Good day. This is LIAN GLOBAL LOGIS. If you have personally managed exports to the United States, you have likely wondered why identical products sometimes clear smoothly at the Port of Los Angeles while others are held for days on end. In fact, according to the 2025 fiscal year trade enforcement statistics released by the U.S. Customs and Border Protection (CBP), the number of new investigations under the Enforce and Protect Act (EAPA) related to origin and transshipment rose by double digits year-over-year, and cases of customs holds and penalty assessments on Korean-origin cargo—often citing suspicion of transshipment—continue to be reported regularly. This briefing examines how the strengthened U.S. tariff policy in 2026 creates cascading effects on shipper logistics costs and lead times, and why B2B cargo containing imported raw materials and components has become the primary target.

Three Core Shifts in the 2026 U.S. Tariff Environment

The recent posture of the U.S. Trade Representative (USTR) and CBP extends beyond simple rate increases. Both agencies are moving toward applying "substantive origin" criteria far more rigorously. This means that even if final processing and assembly occur in Korea, if critical raw materials or components originate from high-tariff-rate countries, the shipment may be reclassified as a product of that country rather than Korean-origin.

Container origin inspection at U.S. customs gate As the substantial transformation standard tightens, the fact of "made in Korea" alone no longer suffices for clearance.

Category	Prior Practice (Approximately Pre-2023)	2026 Strengthened Approach
Origin Determination	Tariff Shift basis; primarily documentary review	Substantial Transformation basis; substantive review of value-added and critical components
Transshipment Investigation	Notification-based and post-detection focus	EAPA-based proactive investigation; customs hold at clearance stage
Document Verification	Certificate of Origin (C/O) primary	C/O + BOM + process flow + supply chain traceability documentation package
Penalty for Violation	Duty assessment + limited penalties	Duty assessment + penalties up to a material percentage of cargo value + designation for intensive examination of future shipments

The implication is unambiguous: the fact of "made in Korea" is no longer sufficient on its own, and once a shipper is flagged as a subject of suspicion, customs clearance lead time accumulates with each subsequent export of the same product category.

Why Customs Holds Simultaneously Erode Both Cost and Time

The danger of a hold lies not in the penalty amount itself but in the far greater collateral costs and time losses that follow. Based on actual cases: a precision components manufacturer experienced a 14-day hold on one container shipped to the Port of Los Angeles in the second half of 2025 due to origin investigation. The demurrage, detention, warehouse storage, and buyer liquidated damages (LD) that accumulated during that period alone amounted to 7–9% of the cargo value in additional costs—margin erosion occurred before any duty assessment was even imposed.

Infographic showing cost and time losses from customs holds The hold period itself becomes a larger margin-erosion factor than the duty assessment.

Impact Axis	Short-Term (0–30 Days)	Medium to Long-Term (Quarter or Longer)
Cost	Demurrage, warehouse fees, return freight, legal and customs broker consultation	Duty assessment, penalties (up to material percentage of cargo value), insurance premium increases
Time	Customs hold 10–21 days; supplementary documentation 5–10 days	Designation for intensive examination of all future shipments; average lead-time increase of 7+ days per shipment
Trade Relationship	Buyer delivery delay penalties	U.S. buyer review of alternative suppliers; renegotiation of long-term contracts

Particularly for B2B cargo containing imported raw materials and components, BOM (bill of materials) traceability must be maintained all the way through the supply chain. If documentation tracing back to first-tier suppliers is not organized in advance, the hold period extends proportionally.

Five Operational Risks in Cargo Containing Imported Raw Materials and Components

The patterns that U.S. CBP actually cites as grounds for holds and reclassification are consistent. Shippers should verify the following items in advance using this action checklist.

Concentration of origin in critical components: If the proportion of single high-tariff-rate country components in the BOM exceeds a certain threshold, recognition of substantial transformation becomes difficult. Pre-shipment simulation is essential.
Alignment of HS code with actual manufacturing process: If the declared HS code differs from the actual manufacturing process, EAPA investigation ranks first priority. Secure English-language versions of process flow diagrams and work instructions in advance.
Documentary basis for Certificate of Origin (C/O) issuance: Maintain not merely the C/O itself but an entire package including value-added calculation statements, process descriptions, and supplier declarations.
Supplier change history management: If the supplier for an identical product changed compared to the prior quarter, the probability of CBP issuing an RFI (Request for Information) rises.
Invoice, packing list, and B/L consistency: Quantity, weight, product name, and unit price must be identical across all documents. Unit prices that deviate materially from market rates invite suspicion of undervaluation.

Five risk checkpoints for imported raw material and component cargo BOM, HS code, and unit price consistency form the first gate at customs clearance.

If even one or two of these five elements are misaligned, cargo can be detained at the clearance stage, and shippers flagged once often find themselves automatically enrolled in the intensive examination pool for all future shipments of the same product.

Proactive Response Process: Seven-Day Pre-Shipment Checkpoints

The standard process for blocking origin and documentation risks at the pre-shipment stage is structured as follows. Verification at the local stage in China and other source countries—not merely at the Korean headquarters—is the critical element. If BOM and process documentation are organized at the point of factory release in China, a coherent origin narrative is completed when the product undergoes final assembly and repackaging in Korea before shipment to the United States.

Infographic showing pre-shipment origin documentation verification process Building a consistent origin narrative from the component stage onward is the foundation.

Short-Term and Medium-to-Long-Term Implications

In the short term, the U.S. side updates its product-specific investigation priorities each quarter in 2026, so shippers must monitor whether their principal product categories are included in quarterly EAPA investigation trends. Over the medium to long term, only shippers that diversify supply chains with high single-country dependency and consolidate BOM, process flow, and C/O supporting documentation digitally will maintain a stable export channel to the United States.

As U.S. tariff and origin regulations grow increasingly complex, what shippers need most is proactive response capability to block risks before they materialize. LIAN GLOBAL LOGIS's differentiated forwarding consulting begins precisely at this point. Because our Korean headquarters customs team and China regional network collaborate to conduct unified verification from the component stage through U.S. port-of-arrival clearance, we recommend designing the most reliable strategy for safe cargo passage and logistics cost optimization with LIAN GLOBAL LOGIS—not merely transportation, but comprehensive risk mitigation and efficiency.