A landed cost is more than a line on an invoice

Dear members,

September has been a month of listening closely to the details behind the numbers. For a small importer, a tariff or a supplier-term change is rarely just one new line on a document. It can affect a price already promised to a customer, the cash needed for the next order, and the time a small team has to spend finding out what is owed.

Our Trade Council has not adopted a standard this month. That matters: we should be clear about the difference between gathering evidence, testing a pattern and deciding on a fix. But the evidence has continued to arrive, and the wider Assembly has moved through two important milestones. On 8 September, the Fair Play Council’s FP-001 issue passed the five-part pattern test. On 24 September, the consultation on the Cashflow Council’s CF-001 draft closed after 362 comments. Those are different issues from trade, but they show the process at work: reports are tested, proposals are opened to challenge, and comments are counted before a decision is made.

What the numbers say

As of 27 September, the Founders Assembly had 1,609 members in 49 countries and had received 4,925 reports from 50 countries. The Trade Council had 194 members across 44 countries and 437 reports from 47 countries. The median amount at stake in trade reports was about US$4,034. In the last 30 days, 114 trade reports were filed.

Of the Trade Council reports, 296 concerned tariffs and 141 concerned supplier terms. The country totals with the most reports were the United States, 80; Canada, 68; Mexico, 24; the United Kingdom and India, 17 each; France, 13; and South Africa and Australia, 12 each. These are not a

measure of which country has the “biggest problem.” They show where members have been able and willing to report so far, and where our evidence base still needs to grow.

The team-size figures are just as important. Forty-seven per cent of Trade Council reports came from businesses with 2–9 team members; 32 per cent from people working alone; 14 per cent from teams of 10–49; and 7 per cent from teams of 50–249. A process that assumes every trader has a legal department, a customs specialist and spare cash to absorb a surprise will not fit much of the experience represented here.

A member’s experience, carefully told

A small importer has agreed a price with a customer and placed an order. Before the goods arrive, a tariff or related charge changes the expected cost. The forwarder provides a total, but the importer cannot readily see which amounts are duties, fees, transport or other charges, or when each became payable. The owner must decide whether to absorb the difference, renegotiate with the customer, or risk delaying the next order.

The key point is not that every charge is avoidable. It is that a business cannot plan around a cost it cannot see clearly and early enough. That is why the Trade Council’s TR-001 work asks for landed-cost transparency from forwarders, and for size-based thresholds, plain-language guidance and phase-ins when new trade rules or tariffs apply. We are looking for changes that help a small trader comply and plan—not exemptions from every obligation, and not a claim that small businesses should be outside the rules.

What we are learning

First, “small” is not a single category. The experience of a person working alone is different from that of a firm with 40 employees. Still, both can be harmed by a sudden requirement with no usable explanation or transition. Size-based design should be practical, clear and proportionate, rather than a blanket assumption about what every business can manage.

Second, transparency is part of predictability. A landed-cost figure is useful only when the components and timing are understandable. Members’ reports about tariffs and supplier terms are distinct, but they can meet in the same cash-flow decision: how much money must be available, and by when?

Third, workable thresholds can focus effort where it matters. The European Parliament’s account of the EU CBAM simplification says a 50-tonne annual mass threshold, applying from 1 January 2026, removes around 90 per cent of importers—mostly SMEs—while keeping about 99 per cent of emissions in scope. That is a relevant case of designing a rule so that administrative effort is better targeted. It does not by itself answer every question about small traders, and we should not treat one instrument as a template that can simply be copied everywhere.

Finally, we need to keep listening beyond the places already most visible in our data. Reports come from 47 countries, while membership spans 44 countries; neither number tells us that every kind of trader is represented equally. More evidence from different routes, business sizes and trading situations will help us distinguish a recurring pattern from a local circumstance.

What comes next

On 29 September, the next wave of CEO seats is scheduled to be proposed. That is a step in the Assembly’s process, not evidence of a response or commitment from any company. The FP-001 consultation is scheduled to run from 13 October to 12 November. The CF-001 adoption ballot is scheduled for 26 October to 9 November. For TR-001, our next task is to keep organizing the evidence and prepare the issue for the same five-part test: Volume, Frequency, Consistency, Spread and Corroboration. We will report clearly when there is a formal milestone to report.

To members who filed reports, checked details, joined conversations or helped make the evidence easier to understand: thank you. In particular, thank you to Rosa in Guadalajara, Amina in Nairobi and Daniel in Toronto for

the care you have brought to this work. Thank you as well to everyone who contributed without seeking recognition. An anonymous report can still make a public pattern clearer.

Notes and sources

Sources

1. European Parliament: CBAM simplification and the 50-tonne threshold