CASE STUDY

Navigating Customs Brokerage in an Increasingly Complex Tariff Environment

Client Large U.S. Auto Importer Challenge The importer faced significant complexity in customs entries driven by Section 232 tariffs on steel and aluminum, evolving tariff exclusions, frequent HTS classification updates, increased country-of-origin scrutiny, and heightened CBP enforcement. Ongoing legal challenges and administrative changes further complicated compliance requirements. While structured data, such as a detailed parts…

Client

Large U.S. Auto Importer

Challenge

The importer faced significant complexity in customs entries driven by Section 232 tariffs on steel and aluminum, evolving tariff exclusions, frequent HTS classification updates, increased country-of-origin scrutiny, and heightened CBP enforcement. Ongoing legal challenges and administrative changes further complicated compliance requirements.

While structured data, such as a detailed parts dictionary, helped improve consistency and supported entry automation, the constantly evolving tariff landscape required an additional level of manual review and audit. Changes to duty rates, exclusions, quota status, and regulatory interpretations meant that each entry needed to be carefully reviewed to ensure all applicable tariffs and exceptions were correctly applied. Many brokerage providers operating with lean staffing models were unable to support this level of oversight, increasing the risk of errors, delays, and penalties.

Solution

J.M. Rodgers combined automation with experienced, hands-on compliance oversight. Leveraging the client’s parts dictionary allowed JMR to automate key aspects of data entry and improve efficiency. However, recognizing the limitations of automation in a volatile tariff environment, the JMR team implemented mandatory manual review processes for each entry.

Licensed brokerage professionals conducted detailed validation to ensure proper assignment of steel and aluminum content under Section 232, accurate application of exclusions and quotas, and compliance with current CBP guidance. Layered quality controls and ongoing monitoring of tariff developments ensured that entries remained accurate despite frequent regulatory changes.

J.M. Rodgers’ flat-fee pricing structure was designed to support this approach. Rather than charging line-item fees for individual reviews, tariff changes, or exception handling, the flat fee provided cost certainty while ensuring every entry received the appropriate level of manual scrutiny and compliance oversight.

Outcome

  • Improved entry accuracy and reduced post-entry corrections
  • Faster clearance times supported by automation and expert review
  • Lower compliance risk and stronger audit and enforcement readiness
  • Clear cost predictability despite increased regulatory complexity
  • Increased confidence navigating Section 232 duties, exclusions, and interpretations

Key Takeaways

  • Automation improves efficiency but cannot replace expert compliance review
  • Section 232 steel and aluminum entries require manual validation of content and applicability
  • Flat-fee pricing aligns cost certainty with compliance integrity
  • Investing in people, training, and technology creates sustainable brokerage performance