Managing Customs in 2027: A roadmap for navigating trade volatility

Compliance with unfamiliar legislation, new tariffs and regulatory changes is complex, time-consuming and fraught with risk. Take a few minutes to evaluate your business’s current compliance process against the following model of good, better, best and get a sense of how resilient your business is.

Product-level tariffs, potentially tighter USMCA origin rules, and customs modernization efforts are the latest challenges in what has been an unprecedented period of change in customs and trade. Proactively evaluating your customs processes and regime as part of your 2027 planning can not only help you prepare for expected changes, but also help you build the data, controls, and expertise needed to respond when the unexpected occurs.

Build your 2027 customs plan

An effective customs plan can turn regulatory compliance into a competitive advantage. How effective is your customs and trade compliance regime?

Three key events shaping North American trade and imports—and your customs plan:

U.S. tariff architecture is shifting from broad shocks to product-level controls

Contract pricing, inventory timing, and sourcing decisions can become commercially obsolete between order placement and customs entry.

Where legal authority, exclusions, or refund mechanisms change, importers need accurate and organized entry-level data and payment controls to identify recoverable amounts quickly.

The 2026 USMCA renegotiation is turning origin into a board-level cost variable

of U.S. companies are already planning to nearshore

A tighter origin rule can change the economics of trading a product without changing its supplier or factory. Goods assembled in Canada, Mexico, or the United States may still lose preferential treatment if non-originating inputs, tariff-shift requirements, regional value-content calculations, or supporting records no longer satisfy the rule. The resulting duty can erase the nearshoring advantage, force repricing, or make an existing bill of materials commercially uncompetitive.

The impact:

The opportunity for North American importers includes:

But the review also changes how brokerage and trade-management teams must operate:

Certificates need validation against the actual rule—not merely collection and storage.

Broker instructions and entry controls must change rapidly when a product’s qualification status changes.

Classification, origin, supplier, and bill-of-materials data must be governed together.

Requalifying products constantly, even before revised rules take effect, rather than discovering a failed claim during an audit.

Automating supplier solicitation, origin evidence, and qualification workflows so claims remain current and defensible.

Using scenario analysis to compare preferential duty savings with the cost of changing suppliers, production steps, or inventory location.

Identifying which non-originating inputs drive a negative result and where supplier or bill-of-materials changes create measurable duty savings.

Greater customs scrutiny is raising the cost of non-compliance

Trade compliance is moving into a period of heightened regulatory scrutiny across North America. Customs authorities are increasingly focused on identifying tariff circumvention, validating origin claims, enforcing supply chain due diligence requirements, and ensuring importers can substantiate the information reported on customs entries. In the U.S., CBP’s efforts continue to focus on areas such as country-of-origin verification, preferential trade agreement claims, and attempts to evade applicable duties through transshipment or inaccurate product reporting. There is also greater scrutiny of importers themselves, and an effort to verify the accuracy of importer information submitted on CBP Form 5106. In Canada, policymakers have signaled their intention to strengthen forced-labor compliance expectations, increasing pressure on importers to demonstrate greater visibility into their supply chains and sourcing practices. The trade dispute with the U.S. has also brought on greater scrutiny of classification, particularly as it pertains to goods to which surtaxes are now being applied. Lastly, customs officials have become more diligent about verifying the valuation of goods as part of the CARM initiative that has provided CBSA with greater visibility in identifying non-compliance. Customs compliance extends beyond simply filing entries correctly; it’s about maintaining the evidence needed to support customs declarations when challenged.

Importers will need to:

Maintain complete, audit-ready records supporting classification, valuation, and origin determinations.

Establish documented processes for validating supplier information and trade agreement eligibility claims.

Ensure customs-entry data aligns with commercial, procurement, and supply chain records.

Can your current model detect a tariff or origin change before entry, produce the evidence customs authorities may request, and quantify corrections or recovery opportunities afterward? What operational foundations should an agile customs plan be built on going into 2027?

Assessing your brokerage process

Increased scrutiny means customs authorities are asking more detailed questions about how importers arrive at classification, origin, valuation, and supply chain compliance decisions, and have less tolerance for those that are non-compliant. Businesses that can quickly produce accurate supporting documentation, supplier evidence, and decision records will be better positioned to manage audits, maintain border fluidity, and reduce compliance risk.

Critical consideration

Publicly announced U.S. trade actions illustrate a broader shift toward product-specific controls. These measures can depend on classification, product composition, origin, and entry date, requiring importers to evaluate applicability against their own products and transactions.

Your 2027 customs plan: Optimizing customs compliance

Good

Tariff response should begin by treating classification and origin analysis as part of a strategic approach to customs management and compliance rather than simply data points on customs entries. Importers can then establish documented processes for reviewing classifications, monitoring exclusions, correcting entries, and evaluating eligible drawback or refund opportunities.

Critical consideration

Shifting tariffs, uncertainty around the USMCA, and greater customs scrutiny are just three of the challenges reshaping the current North American trade landscape. As 2027 approaches, a proactive customs plan could help you respond more nimbly to regulatory changes, improve your cash flow, maintain compliance, and avoid surprises at the border.

Importers should review products with significant preferential-duty exposure, assess whether current qualification assumptions remain valid, and evaluate alternative sourcing or qualification approaches before revised rules create cost or continuity risks.

Critical consideration

Basic compliance:

Adhering to the fundamental rules and regulations governing international trade, and basic compliance with trade sanctions. Why it matters: Getting the basics right means no surprises, no delays at the border, no unnecessary duty spend, and happy customers.

Accurate documents:

Ensuring that all required documentation, such as invoices, packing lists, and certificates of origin, is accurate and complete. Why it matters: Unforeseen issues with incorrect paperwork can result in costly penalties for you and delays for your customers.

Awareness:

Making efforts to stay informed about key regulations, changes in laws and trade agreements. Why it matters: Knowing what’s up ahead means you can plan and adapt your business to take account of external changes.

Better

Risk management:

Conducting risk assessments, identifying potential compliance risks, and implementing measures to mitigate those risks. Why it matters: Legal issues can arise from violating regulations or laws, resulting in fines, legal action, or reputational damage.

Technology integration:

Using technology solutions, such as trade compliance software and automation tools, to enhance accuracy, efficiency, and visibility. Why it matters: Technology can help you avoid human error, comply with regulations, minimize risks and be agile enough to adapt to market changes more rapidly than your competitors.

Employee training:

Investing in staff training programs to ensure a good understanding of relevant regulations and compliance procedures. Why it matters: Investing in staff training programs is an investment in the company's stability, growth, and long-term success.

Best

Strategic compliance management:

Knowing how to align your compliance efforts with overall business strategies, integrating compliance considerations into supply chain and logistics decisions. Why it matters: It’s not just about avoiding penalties. It’s also ensuring your business is operating ethically, protecting your reputation and brand, and reducing risk.

Continuous monitoring and auditing:

Continually monitoring trade activities and regular internal audits to identify and address compliance gaps and provide insights for continuous improvement. Why it matters: Stay up to date with changing compliance rules and how your business is adhering to them. You’ll minimize risks, enhance operational efficiency, and maintain a positive reputation in an increasingly regulated business environment.

Global trade expertise:

Partnering with international trade experts to navigate global trade complexity and seize opportunities while mitigating risks. Why it matters: Expert partners are valuable allies to help minimize risks and maximize opportunities. Demonstrating your commitment to compliance helps build trust among stakeholders and investors.

Where legal authority, exclusions, or refund mechanisms change, importers need entry-level data and payment controls to identify recoverable amounts quickly.

Public discussions surrounding the 2026 USMCA review emphasized regional benefits, rules of origin, economic security, and regulatory compatibility. For importers, the commercial implication is clear: preferential treatment requires ongoing validation against the applicable rule and supporting evidence.

Monitor regulatory developments and enforcement priorities that could affect existing sourcing or import practices.

Need help putting your 2027 customs plan in motion? At Livingston, we assist our clients in securing their business’ future by refining the way they approach compliance. Our customs and trade experts can help you keep your business compliant and competitive in the new year.

Conduct regular post-entry reviews to identify potential compliance gaps before they become audit findings or penalties.

2024 Trade Dynamics: Key Shifts, Business Resilience, and Strategic Brokerage

Let’s take a moment to assess your current brokerage process and get a sense of how resilient your business is using the good, better, best model below.

At Livingston, we assist our clients in securing their business’ future by refining the way they approach compliance.

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The impact of key events in 2024 on brokerage processes and strategic tips for resilience and optimization in an ever-changing landscape.

Three key events shaping North American trade and imports in 2024

A universal 10% tariff

10% minimum universal tariff, up from today’s 3% average

$300 billion yearly collective tax increase

Nearshoring

of U.S. companies are already planning to nearshore

One out of three U.S. businesses are planning to replace or supplement their overseas suppliers with those that are closer, often in Mexico or Canada.

The impact:

The benefits to the U.S. include:

But these benefits also mean changes to how goods are traded, including:

Trade lanes used

Administrative burdens associated with USMCA eligibility

Required documentation

Similar business culture

Tariff-free trade

Generally harmonized regulatory policies

Geographic proximity minimizes transport costs and times, ensuring faster product delivery to customers

The CBSA Assessment and Revenue Management Initiative (CARM)

The CARM initiative is set to go live in May 2024, changing how CBSA assesses and collects duties and taxes on commercial goods imported into Canada.

With this launch, importers will need to:

Delegate access to a customs broker

Obtain a surety bond

Is the average brokerage process good enough to withstand the changes these events could catalyze? What does a good brokerage process look like?

Assessing your brokerage process

None of the above choices are optional, and failure to complete any of them will mean interruptions, shipment delays, and extra expenses further down the line.

Critical consideration

What could a second term look like for Donald Trump?

Brokerage process resilience and optimization

None of the above choices are optional, and failure to complete any of them will mean interruptions, shipment delays, and extra expenses further down the line.

Critical consideration

Good

Strategic businesses should already be assessing the potential impact of these changes, how they can pivot, and how that pivot will affect brokerage processes.

Critical consideration

2024 is anticipated to usher in another year of uncertainty in global trade. Geopolitical conflicts, a U.S. election, trade wars, new tariffs, regulatory changes, the list goes on. These concerns are usually viewed in the context of risk, not process. But processes – specifically brokerage processes – are always impacted.

Failure to take these into consideration could offset a business’s landed-cost calculation and, in turn, its margins.

Critical consideration

Basic compliance:

Accurate customs documentation that ensures compliance with local and international regulations. Why it matters: Inaccuracies mean delays at the border and increased time in transit, leading to disappointed customers.

Communication:

The status of shipments is at your fingertips. Why it matters: In the wake of the pandemic, transparency is everything. Know where your goods are and what the status of your customs clearance is so there are no surprises.

Timeliness:

Documents are submitted on time, and any customs clearance issues are resolved quickly. Why it matters: Late documentation submission leads to border delays, as well as tarnished customer and carrier relations.

Better

Value-added services:

The confidence to navigate complex customs regulations and minimize costs by taking advantage of duty optimization programs. Why it matters: Margins are already tight, why narrow them with unnecessary duty spend? Duty recovery and strategic tariff classification means less money going to the government and more going to your business.

Technology integration:

Taking advantage of specialized customs software to automate, reduce errors, and enhance overall efficiency. Why it matters: For diverse and complex product lines with regulatory requirements, using software to maintain classification databases, compliance, and reduced errors can stave off unexpected financial penalties.

Dedicated support:

Having a real voice at the other end of the line for personalized assistance and guidance. Why it matters: When the unexpected happens, you need a partner who understands your business needs and processes to spring into action and take corrective action.

Best

Compliance expertise:

Proactively adapting your supply chain strategies in advance of regulatory changes. Why it matters: Regulations change constantly and without notice. Keeping up isn’t easy, but it’s easier when you have experts and technology solutions at the ready to pivot as necessary.

Global reach:

Knowing with confidence you can scale your services globally and not face compliance issues. Why it matters: Your business isn’t static. As you expand into new markets and source suppliers from around the world, the complexity of regulatory compliance will grow exponentially, requiring a greater breadth of expertise and process efficiency.

Continuous improvement:

Evolving your processes, embracing new technologies, keeping up with industry standards and competitor best practices. Why it matters: Anticipating changes and adapting to them means you can avoid mistakes, improve cost-effectiveness, and boost productivity. Stay ahead of the curve.