CBP Collected $195 Billion in Duties in FY2025. Is Your Supply Chain Ready for What Comes Next?

That number did not appear from nowhere. It is the output of a tariff regime that has been building since 2018, accelerating through 2025, and that shows no structural sign of reversal. The four blogs preceding this one traced what that regime means at the material level — NdFeB, battery graphite, silicon steel, UFLPA forced labour compliance — each a different mechanism, each reaching the same supply chain nodes. Blog 5 is about the enforcement infrastructure that makes all of it consequential, and the one legal provision that separates the companies who acted early from the ones who did not.

The structural problem is not unique to China. Any material originating in a country subject to elevated tariffs — whether through anti-dumping measures, executive trade actions, or bilateral trade disputes — creates the same hidden liability. The enforcement infrastructure described below applies to all of it.

How $195 Billion Happened

The trajectory is not a spike. It is a staircase.

FY2018: approximately $41B — the year Section 301 Lists 1 and 2 were introduced, targeting $34B and $16B of Chinese imports respectively. FY2019: approximately $71B — Lists 3 and 4 added, a 73% year-on-year increase as the full Section 301 regime reached operating scale. FY2020 through FY2022: $74B–$98B as the regime stabilised. FY2023 and FY2024: $77B–$80B — the pre-IEEPA baseline, with Section 301 and Section 232 active but no new major instrument added.

Then FY2025: $195B. IEEPA executive orders stacked on top of existing Section 301 and Section 232 rates. The same supply chain, the same import volumes, a dramatically higher effective rate on Chinese-origin and steel and aluminum content. The $195B is not the result of more trade — it is the result of higher rates on existing trade flows. The enforcement machine did not grow. The tariff stack did.

This matters for how OEMs should read their own exposure. The import volumes in their programmes did not change. The effective duty rate on the Chinese-origin materials inside those imports did. Every company that had undocumented origin in their material stack in FY2024 has a larger undocumented liability in FY2025 — at the same volumes, from the same suppliers, on the same BOM positions that were never traced.

What CBP Did With the Money

The $195B collection figure is the revenue outcome. The enforcement activity that generated it is the operational context every trade compliance team needs to understand.

In March 2025 alone, CBP conducted 71 focused assessments — targeted audits of specific importers' entry records, origin declarations, and tariff classification. Those 71 assessments identified $310M in previously uncollected revenue in a single month. That is $4.37M per assessment, on average, from a sample of companies that CBP had already identified as audit targets.

Focused assessments do not arrive randomly. CBP's Automated Targeting System scores every entry against risk indicators — origin patterns, HS code classifications, declared values, country of origin declarations relative to known supply chain structures. When the system flags an importer, the focused assessment follows. The companies receiving those March 2025 assessments had, in most cases, been filing entries for years on the assumption that their origin declarations were sufficient. CBP's data infrastructure had reached a different conclusion.

UFLPA detention activity tells the same story from a different angle. 6,636 shipments detained in H1 FY2025. 86% automotive. 61% denied entry. 6.5% released into US trade. The enforcement posture is not passive and it is not random. It is targeted, data-driven, and operating at a scale that makes the question of detection not if but when.

The CF-28 and What It Actually Means

CBP's CF-28 — Request for Information — is the instrument that arrives before a formal enforcement action. It is not a routine enquiry. It arrives when CBP has already identified a concern with a specific entry: an origin declaration that does not match trade data, an HS classification that implies a lower rate than the declared goods appear to warrant, a country of origin that conflicts with known production route information.

The CF-28 gives the importer 30 days to produce documentation supporting the entry as filed. For an OEM that has never traced its material stack below the supplier layer, that 30-day window is not enough time to build the documentation from scratch. Legal costs mount. The evidence that emerges is incomplete. The entry that was filed on the basis of what the system knew — German origin, Vietnamese assembly, Georgian manufacture — is now being examined against what CBP's trade monitoring data suggests about the materials inside those products.

The CF-29 — Notice of Action — follows when CBP's review concludes. At that point, the importer's options narrow sharply. The question is no longer whether to disclose. It is how to respond to a determination that has already been made.

The Prior Disclosure Window

19 CFR 162.74 — CBP's prior disclosure provision — is the legal instrument that separates the companies who acted early from those who did not. The provision allows an importer to voluntarily disclose a potential customs violation before CBP has initiated a formal investigation. The effect is significant: the maximum penalty under 19 U.S.C. § 1592(c) for gross negligence — up to 4× unpaid duties — is reduced to interest on the underpaid duties only.

Material	Annual Exposure
Battery graphite (93.5%)	$42.075M
NdFeB (71%)	$31.95M
Silicon steel (50%)	$5.625M
Combined annual	$79.65M

Maximum penalty at 4× gross negligence: $318.6M on one year of underpaid duties. On a three-year look-back — within CBP's standard statute of limitations — the ceiling reaches $955.8M before interest.

Prior disclosure reduces that ceiling to interest on $79.65M per year. The difference between filing before investigation and responding after CF-29 is, at this exposure level, measured in hundreds of millions of dollars.

The prior disclosure window closes the moment CBP issues a CF-28 on the relevant entries. Once the enquiry is open, the provision is unavailable. The OEM who has run ECC's proactive CF-28 simulation — building the documentation package before anything ships — has the factual basis for a prior disclosure narrative already assembled. The OEM who has not has no such option once the investigation begins.

The Proactive CF-28 Simulation

ECC's proactive CF-28 simulation inverts the standard compliance posture. Rather than waiting for CBP to identify a concern and respond within 30 days, the simulation runs the CF-28 response workflow against the current BOM and pending shipments before anything ships.

Three modes: Pre-shipment scan — run before goods depart origin. Every material node in the shipment is scored against its current origin state. ATTESTED nodes: documentation exists, origin confirmed, rate applied with confidence. INTELLIGENCE CONFIRMED nodes: third-party trade monitoring platform records support the origin declaration but supplier attestation is pending. CONSERVATIVE nodes: origin undocumented, worst-case rate applied, attestation action required before shipment or prior disclosure filed. Periodic compliance drill — monthly or quarterly, tracking origin state as the supply chain evolves. New suppliers, new processing routes, new Entity List additions — all flow into the material graph and update the scoring automatically. Reactive response — when an actual CF-28 arrives. The simulation output becomes the response package. Every node that has been attested or intelligence-confirmed is documented. Every conservative node is identified with its resolution action and timeline. The 30-day window becomes manageable because the work was already done.

The output of all three modes is the same: a readiness score per node, an audit trail that documents when the company became aware of potential underpayment, and the factual basis for a prior disclosure filing if one is warranted.

What the Series Has Established

Five blogs. Five angles on the same structural problem.

The enforcement machine is not waiting. The prior disclosure window is open now. ECC builds the documentation that makes proactive action possible — before CBP's targeting system makes it necessary.