[Cindy’s Version] Dancing With Our Hands Tied

How Data Gaps Are Reshaping Trade Enforcement Host: Cindy Allen Published: August 22, 2025 Length: ~20 minutes Presented by: Global Training Center In this week’s episode, Cindy Allen — the Taylor Swift of Trade — takes on one of her favorite Reputation-era tracks, Dancing With Our Hands Tied, to unpack the unseen world of data flows between trade and U.S. Customs and Border Protection (CBP). From new Section 232 tariffs to the end of de minimis and the shift to consolidated entries, Cindy explains why brokers, importers, and CBP alike may feel like they’re “dancing with their hands tied” as vital data disappears from the targeting system. This episode goes behind the scenes of CBP’s systems — ACE, AMS, ABI, ISF, ACAS — and explains why the current rules are creating blind spots, compliance headaches, and risks for global traders. 🧠 What You’ll Learn in This Episode: 🏭 Section 232 Update – 400+ new tariff numbers added, including unexpected HTS lines tied to packaging 🚗 EU Trade Deal Rumblings – Automotive tariffs under review, with possible retroactive relief 📦 De Minimis Fallout – Why companies are moving shipments into Foreign Trade Zones and bonded warehouses 🔍 CBP Data Blind Spots – How the move from Type 86 to standard 01 entries reduces consignee-level visibility 🖥️ ACE & Targeting Explained – The difference between manifest-level data vs. entry summary data ✈️ Security vs. Commercial Data – Why legal firewalls prevent CBP from fully merging security filings with trade enforcement 📉 Operational Risks – Why less package-level data means tougher targeting for CBP and bigger compliance risks for e-commerce players 🔑 Key Takeaways: Importers and brokers are grappling with confusion around new 232 tariffs on products where aluminum/steel is incidental. CBP’s targeting system relies heavily on house-level manifest data, and the shift away from Type 86 leaves blind spots. Foreign Trade Zones and bonded warehouses are becoming popular cost-control strategies in the post-de minimis era. Understanding how ACE, AMS, ABI, and targeting systems interact is critical for compliance and risk management. Traders may want to consider voluntary data sharing to maintain smoother targeting outcomes, even if not required. 📌 Resources & Mentions: Section 232 Federal Register update on tariffs EU automotive tariff negotiations CBP guidance on Foreign Trade Zones and bonded warehouses Background on ACE, AMS, ABI, ISF, and ACAS systems Legal history on security vs. commercial data firewalls post-9/11 About the Host – Cindy Allen Known as the “Taylor Swift of Trade,” Cindy Allen brings clarity, edge, and insight to the week’s most pressing trade developments. With decades of experience, she helps industry professionals make sense of the chaos — with a little pop culture flair.  Cindy is CEO of Trade Force Multiplier  Follow Cindy on LinkedIn: https://www.linkedin.com/in/cindy-allen-a3188210/ Subscribe & Follow: New episodes every Friday Follow us on LinkedIn, LinkedIn (GTC), YouTube, Spotify, or Apple Podcasts Don’t forget to rate, review, and share with your fellow trade geeks! Want to Be on the Show or Have Topic Suggestions? Reach us at [email protected] or DM us on Twitter/X @SimplyTradePod