Tariffs in 2026: from tariff management to tariff intelligence

Tariffs have moved from a temporary shock to a structural feature of doing international business. The EU-US framework has moved into implementation with a fifteen per cent ceiling on most EU exports to the US, but the headline does not tell the whole story: steel and aluminium are treated differently, product-specific tariffs and exemptions keep evolving, and the US has strengthened customs enforcement with the most consequential executive order in years. Meanwhile, the EU has moved CBAM into its definitive phase, launched record numbers of anti-dumping and anti-subsidy investigations, and reserved the anti-coercion instrument (the "trade bazooka") as a potential response tool.

At the third ICC Netherlands Digital Business Lunch on 28 August, Marhijn Visser, Deputy Director of International Affairs at VNO-NCW and MKB-Nederland, and Khalid Abdullah, attorney and EMEA Knowledge Lead at KPMG Meijburg & Co, joined moderator Tom Scott for a practical conversation on what it means for Dutch business and what companies should be doing about it.

A moving target

The main change over the summer, Visser said, is not a single policy but the constant motion between them. "In every boardroom, the question is: what’s the next strike?" The Turnberry deal, which sets the fifteen per cent US tariff ceiling, has been implemented, and does give European companies more predictability. But Section 301 measures are being layered on top of it, with the American administration turning to those legal grounds after the Supreme Court struck down others. New developments have followed between the US and Canada. The picture is not one of stability. It is one of a moving target.

Where the headline number is misleading

For a Dutch company reading that its tariff is now fifteen per cent, that number can be seriously misleading, said Abdullah. "The tariff rate on paper and the tariff cost in practice are two different things." He walked through the four places where the gap opens up.

The first is classification. The HS code determines which rate applies, and the difference between one code and another can be the difference between fifteen per cent and fifty per cent. Abdullah described a recent case in the steel sector where a client had been paying the full Section 232 tariff. A review of the technical specification of the product and its precise classification showed that the product fell outside the scope of the steel tariffs. A single reclassification exercise removed a fifty per cent duty entirely.

The second is origin. New Section 301 forced-labour tariffs cover around sixty economies, with rates that depend on the country of origin. The production process determines origin, and origin determines the rate.

The third and fourth, discussed later in the session, are customs valuation and supply chain structure. Together, these four determine what a company actually pays.

Start with mapping

Asked what a Dutch company should do first thing Monday morning, both speakers gave the same answer. "Mapping," said Visser. "Pull your customs data. Look at the top twenty import lines by duty cost. What are you paying?" said Abdullah.

The reason is that few companies actually know their exposure. Most can quote a headline duty rate. Very few can tell you their landed cost per product, per route, per current tariff regime. Mapping is a data exercise: take the top product lines by import value, and for each one, identify the classification, the country of origin, and the applicable tariff layers.

Visser added that the mapping exercise is useful well beyond tariffs, feeding into resilience planning, due diligence and ESG. It is worth doing for an SME as much as for a multinational. The EU Commission’s Access to Markets tool and the Dutch Enterprise Agency’s resources are both free.

Even for small and medium-sized businesses, Abdullah’s threshold is instructive. "If your US annual import duty bill exceeds around one hundred thousand euros, a focused review of classification or valuation will almost certainly pay for itself." In sectors where the effective rate has increased significantly, such as steel, aluminium and pharmaceuticals, the return on a review can be substantial even below that threshold. "The question is not how large you are, but how exposed you are."

The levers

Once exposure is known, several levers become available. The quick wins Abdullah highlighted are classification review and the duty-relief mechanisms that many Dutch companies underuse: free trade zones and inward-processing arrangements. These instruments are not new, but companies were rarely faced with the duty levels that would make them worth the effort. That has changed.

The lever Abdullah returned to most emphatically was customs valuation. Traditionally, multinationals used their transfer-pricing mechanisms to optimise corporate income tax and treated customs as marginal. With higher duties, that is no longer sustainable. A lump-sum transfer price often bundles non-dutiable elements into the invoice.

"I was working with a client importing heavy industrial machinery," said Abdullah. "It was large equipment that required post-import assembly and installation at the buyer’s premises. They invoiced a lump sum, and customs duties were calculated over that entire amount. We reviewed the transaction, and it became clear that the post-import assembly service was separately identifiable and should be excluded from the customs value. We split it out of the invoice, rearranged the contractual terms in line with WTO valuation rules, and we were able to reduce their tariff burden by fifty to sixty per cent."

Supply chain diversification is another lever, and one where Visser saw both opportunity and complexity. The EU has recently concluded free trade agreements with Indonesia, India and Mercosur. The Vietnam FTA has been in place for eight years and has become a real sourcing alternative. But diversification is not a free lunch. "If you shift sourcing from one country to another, you might solve one tariff problem but create another," Abdullah said. Different origin rules, different preference regimes, different documentation requirements. A tariff impact assessment should precede any sourcing decision.

Where the line sits

The US enforcement landscape has hardened materially. In summer 2026, Abdullah noted, the Trump administration issued an executive order to strengthen customs enforcement, "the most consequential piece in US customs enforcement in years." Getting the line right has never been more important.

"It all comes down to substance," said Abdullah. If a classification position is defensible on its technical merits, the company is on the right side. If an origin determination is supported by genuine production processes and follows the applicable rules, the company is on the right side. It becomes risky where a company creates an artificial structure that does not reflect the underlying economic reality. His practical rule: tariff positions must be defensible in an audit. Any Head of Trade should be comfortable explaining the rationale to a customs inspector.

The road ahead

Both speakers converged on the view that tariffs are now a permanent variable. "Tariffs will be a permanent variable, and the landscape will change significantly," said Abdullah. "The companies that will thrive are the ones that build tariff intelligence into their operating model. The time of the wait-and-see approach is already over."

The image he reached for: "The time to build your roof is when the sun is shining. At this time, the sun is shining, but the clouds are gathering."

For Visser, the single largest shift in the next six months will not be in the White House but in Brussels. The day before the session, the Scientific Council of the Netherlands (WRR) published a report highly critical of China’s trade practices, calling out dumping, subsidies and currency manipulation. Similar shifts are visible in France and Germany. Visser expects the European Commission to take formal action against China within the next six to twelve months. That could include the anti-coercion instrument, the same trade bazooka Brussels has so far kept in reserve. The main shift, he said, will be Europe’s position on China.

The parallel Visser drew was to Canada. Ottawa has now accepted that it will be hurt by American trade policy. Europe faces the same question. Is it willing to accept the pain that would come with a firmer position on Beijing?

What Dutch business should do now

Asked to close with one action for Monday morning, both speakers converged. Marhijn Visser: map your exposure. Khalid Abdullah: pull the customs data, look at the top twenty import lines by duty cost, and know what you are paying. And avoid the temptation to be too optimistic in mitigation. The line between avoidance and optimisation is narrower than it looks.

Next Digital Business Lunch

The conversation continues on Friday 11 September, when Ridvan Taçi (Customs Software Alliance) and Jochem Sprenger (FENEX) turn to the EU Customs Reform: the Single Window, the Customs Data Hub, and what Rotterdam and Dutch forwarders should have in place for the first Single Window deadline on 1 October.

The Digital Business Lunch is a monthly online series discussing the issues that move international trade, covering subjects from tariffs and customs reform to AI in trade compliance, sustainability and IFRS.

For more information about upcoming Digital Business Lunches: iccwbo.nl or our LinkedIn page.