It is time to reassess your customs valuations and structures…
President Trump has announced a new set of tariffs on UK-made products: a 10% tariff across most categories, and 25% for goods in the automotive sector. While we await the detailed product list and further guidance, this is a significant development for any business moving goods between the UK and the US.
Product classification still matters – but customs valuation is now front and centre
Historically, much of the trade planning focus has centred around product classification. This remains important, especially as businesses revisit their classifications to determine if certain products might fall under exceptions or reduced tariff rates.
However, with blanket tariffs now in place, the customs value assigned to goods becomes even more critical. How your business values products for customs purposes — especially in intercompany transactions — can have a direct impact on the final duty paid. If your business has transfer pricing policies in place that influence these valuations, these may now need to be reviewed through a customs lens.
Intercompany structures and cross-border flows need attention
Many businesses operate complex structures where goods are bought and sold between related entities across borders. These transactions often serve legitimate commercial purposes, but under a new tariff regime, they can result in increased duty exposure — particularly if goods are routed through multiple jurisdictions.
There may be opportunities to restructure certain flows or revisit existing models to reduce overall duty impact, provided this is done in a compliant and commercially grounded way.
Don’t forget about origin rules — are your products really ‘UK-made’?
The headline tariff applies to UK-origin goods, but proving origin is not always straightforward. In many industries, supply chains are global: raw materials or components may come from multiple countries. This can result in the final product not qualifying as UK-origin under US customs rules — meaning it may attract a higher rate of duty.
Now is the time to review origin documentation and supplier declarations, and understand whether your goods genuinely meet the threshold for UK origin. The rules of origin can be complex, but ensuring compliance can help avoid unexpected costs or disputes at the border.
In summary:
• Revisit product classification to make sure it’s accurate and up to date
• Focus on customs valuation — this now has a direct impact on costs
• Review intercompany structures and flows, especially where goods move between the UK and US
• Check origin rules carefully, particularly where products have multi-country inputs
If you’re affected by this announcement or want to talk through your exposure and potential options, feel free to get in touch.
