The reactive tariff pattern is back. Most companies still aren't ready.

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The pattern is repeating. The infrastructure gap didn't close.

Front-loading is spiking again, and so are whistleblower-driven customs fraud cases, both signs of the reactive pattern I flagged in last year's tariff report. The companies handling this well built resilience before they needed it. Here's what that actually took, and what's still exposed if you didn't.

The wave one warning is playing out again

Our Tariff-optimized supply chain report called the first wave of 2025 front-loading reactive and temporary. It's June 2026, and I'm watching the same pattern show up in the data again.

Trans-Pacific container rates jumped 51 percent in a single week on the Asia to U.S. West Coast lane, and 25 percent on the East Coast lane, as importers rushed goods ahead of new tariffs on 60 countries and a July 7 hearing on further Section 301 duties. The National Retail Federation moved its peak season forecast forward a full month. A fuel surcharge increase set for July gave importers one more reason to ship now instead of later.

That's not a new problem. It's the old one, repeating on schedule.

I've been watching this cycle play out again in real time. I think it's a couple. Certainly it's reactive to start with. But there's also a general fear that something's going to happen to tariffs anyway, and companies are better off doing something now, with what they know, than waiting to see what happens in August or September.

What's different this time is the pace. It used to be that these swings were intermittent. You'd have one, then things would be status quo for a while. Since COVID, it's been boom, boom, boom, boom.

This year added another trigger. The Iran conflict raised fears of disruption, fuel cost spikes and rising war-risk insurance premiums, and that pushed companies to get cargo moving before conditions got worse. It's the same instinct that's been building since COVID. Years of shocks, the pandemic, Red Sea attacks, tariff whiplash, have conditioned importers to front-run risk instead of reacting to it. Call it a just-in-case reflex replacing just-in-time planning.

That shift, more than any single tariff announcement, is what our report's wave one warning was really about. Reactive front-loading works when disruptions are occasional. It stops working when they're constant.

Compliance stopped being a back-office problem

While rates were spiking on the water, a different kind of exposure was building on land. Customs fraud enforcement under the False Claims Act has surged in 2026, and it's no longer employees blowing the whistle. Competitors and customs brokers are increasingly the ones filing claims.

The numbers are hard to ignore. False Claims Act customs fraud recoveries topped 570 million dollars in the first five months of 2026 alone, more than any full prior year, on the way to a reported 918 million dollars recovered total. A single aluminum extrusion misclassification case settled for 549.5 million dollars. The whistleblower in that case is expected to collect roughly 96 million dollars.

I see this as a direct extension of our report's argument that compliance is now a strategic function, not a checkbox. Compliance is a big deal because the penalties are just so high. And even if you hire a forwarder, you're still on the hook. If the customs broker comes back and says, well, that's what they told me it was, it's still your problem.

The financial framing matters here. It is a C-level discussion. It's not just, so what if one order of goods doesn't make it. It's, what happens if that turns into a couple hundred thousand dollar fine? That's a different conversation entirely.

Rules that change constantly compound the risk. Tariff classifications, denied-party lists and de minimis thresholds are all in near-constant flux, and a company shipping the same product under a slightly different quantity or classification can land in a completely different compliance category without realizing it until an audit finds it.

Trade policy is still being rewritten, even where it looked settled

The whiplash isn't limited to tariff rates. In May, Presidents Trump and Xi agreed to suspend a port tax on Chinese-built vessels through November 9 as part of an interim trade deal. In June, Senators Mark Kelly and Elizabeth Warren called on the U.S. Trade Representative to reinstate it anyway, arguing the roughly 3.2 billion dollars a year in fees are needed to protect domestic shipbuilding.

Nobody has resolved that fight. It's a reminder that a policy pause is not the same thing as policy certainty, and companies that build their trade strategy around whatever the current rule happens to be will keep rebuilding it every few months.

What actually separates the companies handling this well

Our report's central finding still holds: companies that built modal flexibility, duty deferral infrastructure and origin diversification in parallel are absorbing this volatility. Everyone relying on a single lever is scrambling again, for the second time in a year.

I keep coming back to sourcing as the clearest example of how long real diversification takes. A few years ago, I worked with a manufacturer that insisted near-shoring was out of reach because nearly all of its vendors were based in China and switching would be too expensive. Fast forward a few years, and they've near-shored something like 35 percent of their supply. What changed? They had to protect themselves. You can't just assume this isn't going to happen again.

That kind of shift doesn't happen in a single tariff cycle. It happens because a company decided, after the last disruption, to build the option before it needed it.

The same logic applies to execution systems. If your software can't adapt, it doesn't matter what you want to do. You can't do it. You need software that has the ability to adapt, and the vision to use AI to help manage those disruptions. That's a direct line back to our report's framing of tariff exposure as an execution problem as much as a trade policy one: an Order Management System (OMS), Warehouse Management System (WMS) or Transportation Management System (TMS) that can't flex when a lane, a classification or a duty rate changes will bottleneck every strategic decision made above it.

Supply chain data quality matters as much as transportation capacity right now, maybe more. Traceability used to be something you dealt with during an occasional audit. It's now a direct driver of landed cost and import eligibility. Moving fast doesn't help if you can't prove where something came from when you get to the port.

That cuts two ways on the software side. You need systems that keep you compliant on the labor and sourcing side, flagging forced labor risk and documenting where materials came from, and you need trade software that uses tariff data systematically instead of relying on someone checking a spreadsheet by hand. The common thread is data. Having the right information at the right time is what turns compliance from a scramble into routine.

The insurance math hasn't changed, only the price of skipping it

Ask me whether resilience actually pays for itself, and I reach for the same comparison every time. It's a fairly low-cost insurance compared to the consequences. Companies went out of business during COVID because they couldn't get what they needed. This can be business-ending if you're not careful.

I've watched that calculation shift among the people who write the checks. Before COVID, CFOs were reluctant to pay 25 percent more for 30 percent of their parts just to have an alternate supplier. Now it doesn't look so bad.

None of this requires predicting the next tariff announcement. It requires building the modal flexibility, compliance infrastructure and sourcing options that make the next announcement a non-event instead of a scramble. Wave one showed which companies had done that work. Wave two is showing it again.

FAQs

Reactive tariff management responds to individual events, like air-freighting a shipment or front-loading orders ahead of a deadline. Structural management means building the contracts, systems and sourcing options that make those responses fast and repeatable, so a company isn't rebuilding its strategy every time policy shifts.

Importers are pulling shipments forward ahead of new tariffs on 60 countries, a Section 301 hearing scheduled for July 7 and an 80 percent jump in fuel surcharges set for July. The Iran conflict added another push, with companies moving cargo before war-risk insurance and fuel costs climbed further. Trans-Pacific rates rose 51 percent in a single week on the West Coast lane as a result.

The False Claims Act lets private individuals sue on behalf of the government and collect a share of any recovery. Large awards, including a roughly 96 million dollar payout in one aluminum case, are drawing competitors and customs brokers into filing claims, not just employees.

I'd argue the financial exposure makes it a C-level issue regardless of which department owns it day to day. A misclassification fine can run into the hundreds of thousands of dollars, which makes it a budget and risk conversation, not only a compliance one.

Country-specific tariffs replaced flat rates, so accurate HTS classification and rules-of-origin documentation now directly affect landed cost, not just compliance risk. Add stricter forced labor requirements, and companies need to trace raw material sourcing all the way back rather than documenting it after the fact.

Start with the execution layer. A TMS, WMS or OMS that can adapt to classification and rate changes—paired with clean country-of-origin and sourcing data—is what makes modal flexibility, deferral strategies and sourcing changes actually executable, rather than theoretical.

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