The launch of the CAPE (Consolidated Administration and Processing of Entries) system by U.S. Customs and Border Protection marks a significant opportunity for importers to recover duties previously paid under IEEPA tariffs that were later ruled invalid by the U.S. Supreme Court. By enabling consolidated refund claims and streamlining the process through the ACE portal, this program reduces administrative burden and accelerates reimbursement. For importers, especially small businesses that directly paid these tariffs, this development is highly relevant because it provides a time-sensitive pathway to reclaim costs, improve cash flow, and correct past overpayments in a changing tariff environment.
Topics: Contracts & Subcontracts Administration, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Material Management & Accounting System (MMAS), Manufacturing Operations Consulting
Government contractors should be aware of a proposed FAR rule implementing FY 2023 NDAA Section 5949 that will prohibit the use of certain covered semiconductor products and services in federal procurements by December 23, 2027. The rule introduces new certification, disclosure, and supply chain review requirements that may significantly impact sourcing, compliance, and contract performance.
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Material Management & Accounting System (MMAS), Commercial Item Determination, Manufacturing Operations Consulting
The United States Supreme Court has ruled that the International Emergency Economic Powers Act does not authorize presidential tariffs, effectively invalidating prior IEEPA-based duties. This decision creates uncertainty around potential refunds and shifts attention to new tariff measures now in effect. Importers and trade compliance teams must reassess duty exposure, documentation practices, and forward-looking trade strategies in a rapidly changing regulatory environment.
Topics: Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Material Management & Accounting System (MMAS), Estimating System Compliance, Manufacturing Operations Consulting
On Sunday, December 7, 2025, Congress put out a compromise version of the 2026 National Defense Authorization Act (NDAA). There is a lot in this version, but I wanted to bring to your attention the exciting possible changes to the Cost Accounting Standards (CAS).
Topics: Accounting System Compliance, Contracts & Subcontracts Administration, Government Regulations, Export & Import, Cost Accounting Standards (CAS)
The U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) has finalized a significant set of amendments to the International Traffic in Arms Regulations (ITAR), effective September 15, 2025, which expand the U.S. Munitions List (USML) and introduce new definitions and a licensing exemption. These changes mark the first time in years that DDTC has expanded the USML’s coverage more than it has reduced it. The final rule amends 15 of the 21 USML categories, representing a substantial increase in the number of controlled items.
Topics: Contracts & Subcontracts Administration, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Material Management & Accounting System (MMAS), Manufacturing Operations Consulting
History of Tariffs
While import tariffs may seem unfamiliar due to historically low rates in recent decades, they have long played a significant role in U.S. economic policy-serving purposes such as revenue generation, industry support, and protectionism. Historically, high tariffs have often coincided with periods of economic and political instability, whereas lower tariffs have typically supported international engagement and economic growth. Since World War II and the creation of GATT and the WTO, the U.S. has generally maintained lower average tariff rates.
Topics: Contracts & Subcontracts Administration, Government Regulations, Export & Import, Material Management & Accounting System (MMAS), Manufacturing Operations Consulting
President Trump issued several executive orders addressing tariffs. American First Trade Policy dated January 20, 2025 and Modifying Reciprocal Tariff Rates to Reflect Trading Partner Retaliation and Alignment dated April 9, 2025. In addition, he has also issued a 90-day pause to some countries and is planning to reduce tariffs on certain industries such as US auto tariffs (see Amendments to Adjusting Imports of Automobiles and Automobile Parts into the United States dated April 29, 2025). It is clear that tariffs are impacting the supply chain and government contractors.
Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Federal Acquisition Regulation (FAR), Manufacturing Operations Consulting
Well one of the endless numbers of administratively burdensome requirements the Federal Government places on your contracts may just be the silver bullet you need. Review your contracts and look for FAR 52.225-8, Duty-Free Entry, and DFARS 252.225-7013, Duty-Free Entry.
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Federal Acquisition Regulation (FAR)
Are you Ready for the July 1st Implementation Date?
The new United States-Mexico-Canada Agreement (USMCA) goes into effect on July 1, 2020. Are you ready?
Topics: Export & Import
Do you import and export? Does your company use imported components in your manufactured goods? Has your company been affected by the Section 301 Tariffs on Chinese imports?
Topics: Export & Import
