Letter from the President
Dear Valued Clients and Partners,
As we begin 2026, the global trade environment continues to reflect the pressures and adjustments of the past several years. Tariffs remain in place, enforcement standards are elevated, and supply chains are being reshaped with long-term risk in mind rather than short-term disruption. For many businesses, uncertainty has become a constant rather than an exception.
At ITC Diligence International, our focus through this period has remained consistent. We work alongside our clients to bring structure, clarity, and confidence to complex trade environments. Whether navigating sustained tariff exposure, adapting to regulatory scrutiny, or evaluating programs like Foreign Trade Zones and weekly entry strategies, our role is to help clients make informed decisions that hold up over time.
Throughout 2025, we saw companies move away from reactive trade management and toward more deliberate planning. That shift is reflected in the articles throughout this report. Importers are reassessing cost drivers like MPF, strengthening compliance controls, and embedding customs strategy earlier in their operations. FTZs continue to play a critical role in managing duty exposure and supporting supply chain flexibility, as highlighted in the latest Annual Report.
At the same time, ITC has continued to grow thoughtfully, expanding our capabilities and preparing new service offerings designed to support clients more holistically. While the trade landscape evolves, our commitment to accuracy, responsiveness, and partnership does not. We remain focused on delivering steady guidance and practical solutions, even as demand for expertise increases.
Looking ahead, 2026 will reward preparation and discipline. Companies that invest in compliance, visibility, and strategic alignment will be better positioned to manage what comes next. ITC stands ready to support that work with experience, consistency, and a clear understanding of today’s trade realities.
Thank you for your continued trust in ITC Diligence International. We look forward to supporting your success in the year ahead.
Here’s to a successful trade year,
Here’s to a successful trade year,
David Harlow
President & CEO
ITC Diligence International
Global Trade Enters 2026 Under Pressure
As 2026 begins, international trade remains shaped by decisions made over the past two years. Tariffs imposed in 2024 and 2025 are still in effect, enforcement activity remains elevated, and importers are planning around sustained trade risk rather than short-term disruption.
Many measures introduced as temporary responses have become ongoing realities. Instead of waiting for reversals, companies are adjusting sourcing, compliance, and customs strategy to operate under continued pressure.
What’s Carrying Over from 2025
Several trade conditions have followed businesses into the new year:
- Active tariffs across metals, autos, electronics, and industrial inputs
- Heightened customs enforcement focused on valuation, classification, and origin
- Trade policy shaped increasingly by geopolitical risk
Agencies like U.S. Customs and Border Protection and the Office of the United States Trade Representative have made it clear that compliance expectations will remain firm. As a result, companies are turning more frequently to international trade consulting support to interpret policy shifts and maintain consistency across ports and product lines.
How Importers Are Responding
After a year of reactive decision-making, many companies are shifting toward structure and control. Early 2026 planning shows:
- Product-level tariff exposure reviews
- Tighter internal compliance controls
- Earlier evaluation of trade programs such as Foreign Trade Zone operations, bonded facilities, and duty mitigation
Customs strategy is moving upstream, becoming part of planning rather than a downstream correction. Importers that incorporate Foreign Trade Zone planning alongside professional international trade consulting are better positioned to manage both cost and compliance.
Why This Matters Now
Trade risk is no longer episodic. It is operational. Companies that treat tariffs and enforcement as ongoing variables are better positioned to control costs, reduce disruption, and maintain continuity.
As global trade continues to evolve, the advantage lies with businesses that plan deliberately, leverage Foreign Trade Zone programs effectively, and rely on experienced international trade consulting to stay aligned with enforcement expectations.
Import Costs in Focus as MPF Cap Adjustments Take Effect
As 2026 gets underway, many importers are beginning to feel the operational impact of the updated Customs Merchandise Processing Fee (MPF) cap that took effect on October 1, 2025. While the adjustment itself was expected, its real implications are now showing up in entry volumes, filing strategies, and landed cost calculations.
MPF is assessed on most formal entries as a percentage of cargo value, subject to both a minimum and a maximum cap per entry. With the new cap now fully in effect, importers filing high-value or high-frequency entries are seeing MPF become a more meaningful cost driver than in prior years.
Why MPF Matters More in Q1
For many companies, the start of the calendar year brings fresh contracts, new sourcing patterns, and higher shipment velocity. When those shipments are filed individually, MPF can quietly compound across dozens or hundreds of entries.
This has made MPF planning an active discussion point for:
- Importers with frequent inbound shipments
- Companies managing multiple ports of entry
- Businesses importing high-value goods
Without a clear strategy, MPF exposure can grow quickly and erode margins.
Weekly Entry Strategies Gain Attention
One of the most effective ways to manage MPF exposure is through the Weekly Entry Program. By consolidating eligible shipments into a single weekly entry, importers can significantly reduce the number of MPF assessments incurred.
For companies with consistent inbound flow, weekly entry structures can:
- Lower cumulative MPF cost
- Simplify entry processing
- Improve cash flow predictability
Proper setup, eligibility review, and coordination with customs brokers remain critical to ensure compliance.
The Role of FTZs and Centralized Customs Management
Foreign Trade Zones add another layer of opportunity when managing the merchandise processing fee. Admissions into an FTZ are not subject to MPF, and weekly entries filed upon withdrawal for consumption can further reduce overall MPF exposure.
Many importers are pairing FTZ usage with centralized customs oversight to:
- Standardize filing practices
- Track MPF exposure across facilities
- Align entry strategies with operational flow
What Importers Should Review Now
- Entry frequency and shipment patterns
- Eligibility for weekly entry filing
- FTZ utilization and withdrawal strategies
- Coordination between internal teams and customs partners
With MPF adjustments now in effect, early review can prevent unnecessary costs from accumulating throughout the year.
Employee Spotlight: Tasha Wooten, CCS, AZS
FTZ Implementation and Compliance Specialist
When Tasha Wooten joined ITC Diligence International, she brought with her deep experience in Foreign Trade Zones and a clear appreciation for collaboration, communication, and commitment. What first drew her to ITC was the way conversations were handled from the very beginning. Rather than being talked at, Tasha felt genuinely heard, especially during early discussions with the leadership team. That sense of respect and open dialogue continued well beyond her first day.
In her first weeks on the team, Tasha noticed that the culture at ITC matched the expectations set during the interview process. Encouragement, teamwork, and open communication are an everyday practice. As the trade and logistics landscape continues to evolve, she is excited to grow alongside ITC and contribute to the firm’s expanding role in the FTZ and compliance space.
With more than 14 years of experience in the FTZ program from the operator, administrator, and management perspectives, Tasha has seen the program from nearly every angle. Since joining ITC, what has stood out most is working across multiple companies and ports of entry. That exposure has highlighted how differently FTZ procedures and compliance practices can be applied from port to port. Seeing those variations firsthand has been both eye-opening and motivating, reinforcing her interest in continued learning and in supporting greater consistency within the FTZ program.
Of ITC’s core values, Commitment resonates most strongly with Tasha. After spending nearly two decades with a previous employer and building long-term personal and professional relationships, she believes commitment means staying engaged, working through challenges, and following through even when the work becomes complex. That mindset shapes how she approaches client support, compliance responsibilities, and collaboration with colleagues.
Tasha’s experience, perspective, and dedication make her a valuable addition to the ITC team. We’re excited to have her expertise supporting clients as they navigate FTZ implementation and compliance with confidence.
Fun Fact
🥑 Holy Guacamole!
Did you know avocados remain one of the most heavily traded agricultural products between the U.S. and Mexico? Each year, the U.S. imports more than 2.5 billion pounds of avocados, with over 90% sourced from Mexico, making them a standout example of high-volume, high-coordination global trade.
What makes the avocado supply chain especially impressive is how tightly it’s managed:
- Precision timing: Imports surge ahead of peak demand periods, especially around major events like the Super Bowl, which consistently ranks as the largest week for avocado imports.
- Strict inspections: CBP and USDA conduct layered inspections to ensure every shipment meets quality and phytosanitary standards before entering U.S. markets.
- Broad economic impact: The avocado trade supports tens of thousands of jobs across farming, transportation, cold storage, and distribution networks on both sides of the border.
So the next time you scoop some guacamole, just think you’re enjoying a snack that’s a product of international trade, logistics planning, and customs coordination working exactly as intended..
Client Spotlight: Aisin Holdings
Strategic Automotive Logistics Enabled by FTZ Expertise
This quarter, we’re spotlighting a major global automotive collaboration supporting Aisin Holdings, one of the world’s top automotive suppliers. Headquartered in Kariya City, Aichi, Japan, Aisin operates more than 200 companies worldwide and employs over 120,000 people across North America, Asia, and Europe. Its scale and role in the automotive supply chain demand logistics solutions that deliver precision, compliance, and continuity.
To support high-volume manufacturing and distribution, Aisin relies on advanced logistics coordination and customs planning to keep critical components moving efficiently across borders while managing tariff exposure and regulatory risk.
Partnering with ITC Diligence International
ITC Diligence International worked closely with Bee Imagine and Sankyu USA to design and implement a tailored Foreign Trade Zone solution supporting Aisin’s automotive operations. Sankyu USA, founded in 1918, is one of Japan’s leading industrial logistics providers and a dominant force in international freight forwarding, paricularly throughout the Far East.
Leveraging long-standing relationships and deep FTZ expertise, ITC coordinated a compliant, operationally aligned FTZ strategy that supports Aisin’s complex inbound logistics for its Toyota account. The solution covers the import of transmission units, transfer case units, and spare parts, all admitted directly into the Foreign Trade Zone for controlled handling and strategic customs entry decisions.
Delivering Operational Stability and Compliance Confidence
Through this FTZ framework, the operation benefits from a clearly defined distribution structure:
- Transmission and transfer case units are exported directly from the FTZ to Mexico, avoiding unnecessary U.S. duty exposure.
- Spare parts destined for the U.S. market are entered under consumption procedures with full customs compliance oversight.
This approach delivers meaningful cost efficiency, strengthens supply chain continuity for Toyota, and provides insulation from tariff volatility. With ITC managing FTZ compliance, reporting, and coordination, Aisin gains long-term operational stability and confidence in a shifting trade environment.
This collaboration highlights how strategic FTZ planning and hands-on compliance management can support even the most complex global automotive supply chains.
FTZs Continue to Prove Their Value in a Shifting Trade Environment
The 2024 Annual Report on the Foreign-Trade Zones Program (AR-2024) reinforces what many importers already experienced firsthand last year: Foreign Trade Zones remain one of the most effective tools for managing cost, compliance, and operational flexibility during periods of trade uncertainty.
Despite ongoing tariff pressure, supply chain realignment, and enforcement activity, FTZ usage remained strong throughout 2024. Operators across manufacturing, distribution, and logistics sectors continued to rely on zones to control duty exposure, improve inventory visibility, and maintain compliance as trade policies evolved.
Key Takeaways from AR-2024
The report highlights several trends shaping the FTZ landscape:
- Sustained economic impact
FTZs continue to support hundreds of thousands of U.S. jobs and facilitate a significant share of total U.S. exports, underscoring their role in domestic manufacturing and global trade competitiveness.
- Manufacturing remains a core driver
Active production authority within FTZs stayed robust in 2024, particularly in automotive, electronics, energy, and consumer goods. Many operators used zones to offset tariffs on components while keeping final production in the U.S.
- Compliance expectations continue to rise
CBP increased its focus on inventory controls, admission accuracy, and reconciliation practices. The report emphasizes the importance of strong internal controls and documented procedures for long-term program success.
- Zones support supply chain restructuring
As companies adjusted sourcing strategies and distribution models, FTZs provided flexibility to adapt without disrupting customs compliance or duty planning.
What This Means for 2026
The AR-2024 findings make one thing clear: FTZs are no longer viewed as niche programs or short-term solutions. They are now embedded into broader trade and supply chain strategies.
For operators, this means:
- Greater emphasis on accurate reporting and audit readiness
- value in professional oversight and managed FTZ support
- Strong alignment between FTZ operations, customs strategy, and financial planning
How ITC Helps
ITC Diligence International works closely with FTZ operators to translate program benefits into consistent, compliant results. From annual reporting support to operational reviews and long-term planning, our team helps clients align their FTZ programs with today’s regulatory expectations and tomorrow’s trade environment.
As the AR-2024 shows, FTZs continue to be a cornerstone of effective global trade strategy when they are managed with intention and expertise.
Global Trade Enters 2026 with New Pressures and New Priorities
As 2026 begins, the global trade and logistics environment reflects a year of adjustment rather than recovery. While some disruptions eased in late 2025, new pressures around tariffs, enforcement, and infrastructure continue to shape how goods move across borders.
Tariffs Remain a Defining Factor
Tariff policy continued to influence sourcing and routing decisions throughout 2025, and those effects are carrying into the new year. Section 301 duties remain in place, Section 232 discussions are ongoing, and retaliatory measures across key trade lanes have encouraged importers to reassess supplier concentration and cost structures.
Many companies responded by:
- Diversifying sourcing to reduce country-specific exposure
- Shifting production stages to tariff-neutral jurisdictions
- Using tools like FTZs, bonded facilities, and duty deferral programs to manage cash flow
These strategies are now becoming standard practice rather than contingency planning.
Enforcement and Compliance Took Center Stage
CBP enforcement activity increased steadily in 2025, with heightened scrutiny on valuation, classification, and country-of-origin claims. The AR-2024 highlights a continued emphasis on data accuracy, inventory controls, and audit readiness, especially for companies operating in Foreign Trade Zones.
Importers entering 2026 should expect:
- More documentation requests tied to tariff-sensitive goods
- Greater focus on reconciliation and record retention
- Increased coordination between customs, finance, and logistics teams
Logistics Networks Continue to Rebalance
While port congestion improved in some regions, transportation networks remained uneven. Labor negotiations, weather disruptions, and infrastructure constraints continued to impact transit times and reliability.
In response, logistics strategies evolved to include:
- Broader port diversification across U.S. coasts
- More inland warehousing to support buffer inventory
- Tighter alignment between transportation planning and customs strategy
Looking Ahead
The trade environment entering 2026 favors preparedness over prediction. Companies that invested in compliance infrastructure, operational flexibility, and centralized oversight in 2025 are better positioned to absorb future disruptions.
As global trade continues to adapt, companies that monitor tariff policies closely and align logistics with compliance strategy will be better positioned for stability in 2026.
For importers and exporters alike, success in the year ahead will depend on how well logistics, customs, and trade strategy work together as a single system rather than separate functions.
