October letter from the Chair of the Trade Council

Dear members,

October brought an important step for the Trade Council: on 20 October, TR-001 passed the five-part pattern test. That is not a verdict on any one company or a promise that a particular rule will change. It means the evidence meets our Assembly’s threshold for moving from documenting a recurring problem to drafting a practical fix.

On 22 October, we wrote to members with the result and our drafting plan. We are now working on the Small Importer Standard: size-based thresholds, plain-language guidance and a phase-in when new trade rules or tariffs apply, alongside clearer landed-cost information from freight forwarders. We will keep the draft focused on what small traders need to understand and act on—not on adding another layer of paperwork.

What the numbers show

As of 27 October, Reseated had 1,786 members in 49 countries and had received 5,436 reports from 50 countries. The Trade Council has 214 members in 46 countries and 538 reports from 50 countries. That gap between members’ home countries and the reach of their reports matters: trade costs and terms can affect a small business across borders, not just where it is based.

Within our 538 Trade Council reports, 368 concern tariffs and 170 supplier terms. The median amount at stake is about US$4,112. There were 101 reports in the last 30 days alone. The teams represented are mostly small: 47% have 2–9 people, 33% are just one person, 13% have 10–49, and 6% have 50–249. Those percentages are rounded.

The largest numbers of reports came from the United States (92), Canada (80), Mexico (28), the United Kingdom (20), India (19), France (15), South Africa (13) and Australia (13). These are not rankings of hardship. They show where reports have reached us so far—and where we still need more voices.

A member experience, in brief

Imagine a two-person importer preparing a small order for a regular customer. The freight estimate arrives first, but the full cost does not. A tariff or related charge becomes clear later, after the importer has committed to the order and the customer expects a price. The importer must then choose between absorbing a cost that may erase the margin or reopening a conversation that risks the sale.

That is why “landed cost transparency” is not a technical nicety. For a small team, information that arrives late can make a workable order unworkable. The same principle applies to new trade rules: a threshold, a clear explanation and a transition period can determine whether a small trader can comply in time. The EU’s CBAM simplification, including its 50-tonne annual mass threshold from 1 January 2026, is one case of a size-based approach intended to remove many importers from the system while keeping most emissions in scope.¹

What we learned this month

First, repetition is visible in the combined evidence even when each individual report describes a different shipment, supplier or rule. The five-part test—Volume, Frequency, Consistency, Spread and Corroboration—helps us distinguish a recurring practice from a single difficult experience.

Second, the scale of the amount at stake does not tell the whole story. A median of about US$4,112 can be a major disruption for a small business with limited cash and little room to pass an unexpected cost on. The reports also tell us that tariff questions and supplier terms are connected in

practice: both can leave the trader making commitments before the full cost or timing is clear.

Third, the answer has to be usable. A standard that only a customs specialist can interpret will not meet the need members have described. Our draft must make the expectations understandable to a busy owner, and it must recognize differences in business size and capacity.

What is moving across the Assembly

The Trade Council’s work is part of a wider process. The Fair Play Council’s CF-001 adoption ballot opened on 26 October and is scheduled to close on 9 November. The Fair Play consultation on FP-001, which opened on 13 October, continues through 12 November. The Assembly’s Q3 report and First Eight Months report also give members a wider view of the work and participation to date. Each council has its own subject, but the shared sequence remains reports, a pattern test, a draft, public consultation, a ballot and letters to the people able to adopt a standard.

What comes next

• Through the coming weeks, the Trade Council will draft TR-001 using the certified pattern-test result and the members’ evidence. We have not set a publication date for the draft; we will share one when the text is ready for meaningful review.

• Fair Play members can take part in the CF-001 ballot through 9 November. The FP-001 consultation remains open through 12 November.

• On 17 November, Wave 2 letters are scheduled to be sent to the proposed mid-sized platform CEO seats. That is a separate Assembly track, but it is another part of the same commitment: adopted standards should be put directly to those who can act on them.

Thank you to everyone who kept a record, answered a question or helped another member make sense of a difficult cost. My thanks this month go in particular to Amina in Nairobi, Jorge in Mexico City, Priya in Mumbai and

Daniel in Toronto for contributing their time and care to the Council’s work. Reports are most useful when they are specific; they become more powerful when members help us see the pattern together.

Notes and sources

Sources

1. European Parliament: CBAM simplifications adopted