Expeditors International of Washington, Inc. (EXPD) Earnings Call Transcript & Summary

Good morning, everyone. Thank you for joining us today. You are joining, of course, the U.S. Customs Market Update brought to you by Expeditors and our Americas customs team. My name is Samantha Hurst, and I'm one of our managers for marketing and bids here in the Americas region of Expeditors. And I'll be supporting in the background, along with some of my other colleagues to answer any questions we can about technical things as well as our customs team who will be answering your questions in the background as well. But first, we'll kick off with a little bit of housekeeping for anyone who has not joined our webinars in the past, just to give you an idea of how these will typically run. So we have moved to more of about a 55-minute of content format over the last few U.S. Customs Market Update. No surprise to you all, there's a lot of content to cover every time we join one of these events as there's always something changing. So we will continue to ask you to put your questions in the Q&A box. I would encourage you to listen to a good bit of the webinar before we start throwing questions in just because I do know that we've got many questions related to the 232 tariff updates, and we will be addressing that as well as some of the questions you all have sent us directly leading up to the webinar. So just a reminder there to kind of listen intently for that information. And then one of the questions we always get is how can you get the slides. So we will send out a survey feedback, feedback survey request via email, and that will come from myself within about 2 hours of this webinar wrapping up today. Now once you complete that survey, watch closely because as soon as you hit Submit, a thank you message will pop up. And at the bottom of that thank you message will be a link to the landing page where you can find the presentation from today, today's recording as well as a Q&A report from all of the questions that we get today. And if you would like to stay informed about future webinar invites and market updates, you can scan our QR code or I will drop a link in the chat here shortly. And again, we just definitely welcome your questions and ask that you recognize that anything that's incredibly specific to your industry or business will likely have to be addressed outside of this webinar, but general questions that pertain to everyone, we will get to as many as we possibly can today. Okay. So I think now I'm passing it over -- actually, first, I got to introduce people. So Brenda Smith is our Global Director of Government Outreach. She is joining us today as well as Stephanie Holloway, who's our Regional Manager for Customs for the Americas; and Ted Henderson, who's our Senior Adviser for Customs. Now I'll pass it to you, Stephanie.

Thank you, Samantha. Thank you, everybody, for joining. So let's get started. Once again, we have our lovely disclaimer. None of us here presenting are trade lawyers or lawyers in any way. We are doing our best with the information that's being published, interpreting it and giving it out to you guys. So that is what we are all here to do. With that said, we're going to break it into about 3 parts. So the first one is the most recent U.S. Trade actions. And if you can believe it, we were only here together 2 weeks ago, and it feels like our world continues to, I don't know, someone pick it up and like shake it on us. So we're going to pull apart a little bit of what's happened in the last 2 weeks. Brenda is going to touch on what's on the horizon because there's plenty there. And Ted has a really nice section at the end, really looking at enforcement, but also how is our world shifting with everything that's happening, both as brokers and importers. So look forward to that. So with that said, let's get going. We have no shortage of activity. So this slide is our August trade action slide. Of course, we started off at the beginning of August with a big bang, fentanyl going up for Canada and also getting the copper 232 cases started. The next week, we have Brazil that got an additional IEEPA. So that's 40% on top of their reciprocal of 10%. And then the next day, we actually put into effect all of the country changes. So reciprocal tariffs, remember, have that baseline of 10% and then 95 countries, 97 countries have a different rate. So it doesn't stack on top of that 10%, but it's a different rate, ranging anywhere from 15% to 41%. So those countries got that rate added on August 7. August 11, we got a little bit of a reprieve. I guess the can got kicked 90 days down the road for China and Hong Kong country-specific reciprocal tariffs, okay? So China and Hong Kong, if anyone ask you about reciprocal tariffs specifically, we are still paying 10%. That does not mean all of China is 10%. We still have 301. We still might have 232s, but that IEEPA reciprocal tariff is 10%. This week was a pretty big surprise. So I'm going to go in depth. On Friday, we got a very big announcement about steel and aluminum tariffs, and we'll go in depth on this call about those. We have IEEPA looming, I'll touch on that. And then Brenda will talk a bit about de minimis because that one, I think, might be surprising to us in terms of how impactful it could be to an area of your supply chain that maybe you're not thinking about or even know what's flowing in those. So with that said, IEEPA reciprocal tariffs, I mean, to some extent, a bit status quo since they were implemented on August 7. So once again, remember, as you hear about these trade deals, they're not formalized deals like maybe USMCA or Korea Free trade. These are negotiated deals with these different countries. Somebody I saw asked in the chat, when are we going to get the executive orders on some of these more specific ones? I don't know. Brenda or Ted, if you guys actually have heard a more concrete date recently, please share. But right now, we're just kind of out standing by. The tariff increases on these 95 countries have gone into effect. That happened on August 7. And what was a little bit interesting is that the EU, and then we've heard Japan, had negotiated kind of a different type of tariff. And it's that one that's notated with an asterisk. So they're getting a 15%, I call it a fixed or all-in, trying to convey the uniqueness of it, I guess, for anything that has a regular duty rate or MFN, most-favored-nation rate at or below 15%, okay? So if you imported -- I'm just trying to grab something. If you imported this cup before and it was maybe 2.5%, your duty rate is now 15%, and it's a fixed 15%, okay? If the duty rate of this cup was 30%, then you're just going to pay 30%. There's no additional IEEPA, okay? So we heard that and we implemented on August 7 for the EU. But then Japan said, "Hey, we had that deal too. Where is that up for us?" The U.S. has acknowledged that they made a mistake, but we have not actually seen that formalized correction come. So Japan is there in bold to remind me to make that note. We are actively filing an in-transit exemption. So if your goods were on a boat destined to the U.S. by -- prior to August 7, we have an opportunity to not pay these additional percentages. You can just stay at the 10%, okay? And that is effective through October 5. Obviously, though, most of the stuff now that we're clearing was probably on a boat I don't know, maybe, iffy, iffy. But that trend of exemption is going to be running its course here pretty shortly, okay? As I mentioned, China, Hong Kong, Macau, that got pushed out to November 9. And then we still have this kind of looming idea about transshipment. Ted actually did a really nice slide on this 2 weeks ago. We don't have any more information concretely, but we do know that there's this idea of the Trump administration looking at where the components are coming from that are making up goods and then how those components might be, I would say, tariffs taxed differently, right? So if you want to hear more about what Ted had to say, Samantha can get you that recording, but that's still kind of an open item for us. So let's get to the good stuff. So we have to first -- before we can talk about Section 232 HTS additions, we need to step back just a titch, okay? So these were not a complete shock. And the reason was because the Department of Commerce, through an executive order on 232, the Trump administration asked them to regularly review and post a docket on Regulations.gov. This is all public. You can go look at it for a 14-day period. And what that's intended to do is to ask domestic manufacturers, hey, is there any tariff numbers that maybe you need covered to protect our local U.S. domestic manufacturing? There was a lot of responses. Oh, gosh, [ now 10 minutes ], 540 responses. You can go see them. We'll include that link in the -- I was going to say the show notes like we're running a podcast here. We'll include it in the stuff that Samantha sends out. But what it's doing is allowing people to give suggestions. So I sometimes lovingly call this section the suggestion box. So it was allowing that. People commented, importers also commented on the comments that were being made from domestic manufacturers. We knew that commerce had a 60-day -- I think it's a 60-day period to review them, and that was going to be up at the beginning of August. So on August 15, which was last Friday, BIS put out a list of 753 HTS numbers. Now you probably have heard 400. The reason there's a difference is because they put out 8-digit subheadings and some 10 digit. So when it was all said and done, there were 753 HS numbers flagged, okay? Very impactful and very impactful for many of you guys who have never had to deal with Section 232 steel and aluminum. Welcome to the circuits. This place is why some of your importer friends have been dealing with this for a long time. Okay, so tariff rate. This was 50% on steel and aluminum derivative products, okay? The scope, as I said, it expanded. And the 753 are a direct correlation to what was being requested on these dockets. In fact, there was very few that were denied. And the ones that were denied, it was said because they were covered by a different 232 case, okay? So this was -- it feels very rubber-stamped, right? They just essentially accepted all of them. It came in on Friday. There was no transit exemption, and we learned about it on Friday and it was effective on Monday, okay? So many of you guys had things on the water. There was no way to pivot. And I'm really sorry that we're all in this situation together, okay? So for those of you who have not dealt with steel and aluminum, this is very jarring. It doesn't feel like it makes sense. I understand that. So let's walk through. First of all, there was a large amount of HTS numbers flagged, of course, but it covered things like whipped cream, paint, perfume, knives, more engines, lawn mowers, wash -- more washing machines, office furniture, gym and playground equipment. It was huge. And a lot of people are asking, hey, the paint, that's packaging. Should packaging be now subject to these 232 likely aluminum, but potentially steel duties as well? Unfortunately, the answer is yes, okay? So even though we've never had to take packaging into account for classification, for this purpose, absolutely, we have to. I know, which is very strange, very frustrating. Some of you guys are probably screaming at your screens right now. The other thing that is very, very challenging for steel and aluminum is that the duty rate is specifically tied to different data elements that we've never had to provide before. Well, [ never meaning ]. You did have to provide in the normal course of your entry business. Folks who have been doing and dealing with 232 steel and aluminum have been providing these. So you're not being targeted here. Everybody has been struggling with this. So for steel, you have to provide the melt-pour country. That's one country, okay? We have one spot for that. So I know that feels kind of weird. So melt to pour, one place. And then we have a smelt and a cast country. And that's how the duties are actually being driven. So if those are U.S., then your duty is 0%. It's any other country but Russia, it's 50%. And for aluminum, if it's Russia, it's 200%. And that's really important to understand. So I know many of you guys are going to be frantically going back to your suppliers. You're going to be asking for material breakdowns. You're trying to find building material, you're trying to understand the stuff. But people are saying "I don't know where this was melted. I don't know where it was cast." For steel and aluminum, customs has made adjustments in this past year that we can send unknown. The problem with aluminum is if we send unknown, it's going to be a 200% duty rate. And that's because they can't rule out that it's not Russia. And this is very frustrating. I know it's very hard to deal with. So that's the state we're in. You can provide partial breakdowns for all of these. And I know many of you guys are frantically trying to figure those out. One strategy that many importers did back in March when this came on so suddenly for theirs was they have to pay full value and then you'll ask your broker to go back and do post entry once you get that documentation and you understand. There's a lot to stomach, I understand. This gets into partial values as well, documentation. So I want to review this. I know we've talked about it before, but because we have so many more friends in this space, I want to talk about this. Customs has put out one FAQ on how to determine your partial value, okay? There's a link there. I encourage you to go read it. As an importer, you need to show reasonable care and make sure that this value as determined is just as good as all the other data elements you're offering up on your customs entry. As a broker, we're going to have to split this into two lines. So this is going to double your entry count. We're going to have a non-steel aluminum content line and a steel, aluminum content line. So it's going to make the audit very challenging. It makes reconciliation very challenging. It makes drawback very challenging, okay? The way that customs implemented this is very strange. So when you start to see this come through, you should be looking at these very closely, and they're hard to understand and they're hard to pick out. Customs has not said clearly and definitively what type of documentation. There's a source link here for this. So certificate of analysis, bill of materials, they're not required a time of entry, but you should have some backup. When I traveled around the U.S., different importers are requiring different things. Some of you guys are taking it in an email. Some of you guys are making suppliers do certifications. Some of you are getting lots of documentation. It's really up to you as an importer to make sure that you can show reasonable care. Customs comes and ask you, "How did you determine this value?" You can show your work, right? It's just like homework, show your work. You can't just have an answer at the end. The other thing that you have to be thinking about in partnering with your broker on is how are you going to communicate this. This is a big, big challenge that we've been dealing with, with many importers now really since March when a lot more HTS numbers came into play. I expect that there's going to be more information, especially with this huge influx. Customs might give more guidance. I don't know. We'll see. But they put a lot of their guidance on FAQ pages and it is out there. I have links here if you want to look at that. So this topic generates probably the most questions that our team fields. So hopefully, this overview helps answer some of the main ones we get. I need to take a breath. Feel like I just told you guys way too much info. So you can replay the video and put that on slow mode and just let my voice sync over you talking about partial values. What a nightmare that would be. Okay. So IEEPA India, this is still being planned. This is still on the books. So this is an additional 25% on top of their reciprocal 25%. So India effectively will be at 50%. That's going to start August 27. The #1 question I get for that -- for this is why is the transit exemption so strange? So if you look at this, you need to be on the boat by August 27 and to the U.S. by September 17. I think whoever wrote this either has no idea how freight moves from India to the U.S. or the transit exemption is not practically meant to be used. So good luck getting your stuff here from India, but we will be applying this as we can. There were not a ton of exemptions, really just the stuff under 232 investigations and then the standard ones like informational materials and humanitarian aid. Keep an eye on this one, especially if you import from India. I think this was one that they really tried to use as leverage to finish the trade deal, so it will be interesting to see what comes together here in the next week. And just for fun, we included our lovely chart of duties. I know many of you guys say you have this printed at your desk, which I can't imagine a better place to put it. I hope it's in a frame. So once again, you start at the top and you work your way down. And this shows you what duties you're going to actually end up paying. This is not the order of the broker that I have to apply the duties, but that's where we're at. So the top is your base duty rate. Then you're going to be adding on top of that antidumping, countervailing, Section 201, 301 and IEEPA fentanyl for China and Hong Kong. Once you get to the bottom, you're going to work your way from left to right. So for these new steel and aluminum HS numbers, even if you're on that list but we start at the left, auto and auto parts always win. So if you pay any money or you pay money on auto and auto parts, you get to stop, okay? It doesn't matter if you're on subsequent list. You're stopping at auto, auto parts. If you're not there and you're on a steel, aluminum, copper list, you assess that and you see, is there anything I need to pay here? And as I said, packaging, unfortunately, is included. So if you're there and you have something, you're going to pay that. But then you do, if you look at the notes, you're willing to pick up the remaining value with reciprocal or fentanyl, depending on which one it is. So you need to look at those notes very closely. If you don't have steel, aluminum or copper, then you just keep moving across, okay? So we'll keep updating this as new trade remedies are coming out because especially with the 232 cases, we expect this kind of elaborate prioritization order based on what we've seen so far. Okay, Brenda, I think I've reached ultimate fun, giving them all the info about HTS, numbers for steel and aluminum. So I'll turn it over to you for what's on the horizon.

Stephanie, my head is about to explode. But thanks for the overview. We wanted to spend just a little bit of time, as we often do, as if you didn't have enough to remember about what has already taken place just to make sure that you're kind of keeping an eye on what could be coming at you in the next couple of weeks and months. So the first thing that we want you to be sure you're paying attention to are the ongoing Section 232 investigations. Remember, these are the ones that are run by the Department of Commerce and focus on the national security aspect of this industry for the United States. We also, though, just for fun, added a couple more. So it's not just the 232, it is also the IEEPA tariffs for Brazil. Stephanie already touched on that, but those tariff rates are going up significantly at the end of August and specifically are used by the President to address some judicial behavior in Brazil that he's not happy with. We also have seen IEEPA use for India, again, by the President to address behavior by India, namely purchasing oil coming from Russia. This is to put a little more pressure on Russia, probably as part of the Ukraine conflict negotiations. We also have a couple of 301 investigations that are underway. Again, remember, these are run by USTR. There is a good page on the 301 investigations that they share kind of the current status and the documents associated. But we have open investigations on semiconductors coming from China as well as a new one that was initiated on Brazil's trade practices, and that was initiated in July. The opportunity for comments did close on the 18th of August, but there will be a public hearing in early September. So just keep those on your radar screen. They are still looking at things like timber and heavy trucks and critical minerals and aviation and drones and polysilicon. So there's a pretty long list. We do expect to -- and we've been hearing this now for a little while, we do expect to get the impact or the results of the pharmaceutical and the semiconductor investigations in the fairly near future. The President has promised that now for a couple of weeks. We think it's going to be a doozy. So let's go on and look at our next slide, Samantha. So Stephanie has already mentioned that we are seeing several major changes in the small package or low-value entry environment. So we all kind of got used to fairly significant change when the shutdown really of the de minimis option for shipments coming from China and Hong Kong that was shut down in May of 2025. We are now going to see that policy approach taken by the administration on all low-value packages coming into the United States. That will be effective on the 29th of August. And it means that all low-value packages must file either an informal or formal entry that -- and they may require an importation bond even for informal entries, and importers are responsible for paying all the duties, taxes and fees that are associated with that particular package. So if you are doing a lot of de minimis entries currently, you need to think about your solution and what you're going to do with those entries, who are going to file the informal or formal entry. If you are bringing things in by international mail, and this is probably a fairly small subset, but the government has figured out a way to collect the entry information as well as the duty owed on postal shipments. Basically, that will be $80. This is a fee of $80 per package from countries that have reciprocal tariffs less than 16%. It will be $160 per package from countries with tariffs between 16% and 25%. And any countries that have tariffs over 25% will be paying $200 per postal package for the next 6 months. After that, it's going to be the standard duty rates. The other big change that if you rely on the international mail environment, you should be aware of, is that the Universal Postal Union which, as you may know, is the organization that sets the standards for global international mail movements, those new regulations are scheduled to take effect on September 1 of this year. And it means that everyone that is shipping out a postal package must declare or must include a 6-digit tariff code on the customs declaration. The countries have the opportunity to require more, but this would be a significant change if you are providing or if you are using mail systems to move your goods. So please be aware of that and make sure you're making alternate arrangements. All right. Let's go on and talk about the Section 301 investigation into China's engagement in the maritime logistics and shipbuilding sectors. Many of you know because we talked about it a couple of months ago, that there is a new fee for visits by ships that are Chinese built, owned or operated. And that includes foreign car carriers as well as just regular vessels. There is still an ongoing investigation on the Chinese manufacturer of containers and port or cargo handling equipment. There's an interesting aspect to that investigation, and they are looking at Chinese-owned manufacturers, not just in China, but anywhere in the world. And so that will be a very interesting application of U.S. tariff authority when it comes out because it really shifts that question of what is the origin of the goods. It will be a hard one to administer and a hard one to enforce, but it is something that the administration is exploring. We are seeing a lot of conversation about the application of the new vessel fee. CBP has not yet issued guidance. They will actually be the collecting agency. They have not yet issued guidance, but these fees do begin on October 14. So stay tuned. All right. And the other thing that we wanted to cover, moving on, Ms. Samantha, is what is the state of play on the legal issues surrounding the IEEPA tariffs. Again, we talked to you last month about the finding by the Court of International Trade, which happened at the end of May, which was basically that the President's use of the International Emergency Economic Powers Act was not lawful. And in fact, the CIT mandated that those tariffs essentially go away. However, based on some additional legal activity, those tariffs are remaining in effect during the government's appeal to the full Court of Appeals for the Federal Circuit. That case was heard at the end of July by the full court, which is a little unusual, which indicates how significant a case this is. A decision has not been made yet, but many legal experts expect a decision from the CAFC by the end of August, and we're getting fairly close now, or early September. Those legal experts also expect that this case will go directly to the Supreme Court, by whichever side loses. It's not clear yet that the Supreme Court will actually accept that case. But if they do, there are a number of very significant legal issues that are under discussion as part of this legal case. And the expectation is that the Supreme Court will not be able to make a decision if they hear the case at all until towards the end of their next term, which would be July -- sorry, would be June 2026. An expedited process is possible but unlikely. So we are still going to be on the edge of our seats now for another couple of months. With that, I think I am -- oh, one more. All right. So what happens during all these legal machinations and how can we help you plan? If the IEEPA tariffs are found not to be authorized by the statute, we expect and, in fact, are already seeing signs that the U.S. government is looking for alternatives to using the IEEPA tariffs, the IEEPA provisions to apply tariffs. The two, in particular, that are -- would be new, not just an expansion of the 301 and 232 investigations would be the Section 122 and Section 338 statutory authority. 122 allows the President to implement tariffs for balance of payments issues for -- of up to 15%, which now kind of seems like a drop in the bucket for up to 150 days. So it's a kind of a temporary measure. But the other one, Section 338, which has never been used before, is fairly broad, and it allows the President to implement tariffs of up to 50% if there is a finding that a particular country has discriminatory practices against United States trade. There is no time limit on that. And as I said, those tariffs are up to 15%. So that's pretty significant and something else to keep an eye on. We also believe that if our trade partners, who are watching this legal activity very closely, do see that the IEEPA tariffs are disallowed, they are likely to stick to their negotiated framework agreements. They know that there are alternatives for the President to use. They know that the President hates retaliation, and they know that these negotiations are -- take a lot of time and effort. So they're not going to want to start things rolling again if they can possibly avoid it. So that's our best take on what would happen if the IEEPA tariffs are struck down. But again, as I said earlier, it's unlikely to happen until sometime next summer, if not later. And with that, I'm going to turn it over to our expert, Ted Henderson.

Thank you kindly, Brenda. Just before I launch into my material, I do want to pause and go back and just our favorite topic it feels like today, the steel and aluminum derivatives that relate to what we've been calling packaging. I know some of our team has been frantically trying to answer a number of these questions as they fly by. Please understand, this is not a blanket Section 232 tariff on all steel and aluminum and/or copper packaging "cans" or whatever that may be that goods are in. There are specific HTS numbers that are identified in the most recent announcement from the government. If your goods are not listed on that HTS number, then you're not going to be subject to the -- what we're calling the packaging tariff, if you will, on steel and aluminum. So please keep that in mind that the government has issued specific HTS numbers for the steel and aluminum derivatives. And even with the current expansion, we follow that list of HTS numbers and nothing more. Will we see more? Yes, it's highly likely that more domestic or other entities will ask for more -- an expansion of those lists next quarter. But for now, we follow the lists that are issued by the government. All righty. So let's revisit something for a second that we talked about last -- 2 weeks ago in our last webinar. If you joined the webinar 2 weeks ago, you'll remember this slide, hopefully. We talked about the things that are driving us to really have a deeper understanding of the full value chain of a discrete good in our supply chain. So historically, we've only really cared about the seller of the goods, the country of origin where the finished goods came from. And in some case, for those of us involved in the textile world, we had to worry about our manufacturer. But thanks to some recent legislation, some other trends. By the way, we see the government agencies are acting. It's now becoming really increasingly important that we understand the full bill of material of the goods that we import on any different time. So I'll just start real quickly with the box on the left side. Really when U.S. Customs Border Protection started enforcing the forced labor laws and then when the Uyghur Forced Labor Prevention Act went into effect, it suddenly became very important that we had to understand if a finished good that we were importing had some connection to the Xinjiang Uyghur Autonomous Region or people associated with it, somehow associated with forced labor. So it wasn't just enough to say, "Hey, I'm importing my shirts from Vietnam. I have a cut, make, sew operation there." You actually have to go back and I figure out if somehow the cotton that went into that shirt was attached to the Xinjiang Uyghur Autonomous Region region or something along that line. So that was really a thing we started to see come up a couple of years ago. We also saw changes in the interpretation of antidumping, countervailing duty cases where it became interesting that you had to understand if the inputs to your finished product might have come from a third country and the fact they came from a third country, that changed the antidumping, countervailing duty rate that your goods might be subject to. So again, your cabinet might have been made in Vietnam, but did the drawers come from China? Were there other components that went into this? And you had to understand that for certain antidumping, countervailing duty cases. For those of us who have been involved in free trade agreements, particularly USMCA or NAFTA in the past, we cared about regional value content. We had to understand how much work was being done in a certain country, for example, either Mexico, Canada, U.S. to make sure the goods qualified and understood the value that was associated there. Then under Section 232, it really -- as we were looking both the full and the partial of the derivatives, we had to understand about -- and we've just spent a lot of time talking about it again today, if our -- we're importing whip cream, where did that can come from? And what's the value of that can and the actual aluminum, steel that's involved in that can. So again, another instance of us having to dig in. And then the thing that's hanging out there is this understanding of what we did talk about this last time of how the Trump administration is -- has a new interpretation of transshipment, i.e., that there are inputs coming in from third country, making a new article and would that mean a transshipment tariff might apply to those goods. We have no firm, clear definition from the administration on what they're thinking of in that transshipment idea. But again, to me, it kind of feels like a regional value content idea. You're going to need to understand the inputs and components for your finished goods because that may impact whether or not you have a transshipment reciprocal tariff as opposed to the reciprocal tariff that would just apply to those goods. The bottom line, as we said previously, we're having to dig deeper into our value chains. For those individual goods, make sure we have the necessary documentation to support our import declarations for the classification, valuation, origin, all those things we've always cared about for the larger good, the finished good, but we also have to care about the inputs in that value chain of those goods. That's part of our reasonable care that we are obligated to do as importers. But I do want to be clear that CBP, U.S. Customs Border Protection, now has more access than ever to data and tools, which really make it possible for them to get a view of your value chain and really understand to validate your import declaration. So we thought it might be worthwhile to just kind of give you a primer of what customs brokers do and how we put things together and then how customs looks at the declaration that we file when we represent you in front of the government. So customs brokers, in many ways, are data aggregators. If you can see on the column on the left side of this slide, you can look at the 3 major areas that data comes from in order for us as a customs broker to create an import declaration. We look at the transactional data associated with your shipment, the commercial invoice, the packing list, maybe the PO. We also have to look at the conveyance data, either the ship or the aircraft or the truck, whatever, we need that information to report to the government as well. And then reference data. Many of you provide us parts databases. You provide us your free trade agreement information, license determinations, important things about partner government agencies, whether or not FDA might be impacted, things like that. So we take all of that data and we stack it together. We take those 3 LEGO blocks and create a customs declaration according to the requirements of a given country. And by and large, it's fairly consistent around the globe as to what people ask for, what different governments ask for. It's the key things for the government agency to make decisions about whether you're paying the right amount of duty, whether your goods should be admitted into the country, things along that line. Now on the right side, historically, and I can say this certainly as a former customs officer here in the United States, the government was really able to validate that declaration on a pretty limited dataset, where the custom service was looking at manifest cargo data, the historical data they had in their databases about a specific importer. They looked at industry compliance trends, looked at scanned documents as opposed to paper documents as things moved forward. But there just wasn't a lot for a government agency to really look at and tear apart a declaration. It was really a document-based validation of that declaration and Customs Border Protection or the old U.S. Customs service, whatever, would validate that entry with that really limited restricted range of real-time data sources. You need to understand that's changed in the current environment. So let's talk about how things look now as we look at what we're calling a data-validated declaration. By and large, the information on the left is consistent. We're still taking the same data sources, pulling that into the finished customs declaration, submitting that to customs. That's an electronic submission. By and large, here in the United States, 99% probably of the declarations that are submitted are electronic here in the U.S. And the data that we submit electronically is initially really validated electronically by Customs computers, FDA computers, things like that as well. Do understand, CBP officers definitely do get involved in that early targeting and review and analysis as necessary. But much of what is being done on that initial release decision, again, is running through a computer validation and as the declaration is done. That being said, there's a second point of review and validation that goes on after release. And in the U.S., as you know, you can get your goods released immediately, you pay your duties later. And in that process, that entry summary document that's associated with your declaration, which encompasses a fair amount of value, all the things of valuable data, the things we just talked about, that really is the document and the data that customs is reviewing. If you're not aware of this, U.S. Customs and Border Protection has signed several agreements to third-party tech providers to -- initially, they signed them to support their enforcement efforts around forced labor. It was an effort to try to get deeper into understanding how goods float around the world, maybe understanding data points of how cotton might be shipped from China to Vietnam or other countries. So that would allow CBP officers to do some investigative work and potentially take a look at your individual declaration about an article and see if there might be a connection to forced labor, and that would justify detention of your shipment. They've expanded the use of those tools to a much broader use across their entire review process. So they're using AI, machine learning. They're using third-party providers of data. Those third-party providers are providing them billions of data points about how things move around the globe and specifically identifying sellers, buyers, components, things that are probably associated to something in your bill of material somewhere down in the second or third tier. They also -- CBP has access to product mapping and have a view to how individual companies' value chains actually work, not the overall supply chain, but again, the value chain for certain products. They're using isotopic testing as part of that as well. And if you think about it, they also have access to data on your company website. Your company website has all sorts of interesting information about who you're selling to, maybe who you're buying from, you're talking about where your factories are located, things along that line. So somebody can also click through your website to see more information than they previously could have had in the past. We really want to emphasize this that it is imperative for you to understand that CBP and other partner government agencies have really made a huge leap in the last few years in their ability to validate not just that customs declaration data, but also look for a wider range of irregularities in import patterns, specific shipments, and they are much more efficient in exercising their enforcement responsibility. It just -- it's really important for you to understand, in the current environment, CBP is in a full enforcement posture and trade facilitation that those of us who were in the industry 10, 15 years ago, that's gone by the wayside. The pendulum has swung. It always does, enforcement, facilitation, enforcement. We're back to full enforcement, and the government has many more tools than they used to have and have an ability to more efficiently and more effectively analyze the import declarations that are submitted by your customs broker. As evidence of that, we want to bring forward some recent data that CBP has published and things they're saying. This was a statement that the new CBP Commissioner made just the other day as they were releasing information about some investigations. Again, this is -- remember, the CBP Commissioner is a political appointee. So he is obviously going to follow the direction of the President and the interest of the President, and we are very much concerned about, obviously, the trade remedy tariffs and managing a trade environment that protects the U.S. supply chain, if you will. So let's take a look at some of those things we want to call out based on recent announcements. First, we've seen, obviously, a large increase in the data or the -- I'm sorry, the duties that have been picked up by the government in the sense of the steel and aluminum duties, the things along that line, we see a huge increase in that. We did see a little bit of a shrinkage in the Section 301 duties. We think that's likely just due to shifts in trade and how things work. We don't have it on this slide, but again, talking about what Commissioner Scott, his announcement on the 15th of August. He pointed out that CBP has uncovered more than $400 million in duty evasion due to investigations under the Enforce and Protect Act since President Trump's inauguration. So from January to August, they've already found that there are instances of people doing duty evasion, i.e., transshipment, trying to claim the wrong country of origin to avoid antidumping, countervailing duties or trade remedy tariffs. We've also seen interestingly a decrease in audit numbers. So Customs does full-blown audits on companies regularly and various types of audits. Even though there are fewer audits, the revenue collected from those audits has increased. So again, they're getting better at targeting and using the tools that are available to them. The final thing also is penalty cases. We've really seen a declining number in those, but the actual liquidated damages and the collections that came from those have increased. So they're getting better. The CBP are getting better at some of their recovery rates. Another thing I want to call out, not on this slide, is Customs announced the net revenue that they've recovered during entry summary reviews. So I just got through talking about the idea that after release, CBP does a review of entry summaries to see if there are anomalies, problems, whatever. For fiscal year 2025 to date, so that's October through July for these numbers, based on entry summary reviews, CBP has collected an additional $25.6 billion, a total of $25.6 billion versus $667 million during fiscal year 2024. So again, they're getting better at their targeting. Of course, yes, we are paying more duties, thanks to all the trade remedy tariffs, but they are getting better and more effective at collecting the duties that they are obligated to do under the law. So we'll finish up with taking a look at bond sufficiency statistics. And this is something that's important for you to think about this. Most of us know this, in order to be an importer in the United States, you must post a bond from a surety company, that's really the guarantee to the government that somebody will cover your duty payment if you don't. It's no different than any other bond that's out there. The idea is the government is releasing your goods prior to payment of duty. So they want some security in place to understand that they will be made whole or close to whole in the obligation for the duty. So you post a bond and the bond value is established on your historical rate of imports, what you're thinking of in the future years. Customs is just kind of running an ongoing analysis of your import behavior, the total value of your imports, and they're trying to figure out if your bond is sufficient. If you look at these statistics over the years, we saw a big spike in 2019, and that was Trump 1.0 when we were seeing all the Section 301 tariffs for China and a little bit of 232 action on steel and aluminum, a few other things. If you look at 2025 so far year-to-date, we've already -- CBP has already issued over 4,000 bond insufficiency letters. So that is a letter to an individual company saying, we do not -- we, CBP, do not believe your bond is sufficient to cover the level of duty based on the value of your imports. You need to go get a new bond. And you need to act on that if you get that letter. So we expect the numbers for 2025 will probably parallel 2019. So this is really important. I'm stating the obvious, we all know this. We're paying -- there's a significant increase of duties that you're having to pay. But that means that you do need to be aware of what's going on with your bond. If we manage your bond at Expeditors, we certainly work with you to make you aware of those situations in advance. But if you are one of our customers and you got this letter and you're not sure how to do it, please reach out to your local Expeditors person quickly so that you can maintain your current status on duty payment. All right. Let's close down with a couple of key takeaways, please. They're fairly consistent with things that we've talked about in the past. One of the things that I do want to call out to you is it is important to be very much aware of the things we've talked about today because they're related to the payment of duties and tariffs. You need to understand classification, valuation, country of origin, things along that line. But don't forget about CBP's overall trade mission and enforcement mission. If you didn't see this, the Department of Homeland Security just released their annual update to the forced labor strategy report associated with the Uyghur Forced Labor Prevention Act. They've added 5 additional sectors related to forced labor enforcement. So that's caustic soda, copper, jujubes, lithium and steel. Note, aluminum was already one of the areas they were looking at for forced labor. So now we've added copper and steel. So CBP is looking at copper, steel imports, not only from a duty perspective to make sure you're paying the right tariffs, they're now going to be looking a little more carefully to make sure there's no connection to forced labor. So unfortunately, the scrutiny only increases across the board, and that is Customs will continue to maintain that scrutiny as it goes. We do try to point out a couple of areas where you can engage with government and make comments. This time, there's really nothing related to trade remedy tariffs. The Section 232 conversations have closed, things along that line. But there are a couple of areas to keep in mind. One of them is related to the annual review that's done about counterfeiting and piracy in certain countries. If you are concerned about your intellectual property and things along that, that's an area for you to point out to the government where you think certain countries are not making the right stance against counterfeit and piracy. And then also, it's a notice for a public hearing coming up for China's compliance with the WTO commitments. There's an opportunity to have written comments in for that as well. So please take a look at the 2 Federal Register notices if you are interested. So outside of that, as always, we have received accreditation for this. For those of you who are U.S. Customs brokers, this is part of your -- this will help you meet your continuing education requirements. And if you are part of the NCBFAA's Educational Institute's Certified Customs Specialist Program, this qualifies as well. So we can pause for a moment. I will revert to Stephanie or Brenda. Are there a couple of key things that we have seen in the questions that we want to highlight in our last couple of minutes here?

No, just a lot -- still a lot of questions on steel and aluminum for documentation, best ways to solicit that information from your suppliers. I'll say a couple of different things about this that I've seen because as we've mentioned, a lot of importers have been living in this space prior to March 2025, but especially in 2025. So it really depends on the amount that you're going through, how many suppliers, how many parts. I have seen importers doing -- really trying to do some cool tech stuff in terms of using AI to read spec sheets to pull out. But ultimately, it seems that you still need to go back to your suppliers. Luckily, as a whole, a lot of the world is understanding that they're going to need to start providing this information. You can get it printed on your invoices. We are getting it via spreadsheets. There's different ways to accommodate it. But a big thing that we know happens when big changes happens is it just takes a long time to get everything rolling, especially when we have such a short period of time to actually get ready. As far as documentation, as I said on that slide, Customs has been less than specific on what is required. So this is really you understanding what your -- how conservative or risky per se your company is and then making sure that you're doing a reasonable care. It's just like providing documentation for anything else for an FTA claim or for your valuation or whatever it might be. Think through how you do that, and then I would extend that over. We ourselves have not made a template, but I do know different industry groups are circulating templates and trying to create more consistency in the space. So that's something we'll think about. But I think right now, it's still a bit of a gray area. Brenda, do you want to comment on that?

I was going to say, a lot of times when Customs is quiet, they expect you to do things the standard way. So your standard approach to value, your standard approach to classification, currently your standard approach to origin. So a lot of times, you're reading the tea leaves, but that's what their expectation is. The other thing I wanted to touch on because we got a couple of questions was text for the negotiated agreements that the administration has been announcing is generally not available. The only one we've seen is for the U.K. The rest of them are considered framework agreements. They're very high level and further details would have to be negotiated. My guess is that it only after those further negotiations that we will see any kind of text.

Thank you. Ted, any final thoughts from you?

No, we're at the clock. So Samantha, do you want to -- I'm the third base coach saying, "Send us home, we're ready. Go on."

Absolutely. Okay, Samantha, final words.

As always, you all did a great job. Thank you, everyone, for joining us. Just a reminder, we will send out the survey in about an hour to 2 hours. You will receive it via email from myself. And we just appreciate your feedback. It may seem like the same questions, but we always want to get your input on how we did and what we can do better. And then once you complete that, you will get the landing page where you can find all the materials. So we appreciate you all joining us today.

Thank you, everyone.

Bye, everybody.

Thank you.

Take care, please.