our product so that it falls outside of a trade action or not? Those should all be normal.
documented playbook discussions that you have. You know which departments need to be sitting at the table with you and which departments need to ha weigh in and then how you communicate that. So you as the trade professional can ensure you’re ready for it. Cause that’s about all we can be is ready for it now. I’ll talk to you next week.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
[View Source]