CBP Issues Guidance on IEEPA Tariff Exemptions and Transshipments: CBP issued FAQs yesterday that addressed the “final mode” of transit definition in the executive order on the IEEPA reciprocal tariffs. After some weeks of speculation on the interpretation of final mode, the announcement answers the question of whether final mode is the final mode of transit to the USA or the final “vessel” moving the cargo to the USA. Yesterday’s announcement confirms that the cargo must be on the same vessel that is moving the cargo to the USA before April 5th. That vessel may make stops at intermediate ports to load, unload, or refuel BUT the original cargo destined for the U.S. must remain on that vessel. If cargo leaves a foreign port before April 5, but is offloaded and put on another vessel at a transit port after April 5, it is not eligible for the tariff exemption. For importers who may have claimed the exemption based on first port of loading in a transshipment situation, options are available to correct the entries and PSC/Post Summary Corrections can be transmitted. We expect CBP will issue CF 28 (Request for Information) or CF 29 (Notice of Action) to rectify incorrect entries. Keep in mind that Customs will charge interest on underpaid duty, thus taking corrective action via the PSC process could limit interest exposure. The FAQs from CBP issued yesterday are attached here.
Europe Rail Congestion & Work Stoppage Notice: Unfortunately, congestion is continuing in North Europe. The latest update concerns Germany and the rail infrastructure that has become completely overloaded due to construction sites within the Port of Hamburg and on inland routes. For this reason, the region has switched to dispatch-based train control throughout northern Germany. Trains are standing both inland and at the port, waiting to be allowed to arrive and depart. Loading delays, departure delays and complete train cancellations are to be expected. Currently, punctual deliveries are not guaranteed, but our teams in Europe are working hard to mitigate the delays as much as possible.
Additionally, the Port of Antwerp has announced a strike for May 20th, 2025, during which time only import containers will be processed. Some containers are extending gate hours prior to the strike in an effort to combat the expected congestion, but please note that additional delays may be present due to this situation.
Dozens of vessels remain outside the ports of Antwerp and Rotterdam awaiting berthing slots. Some carriers are also continuing to shunt containers between these two ports based on changes in berthing windows due to the continued chaos in the ocean carrier alliance restructuring. The delays in shipping are primarily due to port issues, not due to space on vessels, but the port and inland issues continue to create backlogs in cargo and rolling of bookings. We hoped the new alliance structure would be running more smoothly after three months, but we are still seeing many problems with the ship systems. This does extend to the Mediterranean as well, with blank sailings due to lack of vessels to complete weekly rotations, and average delays of 3-6 days compared to the expected sailing date.
Congestion at London Gateway: London Gateway Port is experiencing moderate congestion, with vessel berthing delays averaging between 6 to 10 days. This congestion is primarily due to high yard utilization and reduced lifting capacity in both laden and empty storage areas. Additionally, one of the quay cranes (Crane 4) is out of service, further impacting operations. Shippers utilizing London Gateway should anticipate potential delays and consider adjusting their logistics plans accordingly. Exploring alternative UK ports, such as Southampton or Liverpool, may help mitigate the impact of current congestion.
Mexico Labor Strikes – On Monday and Wednesday work stoppages took place at Manzanillo port and customs office. The work stoppages are in association with a labor strike by personnel from the National Customs Agency of Mexico (ANAM). Port and customs operations were fully halted during the work stoppage times, and some delays may be expected due to this disruption. We will continue to monitor the situation and provide updates as available.
South America: Winter has started and we are already seeing border closures between Argentina and Chile, as well as heavy weather affecting port operations. The last year was exceptionally bad for the mountainous border road and the number of cut and run operations at San Antonio port in Chile. We expect this winter to be equally disruptive. Please reach out to WSSA should you need more information or options for storage of cargo near the port facilities to minimize disruption.
NW Seaport Alliance (Seattle/Tacoma): WSSA will be hosting a port tour and logistics briefing on June 16th in Seattle/Tacoma. Space is limited, but ff you are interested in joining, please contact us.