2025 in Review: A Year of Change and Vigilance

Reciprocal Tariffs in Flux

It has certainly been an eventful year in the tariff world. 2025 began with the promise and the introduction of sweeping, high tariffs on nearly all imports. While there was a transition to a two-tiered system including broad tariffs and country-specific rates, the mid-year brought pauses, renegotiations, and recalibrations. The fall included more strategic trade-deal frameworks and by year end we have seen major exemptions (especially food/agriculture), put in place to try and ease the impact on U.S. consumers.

Many of the new tariffs were deemed drawback-eligible but the legality of them remains under scrutiny. As we await the Supreme Court’s decision, the future of the reciprocal tariffs and their recovery through duty drawback remains uncertain. ITM continues to follow the situation and we are ready to guide all our existing and new clients as we navigate this ever-changing landscape into 2026.

CBP Audits Surge 50%

As promised, CBP has significantly increased customs audits in 2025. Early in the year, audits surged, uncovering numerous instances of improperly declared or undervalued goods. By mid-year, duties and fees identified through audits had risen sharply compared to 2024, signaling stricter enforcement and less tolerance for compliance failures.

According to sources, CBP's audits increased by more than 50% by April 2025 compared to the entire fiscal year of 2024. In August, a new Trade Fraud Task Force was established, focusing on misclassifications and compliance issues.

CBP has made it clear that enforcing new tariffs and ensuring compliance with trade regulations are top priorities. As enforcement continues to tighten, it’s critical for all importers to fully understand the requirements and ensure compliance to avoid the consequences of noncompliance. The audit process will only intensify, so it’s more important than ever to be prepared.

Our Commitment to Your Success in 2026

As we bid 2025 farewell, we at ITM would like to express our sincere thanks and appreciation to all our clients, colleagues, and friends. We wish you all a happy and healthy holiday season and look forward to continuing our relationships into the new year!