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Procurement Risk Briefing · #4

The customs rules just changed under your feet — your landed-cost math is already wrong

Week of June 17, 2026 · 3 items · 4-minute read

1. The customs rules are changing — re-audit your importer-of-record arrangements before they land

The administration is overhauling US customs rules, and trade experts are telling companies to re-evaluate their importer-of-record arrangements and tighten supply-chain visibility ahead of the changes, not after. The specifics are still being finalized, so treat this as a planning signal rather than a fixed effective date — but the direction is clear: the obligations and liability that attach to bringing goods across the border are moving. A change to who is the importer of record, or what they must document, can shift compliance cost and exposure onto a party in your chain that wasn’t carrying it before.

So what: pull your importer-of-record arrangements on your top import lanes now and confirm who actually carries the obligation under the new rules — before a shipment is held at the border, not after. The cheapest version of this audit happens while the rule is still proposed; the expensive version happens at a detained container.

2. The EU-US tariff deal re-prices your transatlantic lanes

The EU has given final approval to install a US tariff deal: EU officials say the bloc plans to remove tariffs and begin providing preferential market access for a range of US goods by the end of the month. If that timeline holds, transatlantic lanes that were uneconomic last quarter may now clear — and the competitive math for sourcing across the Atlantic changes for everyone at once. The risk isn’t the deal itself; it’s that your sourcing decisions are still running on the old schedule. A lane you wrote off may now be your cheapest option, and a supplier relationship you built around the old tariff wall may no longer need that premium.

So what: re-pull landed cost on your transatlantic and tariff-exposed lanes against the new schedule, not last quarter’s. Confirm the EU timeline against the primary source before you act on it — but get the re-price queued now, because the companies retooling first capture the lanes that just opened.

3. Tariff and transfer pricing are one number now — not two

The Council of Supply Chain Management Professionals’ latest State of Logistics report calls this market a “structural reset,” telling supply-chain managers to treat disruption and volatility as the norm rather than the exception. Inside that reset, the cost driver runs two layers deep. Tariffs hit the invoice — but transfer-pricing treatment determines how that cost lands across your legal entities, and which entity books it changes your real margin. Procurement and finance usually negotiate those two levers separately. When customs and tariff schedules move in the same quarter, treating them as one coupled number is what separates an accurate forecast from a surprise.

So what: model tariff exposure and transfer-pricing treatment together on your most exposed categories, not in separate spreadsheets owned by separate teams. Visibility tells you the box moved; this tells you what it now costs — and the decision layer on top of the landed-cost number is where the margin actually lives.