Don’t Let Compliance Become Your Horror Story

BY:

Sandra Strong
28 October 2025

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Export and import controls aren't just red tape…. They are serious! The penalties are real, and the ghosts of mistakes past are hard to banish. So this Halloween, double-check your HS codes, origin declarations, OGEL conditions, and valuation methods. Because nothing's scarier than the words: "You are under investigation."

The Origin Mistake: A Tale of Tariff Terror

When Trump returned to the White House in 2025, one of his first moves was to reinstate and expand tariffs on Chinese-origin goods, citing "economic resilience" and "national security." For UK exporters with links to US supply chains, it marked the start of a new nightmare. At Braxwell Components Ltd, Nigel—the ever-efficient sales director—was proud of his ability to turn orders around quickly. He wasn't one for fine print or footnotes, especially when it came to customs paperwork. So when it came time to fill in the Certificate of Origin for a shipment of control units headed to a key US client, he didn't hesitate: "UK origin," he declared, as the company always had. After all, the units were checked and packed in Leeds, and some of the Chinese parts did fit together.



Surely that made them British enough, didn't it? Weeks passed without incident. But then came a cryptic email from the customer's US customs broker: "Urgent: Query on declared origin under 2025 Section 301 tariffs. Please confirm the Chinese content." Nigel dismissed it. "All UK assembled," he replied. But questions kept coming back, and details of the "assembly" were requested, and all the time the goods were delayed in customs, and the customer was getting very jittery. Then a 2nd, a 3rd and a 4th import from Braxwell were detained. The Halloween decorations in the office seemed to grin menacingly at Nigel, especially that stupid spider!!!


Then came the final email. This time it included flagged entry reports, documentation reviews, and a worrying phrase from the US Customs and Border Protection (CBP): "Substantial transformation not met." US Customs had classified the items as Chinese-origin, regardless of where they were "assembled". That meant Braxwell's clients owed the full additional tariff rate on the imports – an eye-watering potential of up to 84% or more, once you stacked Section 301 duties, IEEPA surcharges, and Trump's new "reciprocal" tariffs. Retrospective duty charges were being assessed on imports that had been allowed in as UK origin.  Head in hands, Nigel sadly acknowledged the message from one client cancelling all future orders; another threatened litigation. 


Nigel tried to argue the logic of UK labour and assembly, but logic doesn't override regulation – even his Halloween spider seems to shake its head. Braxwell had also been warned that they could now face investigation under US and UK compliance frameworks.


The lesson was clear: origin isn't about where a box is closed—it's about where its value is created. For Nigel, Halloween came early—and it brought spreadsheets, angry customers, extra duties, and a potential loss of market access, not to mention a laughing spider. 



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