解读关税影响：评估风险敞口和风险的分步指南

Tariffs are a major force shaping supply chain costsand procurement decisions in 2025. With new rules under Section 232 and Section 301 ofU.S. trade law, the International Emergency EconomicPowers Act (IEEPA), and reciprocal tariffs, the rates areno longer static. They vary by country, spend category,and political climate. But how exactly does an organization evaluate tariffexposure and impact? GEP has created a five-step framework for just that. Itbreaks down the process of understanding, validating,and addressing tariff impacts. It gives procurementand supply chain teams a clear methodology to trackexposure, quantify cost increases, and act, whether itmeans pushing back on a supplier demand, revisitingcountry of origin, coming up with a quick short-termaction plan, or designing long-term mitigation strategies. Enterprises are dealing with supplier price increaserequests, unclear cost deltas, and confusionover applicable tariff rates and their duration, allwhile managing rising compliance risks and auditrequirements. It’s critical for companies to understand how tariffs affectlanded costs, when they can push back on supplierprice increases, and when they need to rethink sourcingaltogether. The steps outlined in this paper are meant to be practicaland repeatable and will give procurement, finance, andsupply chain teams a shared language and toolkit to dealwith an increasingly complex tariff landscape. GEP’s 5-Step Tariff AssessmentFramework This model enables enterprises to isolate tariff-driven cost impacts at the SKU level and equips categorymanagers with actionable data to negotiate, model, and mitigate. Step 01Validate Import Data and Country of Origin The first and most foundational step in managing duty exposure is to validate the country of origin (COO) andthe importer of record (IOR) as errors at this stage will impact the whole tariff assessment process. Country of Origin (COO):It is the country where the product undergoes its most substantial transformation, aprocess that changes the item’s name, character, or intended use. It is not necessarily the last country the goodspassed through. For example, a handbag made of Chinese leather but stitched in Vietnam may be considered ofChinese origin if the transformation does not meet the substantial change threshold defined by customs regulations. Importer of Record (IOR):The IOR is legally responsible for filing customs documentation, ensuring regulatorycompliance, and paying duties and tariffs to U.S. customs. It could be the buyer, a customs broker, or a logisticspartner, depending on shipping and contract terms. Why It Matters •An inaccurate COO can result in incorrect tariff brackets or the loss of preferential treatment under tradeagreements like the United States-Mexico-Canada Agreement (USMCA). •A misassigned or unclear IOR can cause customs clearance delays, misallocated landed costs, financial penaltiesand legal disputes. Key Documentation for COO and IOR Validation Accurate and auditable documentation is essential to support origin classification and confirm tariff responsibilities.These are the two standard documents used across industries: The best practice is to maintain a centralized, validated repository of COO and IOR documents, especially for high-risk categories with volatile sources or complex supply chains. Once the COO and IOR are validated, the next step is to build a clean, defensible input dataset. At this stage, thefocus is twofold: Capture the true product cost at point of export and classify it under the appropriate HTSUS codeto determine tariff. HTSUS Classification: The Code That Drives Cost HTSUS (Harmonized Tariff Schedule of the United States)is a 10-digit product classification system used todetermine applicable duty rates. •Digits 1–6:Global classification under the World Customs Organization’s Harmonized System•Digits 7–10:U.S.-specific refinements to capture value, use, and product specification nuances Sample Code Breakdown: HTSUS 6402.91.80.05 Even subtle product differences (e.g., the presence of a toe cap, or a change in outer material) can change theHTS code and alter the applicable duty rate significantly. Misclassification can trigger penalties or retroactive dutyassessments. Step 02Determine Transaction Value of Goods The U.S. government defines the base value for tariff calculation — referred to as “customs value” — as the totalworth of imported goods up to their entry point into the U.S., in line with international standards and HTS. This valueis typically determined using the transaction value method, which is the actual price paid or payable for the goods,plus additional costs such as freight, insurance, royalties, and assists, up to the port of importation. If the transaction value cannot be used (due to circumstances like related-party sales, consignments, or barter deals),authorities apply alternative methods in a specific hierarchy: transaction value of identical or similar go