[Cindy’s Version] Right Where You Left Me: Is Trade Stuck In The Past? (Podcast)

Same Assumptions, Different World

International trade keeps changing, but many companies are still running on old assumptions. Cindy Allen uses Taylor Swift’s “Right Where You Left Me” to ask whether the trade community is holding onto ideas about tariffs, sourcing, and supply chains that were formed in a very different environment. The challenge isn’t just keeping up with new regulations. It’s recognizing when your strategy needs to change.

Tariffs Are a Tool, Not a Strategy

Cindy sees a role for tariffs in specific national security, health, and supply-chain concerns. However, she questions whether broad tariffs alone can accomplish bigger policy goals. Using pharmaceuticals and metals as examples, she explains why domestic capacity also requires incentives, investment, and long-term planning. In short, ask what problem you’re solving and which combination of tools can solve it.

Check Your Records Before CBP Does

Importer-of-record enforcement is a clear theme this week. Importers should review the information tied to their IOR numbers, including CBP Form 5106, and make sure it’s accurate and current. Refunds bring their own challenges. Importers without the necessary ACE refund information in place can hit operational roadblocks, especially as CBP moves through CAPE Phase 3.

Watch the Water, the Rails, and the Roads

Meanwhile, logistics remain exposed. Cindy covers ocean freight congestion, uncertainty in global shipping, and Golden Week pressures on the horizon. She also touches on the Jones Act, rail export manifests, and trucking challenges at the southern border. As a result, continued supply chain monitoring isn’t optional.

Ready to Go Deeper?

Want to strengthen your approach to a changing trade environment? Explore GTC’s course offerings on Importing Procedures, Importing 201, and Trade Action Strategies to build a stronger foundation for compliance, sourcing, and long-term planning.

Transcript

Machne Operated

Cindy Allen – Trade Force Mult (00:03.288)
Hello, today is Friday, September 18th, 2026. I’m Cindy Allen, also known as the Taylor Swift of Trade. I am CEO of Trade Force Multiplier, which is a global trade consultancy service, handling everything from those pesky questions from CBP to corporate strategy and investment, understanding where you need to invest and what to move your business forward. Also, how to handle all of these tariff actions that are taking place and how it’s going to impact your company.

Welcome to Simply Trade Cindy’s Version, where I base an international trade update on a Taylor Swift song. This is brought to you in association with Global Training Center. Today’s song is Right Where You Left Me, off of the Evermore album. I’ll get to that in a moment, but first, what happened in international trade this week? So no big things happened, but lots of little things happened today.

CBP actually updated the Court of International Trade on AIPA refunds via CAPE. two hundred and seventy-two thousand declarations. of those 191,000 were accepted for about $132 billion in potential refunds. Not all of those refunds have been processed though.

About 22,000, a little more of the refunds totaling 1.7 billion, actually have been transmitted to Treasury without any ACH refund information, which means that the importers of those 1.7 billion dollars isn’t are not going to get their money back until they go into ACE and establish an ACE refund portal. Now, for those of you who are caught in the ACE

Help desk hell, as I’ll call it, know that this is actually taking months, if not several months, to get resolved in trying to get those ACH refunds accounts established. The ACE help desk does remain backed up in their processing as millions of importers suddenly decided they needed an ACE account that didn’t have it before. So this it continues to be an issue.

Cindy Allen – Trade Force Mult (02:09.018)
CAPE phase three will also go live after being delayed. They have indicated this is for those actions that have been filed with the court for finally liquidated entries that have that court challenge. Those are expected to be filed by legal counsel in phase three of CAPE. Also, the Jones Act.

was the waiver was extended to November fifteenth, twenty twenty six. If you recall, the Jones Act is actually a requirement that the carriers transacting trade within the United States, within territories of the United States or within the United States actually be US owned.

This has been seen as a challenge for some of the oil transactions that have happened between Alaska and the US, which does require a US vessel and also in the Gulf Coast from some of our territories in the Caribbean to the mainland and back. So that has been extended to November 15th, 2026. If you recall, there are two camps.

One that say this really should be done away with and the capitalism, the free market really needs to reign here. And there’s another that says we do need US ships in our in our repertoire in the US. And this is one of the ways to ensure that we have US owned ships that continue to transact international trade. today.

Today, September 18th, CBP will begin voiding importers of record numbers when the information on file via a customs form called 5106 data is incomplete or inaccurate. At the trade cargo security summit C B did indicate that they did eliminate five million IOR numbers without any repercussions or any pebbles being thrown in that pond. So we’ll see once they begin a whole

Cindy Allen – Trade Force Mult (04:08.11)
wholesale effort of avoiding these numbers, how trade is going to be impacted. One of the main concerns there is if your importer of record number is voided, how do you get your goods into the United States? It’s going to have to go into a holding CFS, you’re going to have demerged attention, probably storage. So that’s a big concern. So make sure that the information that you have on file with customs if you’re an importer is accurate. If you’re a customs broker, you may want to review that information

from your clients to make sure that that is accurate. One challenge is there’s really no way to query and get the full record. The only one who sees that is the importer of record in their ACE account. And even then that information can be overridden on a filing of a 7501. So it’s a little bit of a tenuous situation, but just keep an eye on that if you’re an importer, if you’re a customs broker.

get ready to be answering those phone calls and helping those importers navigate the labyrinth of CBP to make sure that they get that number reactivated if they are actually a correct importer of record. Also, we do believe that in those instances, customs is going to require a little bit more information than those six mandatory fields on the 5106. They’re going to want to make sure that that entity is who they say they are and they’ll want proof of that.

On the Hill, the House has declared recess until after the midterm election. So we’ve got a couple of months. the Senate is still in session, but may move to recess in the next couple of weeks. So we aren’t going to see any major legislation coming out in the next couple of months from the Hill, which is maybe a good thing. Let’s all give ourselves a break on some of these actions. effective October 26th, rail export manifests will be required.

Now, CBP has been rolling out export manifests over the past couple of years, air, truck, and now rail is going to have to have an export manifest that is filed. Not expected to be a major issue for the rail carriers because a lot of them file manifests going into other countries. So not a huge deal for the export manifest. And possibly contributing to driver shortages.

Cindy Allen – Trade Force Mult (06:28.628)
On the southern border, especially, the administration announced it’s moving to shut down a hundred and ten driver schools that have failed to require the drivers to know English well enough to be able to take a test. And the administration has indicated that this is a risk, and they’re going to be shutting down those 110 driving schools, mainly in the Southwest, that are actually facilitating getting those drivers certified for truck.

you know, truck operation in the United States. So we all know that the southern border is experiencing a driver shortage due to some of these language concerns, also due to some of the scrutiny by the drivers coming in from Mexico. And many of the drivers are just staying in Mexico doing domestic loads. And that’s created a shortage for a lot of the trucking companies and a lot of the importers who are trying to move their goods from Mexico into the United States.

In other transformation news, ocean freight is beginning to experience congestion in China. This is nothing new. We’re going into the fall, you know, shipping season. Golden Week is coming up in China, the first week in October, which will likely continue to increase congestion. We’re also seeing some congestion on the West Coast with containers waiting to be exported. So

This seems like a more normal shipping peak season that’s happening rather than what we’ve experienced over the past several years since COVID, where no demonstrated peak season has happened in any large-scale effort. So this may be the beginning of that. We’ll continue to to keep an eye on that, let you know if that gets worse over the past next next month or so. speaking of shipping.

Challenges abound globally for ocean shipping. We’ll still have the issues in the Strait of Hormuz. We have some new attacks that are happening. We have issues in the the Suez Canal, we have Red Sea issues with the Houthis performing attacks on vessels. We also know that the US and Iran continue to trade strikes on vessels that are transiting that area, so it’s created a very hazardous environment.

Cindy Allen – Trade Force Mult (08:50.552)
For those shipping through that area. We don’t think it’s impacting the China flow of goods, but definitely overall impacts to goods coming into the country via ocean. With the China US leadership summit that’s going to be happening in the near future, some are predicting that there might be reduced tariffs on Chinese goods.

which may create some issues for some of our other trade partners, we’ll which we’ll see that the tariff rates on China are actually lower than those with some of our very close trading partners. we do see that this agreement between China and the US not to escalate into another tariff war.

is somewhat fragile. So it’s going to be some delicate conversations. And we’ll want to, and the administration and their negotiators will want to ensure that they don’t inflame this while still maintaining some of their objectives to limit some goods, but also free up some of those critical minerals and other exports from China that we continue to need for production in the United States. So everyone is keeping an eye on that.

In Canadian news, Canada proposed being an associate member of the EU and the US administration then threatened heavy tariffs on EU products and proposed possible EU import sanctions, so not allowing some goods from the EU into the US if the EU does move to allow Canada to be an associate member.

Canada and the EU do have an agreement that hasn’t fully been ratified in the EU overall by all of the EU members. We don’t know if that’s going to be impacted by this or what an associate membership into the EU actually looks like. but also very a hot topic in the United States right now with the administration trying to further that discussion with Canada to achieve the results that they want while not allowing other.

Cindy Allen – Trade Force Mult (10:57.804)
other areas of the world to assist them. So an interesting dynamic going on between Canada, the US, and the EU. The WTO will release a report on eight decades of trade and the benefits of it, outlining the economic impact, the elevation of a middle class across the world, the allowance of capitalism across advanced manufacturing capabilities.

but what the report doesn’t do is it doesn’t make specific recommendations. It indicated that the WTO must modernize in its approach and some of the agreements that it has to move forward and be effective, but it stops short of actually outlining how they’re gonna do that. So again, WTO is something that the this administration feels is not really relevant to trade in the United in the United States and globally anymore, that they’ve kind of lost their

Way and become a bureaucratic nightmare to deal with. And this, in my view, is the WTO actually seeing and agreeing with some of those comments and actions. so why did I pick the song that I did right where you left me? I had an interesting question posed to me this week in a forum that I was speaking at, and that is: Do I agree with the tariffs? The the questioner was asking me, he said, you know.

He doesn’t agree with with any tariffs. He believes that trade needs to flow unimpeded without tariff boundaries being put in place or blocks being put in place. And I I really thought that was an interesting question because I do believe that there are some certain circumstances where tariffs can help achieve a goal. And I don’t think it’s the only thing that can achieve that goal. for example.

It’s important that the US has an ability to produce pharmaceuticals. We saw that in the in the COVID times where certain pharmaceuticals were not produced in the United States and we couldn’t get them in fast enough for the people who needed them, which created health crisis even further on top of the COVID crisis that we already had. So I think some capacity in the United States is necessary, especially for those critical pharmaceuticals that keep people alive and healthy.

Cindy Allen – Trade Force Mult (13:20.614)
so I think that that is a good thing, especially in light of shortages across the world. However, tariffs don’t achieve that goal in and of itself. That is a tool that can be used, but there’s a whole set of tools that need to be used in conjunction with that one tool that will entice those pharmaceutical companies to make investments in manufacturing in the United States. same with you know, steel.

And some of the aluminum production, it’s important that the US have the capacity to defend itself. I’m not for war, but if we’re attacked, we do need the ability to defend ourselves here in the United States. So that’s important to know that we can produce tanks and we can produce equipment that is needed to to actually defend ourselves. Outside of that.

I think that there really isn’t a need for tariffs. And these overall broad tariffs like the three ones for forced labor enforcement in another country’s own soil, I think is a reach. And I don’t see the goal that it’s trying to achieve. One of my good friends in the industry always said, What is the goal? What problem are we trying to solve? And are we doing the right thing to to address that? I don’t think tariffs overall

Are the right means to address some of these issues outside of those specific, you know, national security or health and safety issues? and I I think a lot of people have to recognize that we are cannot be caught in a moment of time that is in the past. And that’s really right where you left me: is a song about being caught in a moment of time.

where she thought it was how things were supposed to be. And she feels frozen in that moment in time and can’t get past it. So I think that it’s important to know that we’re in a different moment in time and we do need to get past where where we were even five years ago, you know, 10 years ago, before the first Trump administration to understand things are changing. And regardless of what administration comes in,

Cindy Allen – Trade Force Mult (15:34.925)
I think regardless of whether the midterms produce a different controlling party in Congress, whether House, Senate, or both, I don’t think we’re gonna see large scale changes to the tariff landscape. They may slow down some of the escalation of the changes, the pace of those changes, but I’ve never seen a government where they say, we’re collecting too much money, let’s give some of it back.

Except in in taxes. we’ve seen that for certain segments of the population to achieve other means, but it’s really hard to walk away from billions and billions and billions of dollars of tariff revenue especially in an economically challenging environment. So it’ll be interesting. But I think that, you know, everything that was discussed at the trade cargo security summit, all of the administration actions, all of the CBP enforcement.

really have indicated this is this is the new normal, this is the new environment. And how do you move on from a past stance or point of view? So I think it’s important that we ask ourselves those questions. What am I holding on to? Where am I right where you left me 10 years ago? And where do I need to move on? And the last line in in this Taylor Swift song is you left me no choice but to stay here forever. So I’m gonna encourage you all to make a different choice. Don’t stay there forever.

And let’s live in the here and now and look at these actions apart from the politics of all of it and understand we’re likely gonna be living with this. This is the new trade environment moving forward. We’ll talk to you next week.