Let’s Talk Tariffs with Jamie Rodgers: Import Bans Begin, Secondary Tariffs Expand & CBP Looks Deeper Into the Supply Chain

Your weekly coffee chat on tariffs & trade.

For the last few weeks, I’ve been writing about the Canadian import bans as something that was coming.

Well, they’re here.

As of September 29, certain Canadian alcohol, dairy, motor vehicle and motorcycle products can no longer be imported into the United States. These are products that, not long ago, we were discussing in terms of an additional 50% duty. Now we’re talking about whether they can cross the border at all.

That escalated quickly.

But strangely enough, that’s not the development I’ve been thinking about most this week.

What Caught My Eye

The new secondary tariff authority is the one I’d keep an eye on.

The Lindsey O. Graham Sanctioning Russia and Iran Act was signed into law September 18. Among other provisions, it creates authority for tariffs of up to 500% on Russian goods and secondary tariffs of up to 100% on imports from certain countries that are major purchasers of Russian energy or facilitators of Russian oil sanctions evasion. The law calls for implementation by October 18, subject to exceptions and waiver provisions.

We don’t know yet exactly how that authority will ultimately be applied. That matters, and I wouldn’t get ahead of it.

But if I ran a business sourcing internationally, I’d certainly want to know where my exposure could be.

Importers are accustomed to looking at a product and asking: What is it? Where was it made? How is it classified? What duties apply?

Now there can be another question in the conversation: what is happening between that country and somewhere else in the world?

That’s a pretty significant change in how you have to think about sourcing risk.

You may have a perfectly established supplier relationship, a product that hasn’t changed and a classification you’re confident in. The variable can now be something happening thousands of miles away from the factory.

Welcome to global trade in 2026.

Here’s My Take

I wouldn’t start rearranging a supply chain based on something that hasn’t happened yet.

I would start asking questions.

There’s a difference.

Over more than 75 years at J.M. Rodgers, we’ve watched plenty of trade programs come and go. One thing experience teaches you is that reacting to every announcement can be just as problematic as ignoring them.

You need to know enough to move when there’s actually something to move on.

For companies with significant international sourcing, that means understanding where purchases are concentrated, which suppliers would be difficult to replace, how long a sourcing change would realistically take and where you have alternatives.

That work is useful whether a particular tariff materializes or not.

Nobody wants to build a second supply chain just for fun. But discovering you need one after the first one becomes a problem isn’t much fun either.

If It Were My Business…

There’s another development this week that I think importers should spend some time reading.

CBP is considering significantly expanding the supply chain information importers may eventually need to provide.

Its Advance Notice of Proposed Rulemaking, “Heightened Import Disclosures for Supply Chain Visibility,” considers requirements involving more information about parties throughout the supply chain, technical tracing capabilities and foreign export documentation. This is still a potential rulemaking, not a final rule, and CBP is accepting comments through December 1.

I wouldn’t brush this off as another paperwork issue.

Customs has been moving deeper into the supply chain for years.

Origin, forced labor, valuation, classification, transshipment, manufacturer information. More and more, what happens before a shipment reaches the United States matters to what happens when it gets here.

If CBP ultimately requires more of that information at entry, the broker can transmit the data. Somebody still has to obtain it.

That somebody is the importer.

And that’s where I’d start looking now. How much visibility do we actually have beyond our direct supplier? What information could we produce if CBP asked for it? How dependent are we on vendors overseas to provide it?

You might be surprised by the answers.

One for the Road

CAPE Phase 3 opens October 6.

I know. I said last week I wasn’t putting the date in permanent ink.

I’m getting closer.

For the qualifying importers currently included in Phase 3, next week should finally give us a look at how the process works with actual refund applications moving through the system.

We’ll be watching closely.

But when I look across everything happening right now, I keep coming back to visibility.

Visibility into your entries. Your suppliers. Your sourcing countries. Your duty exposure. Your records.

We’ve been in this business for more than 75 years, and the amount of information available to importers today would have been unimaginable when J.M. Rodgers started.

The funny part is that the basic advice hasn’t changed all that much.

Know what you’re importing. Know who you’re buying it from. Keep good records.

The government may keep finding new reasons to ask.

See you next week.

Jamie Rodgers
CEO, J.M. Rodgers Co.