Let’s Talk Tariffs with Jamie Rodgers: China Trade Deadlines Approach, USTR Proposes Extension & CBP Delays ACAS Enforcement

Your weekly coffee chat on tariffs & trade.

We’ve spent much of this year talking about new tariffs, changing trade policies and the challenges businesses face trying to keep up with it all.

This week, we’re talking about something a little different. More time.

The Office of the U.S. Trade Representative has proposed extending the suspension of certain Section 301 actions against China through January 9, 2027. Meanwhile, CBP has pushed the full enforcement deadline for its Enhanced Air Cargo Advance Screening requirements to May 1, 2027.

Both developments offer businesses some additional breathing room.

And after the year we’ve had in international trade, I think that’s welcome news.

But there’s an important distinction between having more time and having more certainty.

As we head toward the end of the year, that’s what I’m thinking about most.

What Caught My Eye

The approaching deadlines involving China deserve some attention.

On October 26, USTR proposed extending the suspension of certain Section 301 measures related to China’s maritime, logistics and shipbuilding industries.

Those measures, which include additional fees on certain Chinese-built or Chinese-operated vessels, were previously suspended under a U.S.-China trade arrangement.

The current suspension is scheduled to expire November 9, and the proposed extension would move that date to January 9.

For businesses involved in ocean transportation, that’s a meaningful development.

Additional vessel fees can affect transportation costs, carrier decisions and ultimately the prices importers pay to move their merchandise.

But what makes this particularly interesting is the timing.

Other U.S.-China trade arrangements are also approaching expiration in January, including the current extension of the reciprocal tariff agreement and the so-called 30-for-30 framework.

That puts several important trade decisions within a very short period.

I’ve been in this industry long enough to know that negotiations don’t always follow the schedules businesses would prefer.

Sometimes agreements come together quickly. Other times, deadlines are extended while discussions continue.

And occasionally, the outcome looks quite different from what everyone expected.

For importers sourcing from China, I think the sensible approach is to understand what these deadlines could mean for their landed costs and prepare for more than one possible outcome.

Here’s My Take

I think there’s a broader lesson in the way these trade arrangements are being handled.

Temporary extensions can be valuable. They give businesses an opportunity to continue operating under familiar conditions while governments work toward longer-term agreements.

But companies still have purchasing decisions to make, contracts to negotiate and inventory to manage.

A manufacturer can’t necessarily wait until January to decide where it will source the materials needed for production next spring.

An importer placing orders today may be making commitments that extend well beyond the current trade arrangements.

That’s where the uncertainty becomes difficult.

And I think it’s worth remembering that these decisions affect more than customs departments.

They affect finance teams building budgets, purchasing managers negotiating with suppliers and logistics teams planning transportation.

When I look at the possibility of additional tariffs on Chinese goods, my first question is how prepared a business is to absorb a change in costs.

Do they know which products would be affected? Have they calculated their exposure? Are there alternative sourcing arrangements worth evaluating?

I wouldn’t recommend making major business decisions based on speculation about what Washington or Beijing might announce next.

But I would want to understand the numbers well enough to make an informed decision when something does change.

At J.M. Rodgers, we’ve always believed that good customs management starts with understanding the business behind the entries.

That becomes especially important when trade policy is moving this quickly.

If It Were My Business…

I’d also be paying attention to the latest developments involving air cargo.

CBP has extended the phased enforcement period for its Enhanced Air Cargo Advance Screening requirements through May 1, 2027.

The rule calls for more detailed information about shipments before cargo is loaded onto aircraft bound for the United States.

That includes more precise cargo descriptions and additional information about shippers and consignees.

The extension gives the industry additional time to prepare, which I think is a reasonable approach considering the operational changes involved.

But there’s an important detail here.

Some major carriers are already implementing stricter data requirements ahead of the federal enforcement deadline.

So while CBP may be allowing more time, businesses could still encounter new requirements when booking shipments today.

If I were regularly moving goods by air, I’d be speaking with our freight forwarders and carriers about exactly what information they need and when they need it.

I’d also review the quality of the shipment descriptions and contact information we’re providing.

These may seem like relatively straightforward details, but when you’re handling a large volume of international shipments, inconsistencies can create real problems.

I’ve seen how much progress the industry has made in electronic data exchange over the years.

Better information can improve security, visibility and efficiency. But those benefits depend on the accuracy of the data being submitted.

The additional time should be used to make sure the processes are working properly.

One for the Road

Before we wrap up, I want to touch on Canada.

The latest changes to the Section 338 tariffs took effect October 30, adding and removing specific products from the additional 50% duty lists.

We’ve discussed these adjustments quite a bit recently, and I think they illustrate the same challenge businesses are facing with China.

The rules affecting international trade can change considerably while the underlying business relationships remain the same.

A company may have worked with a Canadian supplier for decades, but that doesn’t mean the cost of importing its products will remain consistent from one month to the next.

That’s why I keep coming back to the importance of communication between customs, purchasing and finance.

As we approach the end of 2026, I’d encourage businesses to take a careful look at their tariff exposure heading into the new year.

We’ve got several significant deadlines approaching, and there’s still plenty of time for new developments before January.

I’m hopeful that continued negotiations will bring greater stability to U.S.-China trade. I think that would be welcome across the industry.

In the meantime, businesses have an opportunity to review their costs, strengthen their processes and make sure they’re prepared for whatever comes next.

After 75 years in business, J.M. Rodgers has seen trade policies change many times. What remains consistent is the value of having good information and experienced people who know how to use it.

We’ll be watching these developments closely as the year winds down.

See you next week.

Jamie Rodgers
CEO, J.M. Rodgers Co.