Question 1

What is the BIS 50% Rule (Affiliates Rule)?

Accepted Answer

The BIS 50% Rule is a new U.S. export control requirement that extends Entity List and MEU List restrictions to any company that is 50% or more owned (directly or indirectly) by one or more listed entities. This includes subsidiaries, holding companies, offshore structures, and multi-layer corporate ownership.

Question 2

When will the BIS 50% Rule be fully enforced?

Accepted Answer

The rule becomes fully enforceable in November 2026, but early preparation is essential due to the difficulty of uncovering hidden ownership relationships.

Question 3

What are the risks of BIS 50% Rule non-compliance?

Accepted Answer

Organizations face export privilege loss, regulatory penalties, and significant shipment delays. Many companies now search for BIS 50% Rule penalties and export control enforcement as enforcement tightens.

Question 4

How does Assent support BIS 50% Rule compliance?

Accepted Answer

Assent’s Enhanced Entity Screening integrates AI-powered analysis, ownership tracing, and expert review to:Identify complex indirect ownership chainsUncover offshore or layered affiliatesConsolidate beneficial ownership data across jurisdictionsApply OFAC and BIS style 50% ownership logicProduce defensible evidence for audits and licensing decisions

Question 5

What is Section 232 and why does it matter for steel, aluminum, and copper imports?

Accepted Answer

Section 232 of the U.S. Trade Expansion Act allows the president to impose tariffs if imports threaten national security. Since 2018, this has led to significant tariffs on steel and aluminum, and in 2025, copper was added. Importers must now provide detailed supply chain data (such as country of smelt, cast, melt, and pour) to avoid duties up to 200%.

Question 6

How can importers stay compliant with Section 232 reporting requirements?

Accepted Answer

Importers should:Collect mill test certificates, certificates of analysis, or supplier attestationsEngage suppliers early to ensure smelt/melt data is availableUse trade compliance software to trace metals back to the smelterWork with compliance experts to interpret CBP updates and avoid costly penalties

Question 7

What are the risks of not complying with Section 232 tariff requirements?

Accepted Answer

If importers cannot prove the country of smelt, cast, melt, or pour, U.S. CBP may assume the material originated from a restricted country (such as Russia). This can trigger a 200% duty, shipment delays, or even having goods stopped at the border. Lack of documentation creates significant financial and operational risks.

Question 8

What does country of origin (COO) mean?

Accepted Answer

COO indicates where a product was produced or manufactured. All imports require clear marking of COO, ensuring transparency and accountability for goods crossing borders. It’s the basis for everything from standard customs clearance packets to tariff analysis to compliance with regulations such as the Uyghur Forced Labor Prevention Act (UFLPA). On top of that, a part’s COO determines whether the product or part is eligible for preferential treatment under certain trade agreements.

Question 9

Why is accurate country of origin data important?

Accepted Answer

Accurate country of origin data helps avoid shipment delays, unexpected tariffs, and fines. For some materials like steel or aluminum, importers must also report the country of smelt, pour, or cast — not just where the product was assembled.

Question 10

How can manufacturers stay compliant with country of origin rules?

Accepted Answer

To meet country of origin compliance requirements, manufacturers need traceable, up-to-date part-level data. Using automated trade compliance software helps collect certificates of origin, assign the correct HS/HTS codes, and keep up with changing trade regulations.

Question 11

Why are tariffs a major concern for manufacturers in 2025?

Accepted Answer

Tariffs have become one of the biggest obstacles to manufacturing growth. According to the National Association of Manufacturers, 76% of companies cited trade uncertainty as their top concern in early 2025: a 20% jump from late 2024.At the same time, manufacturers expect raw material costs to rise more than 5%, largely due to shifting global tariffs and supply chain disruptions. These new trade barriers are forcing companies to reassess sourcing strategies, supplier dependencies, and cost structures. Uncertainty around import duties, Section 232 tariffs, and global trade agreements means manufacturers need accurate supply chain visibility to forecast costs and stay competitive.

Question 12

How can supply chain data help manufacturers lower tariff costs and qualify for tariff exclusions?

Accepted Answer

With accurate country of origin (COO) and harmonized tariff schedule (HTS) data, manufacturers can apply for tariff exclusions, qualify for free trade agreements (FTAs), and even reduce customs duties. But approvals only go to manufacturers with verifiable COO and HTS data to prove eligibility. The substantial transformation rule also allows tariff reductions when parts from multiple countries are assembled into a product that undergoes significant change but this is only valid with traceable supply chain data.

Question 13

How does Assent help manufacturers manage tariffs and trade compliance more effectively?

Accepted Answer

Assent helps manufacturers navigate complex tariff requirements and trade regulations through a combination of expert guidance and AI-driven technology. Our platform automates the collection of COO and HTS data, improves supply chain visibility, and ensures compliance with trade regulations, including Section 232, Dodd-Frank Section 1502, and global FTAs.With the largest supply chain data network in the industry, Assent gives you:Accurate COO and HTS data managementAutomated supplier outreach and educationGuidance from trade compliance expertsProven processes for securing tariff exclusions and cost savings

Question 14

What are the phases of CBAM implementation?

Accepted Answer

The Carbon Border Adjustment Mechanism (CBAM) is being implemented in two phases: a transitional phase and a permanent phase.The CBAM transitional phase runs from October 1, 2023 to December 31, 2025 and requires EU importers to report the embedded greenhouse gas emissions of in-scope goods on a quarterly basis, without purchasing CBAM certificates.The CBAM permanent phase begins on January 1, 2026. From this point forward, importers must submit annual emissions declarations and purchase CBAM certificates to cover a growing share of embedded emissions, with full financial coverage required by 2034.

Question 15

What is the Carbon Border Adjustment Mechanism (CBAM)?

Accepted Answer

The Carbon Border Adjustment Mechanism (CBAM) is an EU regulation that places a carbon price on certain imported goods based on their embedded emissions.CBAM is designed to prevent carbon leakage by ensuring imported products face a comparable carbon cost to goods produced within the EU under the EU Emissions Trading System (EU ETS). The regulation currently applies to carbon-intensive goods such as iron and steel, aluminum, cement, fertilizers, electricity, and hydrogen, and requires importers to calculate and report emissions using defined EU methodologies.

Question 16

What is a CBAM certificate?

Accepted Answer

A CBAM certificate is a tradable unit that represents one tonne of CO₂-equivalent emissions embedded in imported goods subject to the Carbon Border Adjustment Mechanism.During the CBAM permanent phase, EU importers must purchase and surrender CBAM certificates annually to account for the emissions associated with their imports. Certificate prices are linked to the average EU ETS carbon price, and the number of certificates required may be reduced if a carbon price was already paid in the country of origin. Accurate supplier emissions data helps minimize certificate costs.

The Year in Compliance: Key Takeaways & What Comes Next

The BIS 50% Rule (Affiliates Rule): Get Prepared Now

How to Prepare for Section 232 Tariffs

Country of Origin 101: What You Need to Know to Stay Compliant

Stay Ahead of Global Regulatory Shifts: What’s in Store for Q3 2025 Compliance

The Trade Compliance Playbook: Lower Your Risk, Boost Your Savings

The Trade Compliance Playbook: Lower Your Risk, Boost Your Savings

Tariffs & Your Business: Forging Resilience Out of Uncertainty

The Year in Compliance: Key Takeaways & What Comes Next

Data-Driven Global Trade: Tactics to Sidestep Tariffs, Slash Costs & Stay Flexible

Tariffs, Trade Restrictions & Supplier Data: The Key to Staying Ahead

Benchmarking Assent: A Comparative Look at Supply Chain Sustainability Management Software

RCEP: World’s Largest Free Trade Agreement Has Global Implications

UK Regulatory Uncertainty: What We Know About Brexit & REACH

USMCA: What Changed From NAFTA & What It Means for Industries

USMCA and Forced Labor: Requirements for Companies

Tag: Trade Compliance

The Year in Compliance: Key Takeaways & What Comes Next

The BIS 50% Rule (Affiliates Rule): Get Prepared Now

How to Prepare for Section 232 Tariffs

Country of Origin 101: What You Need to Know to Stay Compliant

Stay Ahead of Global Regulatory Shifts: What’s in Store for Q3 2025 Compliance

The Trade Compliance Playbook: Lower Your Risk, Boost Your Savings

The Trade Compliance Playbook: Lower Your Risk, Boost Your Savings

Tariffs & Your Business: Forging Resilience Out of Uncertainty

The Year in Compliance: Key Takeaways & What Comes Next

Data-Driven Global Trade: Tactics to Sidestep Tariffs, Slash Costs & Stay Flexible

Tariffs, Trade Restrictions & Supplier Data: The Key to Staying Ahead

Benchmarking Assent: A Comparative Look at Supply Chain Sustainability Management Software

RCEP: World’s Largest Free Trade Agreement Has Global Implications

UK Regulatory Uncertainty: What We Know About Brexit & REACH

USMCA: What Changed From NAFTA & What It Means for Industries

USMCA and Forced Labor: Requirements for Companies

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