I will gladly join you on this hill.

My point being that the administration is known to take a wide view of what constitutes "national security." The input BIS asks for is pretty trade-standard stuff. I just wonder if some non-trade security risks are identified.

I don't think harm to the domestic industry matters here. The administration might be able to say that having wind turbines is a national security threat because they're killing all the whales, so we have to ban them all.

Until we see something to implement the administration's new view of transshipment, I think CBP is applying the 40% transshipment rate under the traditional definition. (14/fin)

So we have no idea how they want to implement it. Rules of origin are hugely bureaucratic. This is not a simple change. I wrote about some of the complications here: insidetrade.com/daily-news/n...

(13/n)

Now we haven't seen how the administration is going to implement this new idea on transshipment/rules of origin. We haven't seen any announcement or guidance from Customs. I would think that we would have to see at least a Federal Register notice to change the how we look at rules of origin. (12/n)

The U.S. wants this in more of its tariff deals. This from the New York Times this morning: www.nytimes.com/live/2025/08...

(11/n)

This is not the administration's first mention of this. A senior admin official briefed reporters on the U.S.-Indonesia framework and said the same thing. I wrote about it here: insidetrade.com/daily-news/i...

(10/n)

Lutnick is clearly not talking about that here. All sorts of goods have 30% content from a third country. If a textile company imports its yarn to produce a shirt, Lutnick seems to be saying that's transshipment and subject to a higher tariff. (9/n)

The difference between transshipment and, well, the supply chain hinges on "substantial transformation." Commerce defines it as: (8/n)

But he immediately follows that with something else entirely. Now, he says, a good with just 30% content from a third country gets hit with a higher tariff rate. (7/n)

Here we get a basic definition of transshipment. (6/n)

Commerce Sec. Howard Lutnick touched on this during a Fox Biz interview this morning: www.foxbusiness.com/video/637665... (5/n)

There are other, legal types of transshipment, but we're not going to focus on those right now. (4/n)

Transshipment usually refers to when companies are trying to mask goods' true country of origin. Country A sends widgets to Country B where they're repackaged with a 'Made in B' label and shipped to the U.S. This is done when Country B faces lower U.S. tariffs than Country A. (3/n)