Expeditors International of Washington, Inc. (EXPD) Earnings Call Transcript & Summary

Hello, everyone. Thank you for joining us. I'm starting to see our participant numbers steadily climbing there. So it means you all are probably getting your alerts for what's next on your agenda for the day. And we are very glad that part of your schedule is joining us for the U.S. Customs Market update. I don't know? Anybody else feeling like deja vu or Groundhog's Day here because we've definitely done a lot of these. But we are glad you're here for another one. And today, we've got a lot of content to cover. So let's talk about the housekeeping items in case you have not joined us before. [Operator Instructions] All right. Moving on along, we're going to get you guys to people you really want to hear from, which include today, Madeleine Veigel, our Vice President of Customs for the Americas; Brenda Smith, our Global Director of Government Outreach; Ted Henderson, who is our Senior Adviser of Customs; and Stephanie Holloway, our Director of Customs Operations for the Americas. And Stephanie is going to get us started today.

Thank you so much, Samantha. Okay. So let's dive in. Of course, our -- the best slide of the whole show, the disclaimer. We are doing the best we can here. We are going to give you the best information we have. But just know that we are not lawyers. We are just customs brokers, which is a very noble profession. So here we go. I'm going to start us off with tariff and trade developments. We have not been light on those in the last month. In fact, it kind of blew up the whole system. So I'm going to do the best I can to talk about those in a concise and meaningful way. I'm going to cover the ones that were recently implemented and then which are coming soon. Ted is going to talk about tariffs under legal challenges. So of course, now the court system is right in the thick of tariffs, still dealing with IEEPA, and he's going to touch a little bit more on the most recent cases that are popping up for the Section 301 forced labor. Brenda is going to really level set. This will be fun to hear from her about our key trading partners. And what is the status of our relationships with them and what does that maybe look like? And then Madeleine, everyone's favorite topic, enforcement. She'll touch on some CBP enforcement activity, our favorite, the trade fraud enforcement guide that came out in the last couple of weeks, and then really give you some more information about that executive order. So let's dive in. This -- when I was making this slide, it kind of cracked me up because I was like, "Oh, there's actually some space, I guess, for October." So we'll see what is in there. But since we last met, of course, the biggest headline was that Section 122 tariffs expired. So those expired on July 23 and immediately were replaced at 12:01 on July 24 with the forced labor tariffs. So we're going to dive into those a little bit more because that has kind of dominated most of our world. However, at the same time, we've had some Section 232s coming on. We're going to be touching on the Canada Section 338 that were announced and what that might entail for us. And then, of course, we always have this long tail of activity that we need to keep an eye on. So let's get going. Before I talk about all the things that have been going on, I just thought it would be really -- almost said fun. Fun is not the right word. It would be good for all of us just to reset again. And Samantha always reminds us, there's many new people coming into the industry all the time. And we are -- sometimes I listen to a sentence I say, and I think just 2 years ago, I wouldn't have understood what I was trying to get across. So we have the 232s, the 201, the 301s. All of these things, of course, are the legal basis of how the Trump administration is applying tariffs. And this really helps you understand where these are coming from, how durable they are, how long lasting are they are -- how long lasting they are, how long would it take from a case being announced to tariffs potentially coming on? So this is the key, right, to really understanding this is kind of your guide book of how to understand how tariffs might impact your business in the future. This chart is actually from a congressional research service paper. If you don't know who they are, they're a fantastic government group whose job is to do research for Congress people and present these reports in a very easy-to-read fashion. If you have -- if you're new or if you're trying to get people in your organization to understand, this link is a great one to look at. The report, I think, is from April. So not too old, but it really highlights some of the main legal basis in how tariffs can come. So the ones that I'm going to focus on, of course, because actually, we've had all of these in the last month come at us. So you can see here, of course, on 232, 201, and 301, if you look at this line that says agency required to make findings, all of those ones have an agency that's tied to them that have to go do a report, and that's going to be important to know. It's the Section 122 and the 338 that can be very quick, right? There's no report needed. So always understanding that is really important. So what has been happening? I resurrected this list, although I tried to make it look cooler. Brenda informed me my font is too small. So just bear with me here. So on the Section 232, this is listed in order of when these cases were initiated, okay? So you can see here, we've been checking down the list of the 232s. So we have skipped over critical minerals, but pharmaceuticals went live. The first part went live July 31. They officially have closed the commercial aircraft one. And then we just got instructions last Friday, I think, for polysilicon, although it's planned for December 2026. So if you're wondering, in your case, if you have one of these that's going to be highly impactful, you can I see what's happening here. Section 301, this is a little bit more all over the board, but there's a lot open, right? These are all ones that are formally open. If you Google Section 301, open investigations, you'll see the page. They're all there. But we've had 2 of these go live in the last couple of weeks. So we had Brazil and we had the forced labor one. So both of those just days apart. And then Section 201, haven't seen an appearance of tariffs under that for a while. I always say my fun fact is 201 was the original tariffs that came on during Trump 1.0. They were for washing machines and solar cells. So there's your fun fact of the day. It is coming back to life with quartz surface products. That will be middle of August. It's actually a quota. So interesting twist. We haven't seen that in a while. And then just in the last month or 2, they also opened up a Section 201 on lamb meat. So I'm not quite sure the background on the lam meat, but it is out there. Okay. So this is kind of an overall view. Let's look at what got implemented, okay? So I'm going to hit -- usually, we try to go a little deeper on this, but we kind of have to do an overall pass by. And what I'm going to try to hit is what are the key parts that are important because this kind of gives you the outline of how the Trump administration is looking at tariffs. And even if this directly doesn't impact you, you can see the writing on the walls. You can read between the lines to really see the patterns that are emerging. So Section 301 Brazil, this was essentially the -- what do you call it? The repeat of the IEEPA Brazil case. So if you remember for Brazil, there was actually 2 IEEPA cases. There was the IEEPA Reciprocal Tariffs and in IEPA Brazil specific. They stacked on top of each other. When IEPA Brazil came on, they actually opened on the same day, the Section 301 Brazil case. So this started on July 22. It's a 25% rate, which is ironically, the exact same amount as the IEEPA one. They exempted many commodities from Brazil. The list actually was not exactly the same when it went live, but it does stack on top of the forced labor. So very similar patterns as what we saw before with the IEEPA cases, okay? A lot of exemptions on that, by the way, as well. And I'm going to have a slide about exemptions because exemptions are becoming their whole own thing that you have to have a strategy of how you manage them. The big, big headline, of course, for many of us was forced labor. So this was the Section 122 expiring at the end of July 23 and then July 24, right? These were coming in. The other big headline, of course, was that many brokers and software providers had very little time. We had 7 hours to prepare for this. It's a 400-page Federal register notice, a gigantic CSMS. I keep bragging about my team. They did a fantastic job getting that implemented. But this covered 60 economies. And it says economies because it includes the EU. So I think it's 84 individual countries, if I did my math right, don't quote me on that, please. And it came out with a structured duty rate. So there's 10% or 12.5%. But in each of those, there's one that's with the MSN rate, right? That's that old standard duty rate that we used to pay. And then there's another one where it's an all-in rate. So certain countries, really depending on if we had one of the trade agreements signed with them, got grouped into these different buckets. USMCA goods are exempt. And there was actually a pretty broad list of exemptions, and I have some listed there, a lot of them being ones that are already tied to Section 232 cases. So that was a very similar pattern that we saw with IEEPA Reciprocal was if we can exempt it on a 232, they did. Same thing with these, okay? And this can stack on other 301. So in my example with the Brazil, it is both of those coming together. The Brazil stacked with the forced labor, giving you a 37.5% additional duty. The other one we had was Section 232 pharmaceuticals. Of course, the pharmaceutical folks are all over this. But this one was really interesting. We had actually a lot -- we had 120 days' notice. So the original notice came out on -- in April, if I remember right. And the complexity around how to calculate these duties are unmatched. We haven't seen this level yet. It looks at, is it a generic or pharmaceutical? How big is your company? Have you worked out a preferential trade deal, like essentially a pricing agreement with the U.S. government? They call it MFN pricing, which is very confusing to the trade nerds because we know that to mean our Most Favored Nation duty 1 column rates. They're using this to mean that you have worked out a preferential pricing agreement with the U.S. government, but also looks at do you have an onshoring agreement? Are you investing in building a factory in the United States? All of those factors impact your duty rate for pharmaceuticals. This is kind of mind-blowing stuff. Also, if there was a trade deal, those countries got the preferential rate. So these are huge tariffs, by the way. I didn't capture that. There's different tiers, but you can get easily up to 100% tariff on these goods. So this really kind of shows the playbook on how the Trump administration is trying to bring back certain types of manufacturing to the U.S., of which pharmaceuticals is one that they really care about, okay? So that's what we've lived through implementing. And I think most -- 2 of these have been on -- we get instructions on a Thursday night, and we implement on Friday. So we have not been short on activity. The other thing that we're seeing is we've gotten some pre-announcements. So pre-announcement is always a little bit interesting in terms of the lead time that you see. The Trump administration often signals that they're willing to negotiate or maybe the story is not quite done when you have more of a lead time because they're trying to get companies, countries, whoever, to come to the table and figure out ways to make things happen. So these ones are a little bit interesting courts. So once again, this is a Section 201 with a quota. So we have not seen this type of activity for a long time, and it is going to start August 15. It's 25% in quota, 50% once it goes over. So I -- we have just a handful of commodities in the U.S. that still have a quota. But just in case you don't know or can't deduce what it is, it's essentially a certain amount can come into the country at a certain rate. So once that gets filled -- that first amount can come in at 25%. Once that's filled, you can still import, but now you're going to be paying 50% okay? So that just makes watching -- it's just a whole another aspect to pay attention to, watching what's coming in, knowing how full the quota is and using that as part of your tariff strategy is really important. There was a lot of country exemptions, and I have some of those listed there. But if this impacts you, this is something, of course, I'm sure you're paying attention to, and we have more detailed information that we can circulate. The other, I'll say, kind of trade announcement that got a lot of press in the last month was Canada. So it wasn't just Canada. Of course, Canada always causes a lot of noise in the trade scene because they're such a key partner with us. But also, it was because the President used Section 338 for the very first time, okay? So that's almost the bigger headline is, is this now going to be a trade remedy or tool that the administration reaches for often, okay? So we had 30 days, I think, because it got announced mid-July, and it's 50% on covered goods. So I just want to make sure everyone is really level set on what this is. So there's actually 3 actions that were listed, 3 different Section 338. So there was one for autos, for alcoholic beverages, and one for dairy market access. And remember, a 338 -- so I'm going to go back here, a 338 is when you can show that it burdens or discriminates against U.S. commerce, okay? So -- that was not the best choice I made. Okay, here we go. So what they're saying with in this case is that these industries are being discriminated against, okay? The retaliation action, though, and this is the part that's really important, is that they're not just saying that 50% tariffs will be applied to autos or to alcoholic beverages that are being imported from Canada. It's actually a completely different HTS list. So even though it might not feel like this should impact you, you're like, I don't import an auto. I don't import an alcoholic beverage. It doesn't matter. The HTS numbers that are being targeted for these tariffs tied to each of these individual 338s are not one for one, okay? So it's -- if you import from Canada, if you have products with the country of origin of Canada, you really need to be looking at these lists. There are some exclusions, but it's not -- as it's written right now, it's not going to exclude or give you a break for USMCA, which is a pretty big thing for products from Canada. I don't have to tell you if you know that. The bigger story, as I said, of course, is that the Trump administration hasn't used 338 yet. There's not ever been a legal precedent of using that. So that would be very interesting if this actually happens, okay? And I do think that 30-day lead time that we've been given or that we're seeing is really potentially trying to get Canada to come and negotiate directly with the government. We'll see how that works out. But I do think you need to scenario plan for this because this is going to be very impactful for many of you. The last one I'll say is polysilicon. I'm not going to go too in the weeds. We actually have a pretty good lead time on this. It doesn't go until December. But this is, once again, you can see the playbook of what the administration is trying to do with tariffs. This is its own thing. So it's going to be looking at pricing, how much did you sell it for if you didn't sell it for a certain amount, there's almost an ad valorem and a specific rate duty that are going to be added together. So it's a very, very complex duty scheme. It's going to be very complex for us, both as a software provider and as a broker to actually accommodate this in our systems. So we will see on this one. I think that customs might have some additional data elements they want because, A, we do have the longer lead time, and this is going to be very difficult to actually implement well and make sure that you can prove and calculate the duty correct. So lots there. Last thing I'll say before I hand it over to Ted is what do you make of all of this? This is so much, right? It's -- I won't say it felt like we've ever really had a break in 2026. But we kind of hit our groove in the last couple of weeks have really just feel like they've really amped up. So the thing I do want to hit on is exemptions. Exemptions are great, but they are becoming so difficult to understand and make sure that you can use them correctly. So the one thing I'll say is just make sure that you're not assuming because you're on one list that you're on another list. All of these lists are different. Kelsey and our teams is absolutely brilliant. She always says the civil aircraft. She's like the civil aircraft list, trade agreement to trade agreement can be very different. So you just have to double check everything. Also, we're seeing so many more expectations around end use, contract timing, origin, pricing, manufacturer location to use exemptions, okay? So you can't just assume that it's a one-size fits all, and it's no longer just I have this HTS in country, do I have an exemption? It is a very complex process to understand. A lot of it, too, might require documentation that you need from your suppliers. So my last point is, especially with these, making sure you pull in the right teams early on because sometimes you're going to need to get completely different things from finance or procurement or, of course, having your legal teams look at it. I think right now that the companies who are doing really well are really leveraging industry association and trade groups well as they also are trying to pull this apart and understand sometimes with not much clarity how to interpret this and how to read it and then how do you actually build this into your tariff strategy. So that's my soapbox on exemptions. It's really tough out there. So make sure that you're doing this well and that you have a good strategy in place. Okay, Ted. I'll hand it over.

Thank you, Stephanie. Appreciate it. As Stephanie said, just so much happening in this last month. It really -- it just keeps washing over us. And as we say to all of -- you all out there, hang in there, take a break when you can, try to reset, and then we get to plow forward with the next announcement. So back in our June webinar, we talked about how legal challenges are becoming the new norm with respect to tariff actions. And at that time, we pointed out that U.S. importers clearly have become emboldened to take on the administration, particularly now that we've seen the Supreme Court action the win, if you will, for importers on the IEEPA tariffs. And second, again, to say this again, it just doesn't appear that Congress is emboldened sufficiently to take back their constitutional authority over tariffs and attempt to manage the actions coming from the executive branch. So basically, importers have to go to the third branch of the government, the judicial branch, and try to get interpretations and potential revocation of those executive actions related to tariffs. And so as we can see, not quite as much going on as Stephanie talked about, but certainly some things going on in the courts right now as we're going through. We'll talk a little bit more about the IEEPA stuff in some detail here in a second. But the big round -- the first big round of activity that was, like I said, a win, if you will, for importers was the IEEPA court actions proceeding all the way up to the Supreme Court. And it -- now we're just kind of left with dealing with how to the refund process, and we'll talk about that. Section 122, I think it was pretty obvious. The administration felt somewhat uncomfortable that Section 122 was the durable way to go, but it was the immediate answer they had to impose tariffs after IEEPA. That is moving through the courts now with the Federal Circuit appeal pending on that. So I think on any of these actions, we can expect things to move through the full court system, Court of International Trade, Court of Appeals, and the Supreme Court. And we likely will see this with 122. The key point, if nothing else, hopefully, if it does come to a resolution where importers can get refunds such as in the IEEPA case, hopefully, it also sets the precedent that the administration can't go back and reuse 122, that it does establish some boundaries perhaps around 122 as we move through the court actions. Section 232 metals, this was that interesting one that really talked about valuation and the plaintiffs are suing, really, at CBP and stating that the way CBP is imposing valuation rules on certain derivatives is not in accordance with the valuation statutes and Section 232. So this is really directly very specific about valuation. But it's certainly, depending on how the court ends up finding, we could have to pay attention to changes in valuation models that we're currently using. And then the current big darn deal that replaced IEEPA is the Section 301 forced labor actions, and we'll talk a little bit more about those as well right after I talk about IEEPA. But again, the U.S. court system seems to be the place where tariff actions and policy are now being evaluated and defined. All of the things that Stephanie just talked about, I think we can anticipate more court actions as this goes along. So let's keep in mind that certainly, there's stuff going on now, but we expect more things to be going on as we move forward. So with that, let's talk a little bit about IEEPA. So I just was talking about our June webinar and our July webinar, we did really a deep dive into IEEPA and looking at the duty refunds and all that's going on, the continuing court actions. Today, we just want to kind of do a quick highlight and run through some things and what's going on right now. First, the big -- I think the good news is things in general are going relatively well on this one with the duty refund process. In CBP's latest update to the courts, they talked about over 17 million entries having been processed for refunds. There -- that amounts to about $130 billion in potential IEEPA duty refunds that are going out or will be going out. So by and large, most IEEPA entries seem to be moving pretty well through CBP's Cape processing. The big sticking point continues to be those entries that are considered finally liquidated. That is -- they're the ones that are 90 days past the liquidation date. The U.S. government, in their court filings and general statements, are continuing to maintain that those entries cannot be actioned by CBP unless an importer filed suit in the CIT, the Court of International Trade. CIT Judge Eaton has ordered CBP to reliquidate all entries for importers who have filed suit and the government has stated that they will not appeal that action. So at this point, it does appear that filing suit may be the most promising route to getting refunds on finally liquidated entries. There was also a recent testimony in the CIT around the potential for a class certification for all importers that are tied to these IEEPA duty refund matters, which that could potentially create an opportunity for importers who have not filed suit in the lawsuit to address those finally liquidated entries. The court recognizes the cost of filing suit, even the government recognizes this. And for small, medium-sized importers, they don't necessarily have the wherewithal to go hire outside counsel, go through the process of filing and all that goes along with it. So it is clear that the court is interested and see if there is an alternative and maybe class certification is it. But at this point, we're back to the government continuing to hold the line that CBP does not have the statutory authority to issue refunds on finally liquidated entries without that court filing by an importer. So bottom line, I wouldn't recommend just sitting back and hoping that the court does a class certification. Definitely possible that, that happens, but it's not a given. As we all probably have heard from our high school coach or a drill sergeant or maybe even our mom, hope is not a strategy. So let's think about where we're going, and we're going to stick with the recommendations we've been talking about over the last several months. Excuse me. Enjoying a summer cold here that hopefully, you don't get to enjoy it either. Really, the key thing is quantify that potential refund exposure with finally liquidated entries. Is it worth the investment and the time that it takes to do it through a court filing. But think about it, pay attention to your liquidation dates. Really, we continue to strongly recommend that you think about your protest strategies and whether or not you do want to engage outside counsel for those finally liquidated entries. So again, don't just assume that we're going to get class certification or the fact you've got protest filing filed will guarantee you have access to those finally liquidated entries to get a refund on them. Take the action that you need to do, figure out the cost benefit analysis, and then move forward to make sure you're doing okay. Watch the statutory time frame on -- it's a 2-year limit that you get before you get -- before you run out of time to file in the CIT. So keep that in the back of your mind as well. Don't just keep delaying things as it goes. All right. With that, let's talk about Section 301 forced labor. As Stephanie pointed out, the 122 tariffs went away. And right after that, we saw the 301 forced labor tariffs fall into place. And a combination of the timing, and public statements, and the basis of the forced labor tariffs, and all that stuff have caused a number of folks to pile in with lawsuits. So on the 24th of July, we saw 2 suits being filed. There were 2 importers who, I think, came in first and got there then and then right after that, another importer filed their own suit. It was a class action suit that was filed by the first 2 importers. And really, they're talking about things that are constant and then consistent across all 3 cases. They're saying that the tariffs and, specifically, were arbitrary and capricious. It was a preordained result that come up with the tariffs, things along that line. They're also in the class action suit talking about the fact that 301 is a very targeted trade remedy statute and can't be used to just broad -- do a broad-based sweeping countrywide tariff. There has to be specificity to it. The second suit that was filed similar arguments and in fact, all 3 are similar. They also brought out the point that the USTR in their investigation preceding the tariff action, they didn't meet the statutory requirements for individual findings for each of the 60 economies. So they bring in some additional points. And then finally, we saw about a week after that first round, 25 states led by Oregon, Arizona, and California led their own lawsuit, same arguments. They're also pointing out a potential violation of the Administrative Procedures Act. They're talking about the short time frame that the investigation -- you're talking about 60 economies and yet it took 2.5 months from announcing the investigation to closing it and taking action. They also point out accurately that certain goods that are allegedly made by forced labor are not -- are indeed exempted from the 301 tariffs. Stephanie talked about all the range of exemptions. And it seems interesting that if certain goods are allegedly made by forced labor, then, wouldn't they be subject to these tariffs? So this is all just started. This is early in the process. We expect that we might see actual action in the courts, the parties are all sorting out what's the lead case, who's going to meet when. Maybe by October, we start actually seeing testimony in the Court of International Trade on this. But it's possible that we do see some action on 301. In the past, the courts have been very differential to the executive grant decisions around 301 and 301 cases have not -- the plaintiffs haven't prevailed against the government in the past. But this one does have some merit perhaps. So we also know that, again, CIT will make a decision. We'll see it go to the Appeal, Court of Appeals, and we'll probably see it go to the Supreme Court. So we're in for another long haul on this one. It's just the latest round of lawsuits that we need to keep an eye on. So now as I often have the pleasure of doing, I get pass the baton off to my friend, Brenda. So Brenda, it's all yours, please.

Thanks very much, Ted. Greetings, everybody. So as we head into the fall, we wanted to be sure that you had a really good grasp on what is happening internationally. We have a number of important trading partners. The stability of those relationships has been a little inconsistent over the last 18 months. But just going into September, kind of understanding where we are with the various trading blocks, we think is important as you work through your compliance and your strategic planning decisions. So let's start with North America. We spent a lot of time in the last month or 2 talking about the USMCA review, which is certainly a key aspect, in fact, probably the main driver with the relationship between the U.S. and its North and South neighbor. That review process is still underway with very active negotiations. We believe that the primary activity or the most likely significant activity will come around rules of origin, likely specifically with respect to the automotive sector. But we also believe that, as we've talked about before, that the enforcement focus by the U.S. on ensuring that either inputs or companies with that China connection do not get the preferential duty rate coming out of USMCA. And so that may result in a pretty significant reform of rules of origin. Again, this may be limited to the automotive sector, but I think it will indicate where the U.S. is going with future negotiations, not just in North America, but really around the world. Of course, and Stephanie has already called this out, the other thing that we are really looking at or watching for is what is going to happen on August 19, just 6 days from now with respect to the relationship between the U.S. and Canada. The scuttlebutt here in Washington is that Canada wasn't coming to the negotiating table with good offers as Mexico had done. And this was an attempt to, really, insert some new negotiating leverage by the United States to try to get Canada to come to the table so that we do have resolution around the North America issues before the end of the year. So stay tuned on that. The next major block that we want to talk about is Europe. And Europe -- so Stephanie, if you could move the slide forward. Here, we've talked about tariffs over the last 18 months, but there is so much regulatory activity going on, not only related to carbon, and environmental, and sustainability goals, but also in the digital framework. And a lot of times, we think, "Oh, we don't do digital, we do goods. We do physical goods." But the digital issues that the European Union is working to resolve, with respect to primarily large U.S.-based digital providers, is driving a lot of the conversation between the U.S. and the EU. Turnberry Agreement has been done and dusted. Full implementation is taking place as we speak. It is still possible by some of the associated tariff actions, 232s and 301s, that Europe will be hit by additional tariffs, but the primary focus really is on the regulatory activity that the U.S. businesses are facing when they go into the European trade environment. The last thing of significant interest to us, and hopefully to you, is the European customs reform. UCC Uniform Customs Code, as it's often referred to, has already started with implementation. They're taking baby steps. Our main concern is that we don't know exactly, with any specificity, what that reform actually looks like, what it means to us as compliance professionals, what it means to us as software developers. And so we are keeping a very close eye on that because of the significance of the changes, a centralized data hub, a centralized customs authority and what is likely -- what is that likely to mean not only for the European Union as a whole, but the individual implementing member states where many of us do business. So I think there is a lot of opportunity for change, a lot of opportunity for progress if we can get these digital and regulatory issues kind of set and so that everybody knows what the predictable positions are. So the next elephant in the room is China. A lot of activity there, but it's a very interesting activity, and it really revolves around the politics and the negotiating strategy of these 2 superpowers. Both President Trump and President Xi committed to meeting several times in 2026. We had the first meeting last spring. We saw things like the Board of Trade. Prior to that, what we saw was the 2 countries kind of pulling their punches. They were not taking action that would really irritate or really set the relationship on a bad course. We're seeing a similar approach now as we head into the next Trump-Xi meeting likely to happen in September or October. But we are also seeing kind of a low level of action around export controls, a little bit of critical minerals, some decrees that China has issued, which impact U.S. companies doing business in China. So it's a very complex time for this U.S.-China relationship, not unexpected. But just as an indicator, there were many people commenting on when the forced labor 301 duty rates came out, that China was subject along with many other countries to a 12.5% rate. They expected a higher rate. However, if we're trying to keep the relationship warm, not hot, not cold, that was kind of a middle-of-the-road solution. The other thing that I would advise you to keep an eye on is November, when many of the previous suspensions will come off, technically. So we'll see if that actually happens. We'll see what the meeting schedule between the 2 presidents, how that impacts it. This continues to be an active space. My sense is that the U.S. has not settled on the exact strategy they want to take with China. So stay tuned. And the last trading block that we wanted to touch on is one that many of us are doing business in, and that's the Asia Pacific. I know this is kind of a broad bucket of countries. The production capacity in Asia Pacific region continues to grow, which provides many U.S. businesses with an alternative to manufacturing in China. But we're also seeing China recognizes that. And so they've worked really hard on developing their relationships throughout the region, always strong relationships. What may be interesting is a new free trade agreement coming up or being negotiated now, which may drive additional integration between China and the ASEAN countries. Vietnam, in particular, continues to be kind of the poster child for that increased manufacturing capacity and the integration. And it's something that the U.S. has really been all in on, but also takes it with a grain of salt because it knows the relationship between China and Vietnam is pretty strong, both geographically and politically. And the last thing that I wanted to touch on was the ongoing trade negotiations. The intelligence that we heard from U.S. government officials was that until a trade agreement, one of those reciprocal trade agreements or agreement on reciprocal trades had been published that, that agreement was not final. And when we had published text, then things were locked down. Well, there's very, very few of those in the Asia Pacific region. And so there is still opportunity for tariff negotiations and other provisions to be negotiated between the U.S. and the Asia partners. The next thing to watch on, the next date to watch on, is the big confab between the leaders of these -- the Asia Pacific economic community, which will happen in China in late November. So lots going on there, but we wanted you just to have, in the back of your head, where are we actually with these 4 major trading blocks and where are things likely to go. So with that, I know, Madeleine, you're going to take us into the enforcement realm. So let me turn it over to you.

Right. Thank you so much, Brenda. And yes, everybody, I'm going to be talking about enforcement. Obviously, we have all seen a lot of enforcement with this administration. It's definitely ramping up. We, as Expeditors, have seen just a large number. And I think we've talked about this before on previous webinars, but we continue to see a huge number of CF-29s, CF-28s, which are the request for information and very, very -- and when those come out, CDP is asking for very, very detailed documentation. So in general, we've just seen a huge uptick on both CF29s and CF28s other document requests. And then I think recently, too, I'm sure all of you saw and we touched on this, I believe, last month, it were the 43 additional entities that were added to the Uyghur Forced Labor Prevention Act list. So this administration is definitely looking at and pushing forward on enforcement. And so this is something that you see here on this slide that you should definitely be aware of and take a look at. And we may have mentioned it briefly last month. But remember everybody, there is a Trade Fraud Task Force that was up as part of the Department of Justice, the DOJ. And that was done back in August of 2025. And then last month, this Trade Fraud -- it's difficult to say. This Trade Fraud Task Force came out with a resource guide to trade fraud enforcement and definitely recommend that you take a look at this and just be aware that this is out there. It's very -- it's an interesting read for us trader nerds. The introduction is heavily -- the enforcement is definitely the big hammer and that comes through very clearly in that introduction. It's also interesting that they define trade fraud as being a multi-faceted threat. There's 3 facets, one being fiscal health which they define as duty evasion, is effectively stealing from the public treasury. So that is one facet. The second facet is public safety. So then they're saying that fraudsters are not only bypassing duties, but they're bypassing -- or they're not only evading duties, but they're also bypassing health and safety screening. And then last is, of course, the aspect or the facet of human dignity, which they equate to forced labor and being very careful or basically fraudsters are not removing forced labor from the supply chain. So those are the 3 facets of trade fraud. And the last chapter, the Chapter 5 there is very interesting because the DOJ talks about all of the very predominant fraudster schemes. And so you'll see listed there using false HTS classifications, false countries of origin. There's manifest fraud. There's these dual invoice schemes for anti-dumping countervailing duty. Anyway, it's an interesting read. But it's important to know that it's out there. And I think one thing I can say, too, is we have seen activity from this Trade Fraud Task Force. Unfortunately, we've seen a couple of importers that have received subpoenas where the Trade Fraud Task Force is asking those importers to justify the classification that they use on a number of entries. So they are active. So we do have to -- anyway, you should be aware. Again, it's part of that whole umbrella of enforcement. And I think the main -- here are just the main points that we listed that you can take from this document. I think, again, for me, the most important probably is the fact that compliance and that we see here on the screen is not or is an enforcement issue, right? So classification, origin valuation, and we talk about that, I think, on almost all of our webinars. But based on this document, it's not just going to trigger a possible audit or a penalty, but in some cases, it could lead to a criminal investigation. So again, those 3 basics of the declaration, classification, origin and valuation are super important, and they're sort of the cornerstones or keys of customs enforcement. So again, super important, everybody, to have the right backup documentation, right? The documentation that explains how did you arrive at your classification, how did you determine the origin, and how did you determine your valuation? Those are really the key points. And again, something that we echo on lots of webinars, making sure that you have that piece of your declaration in order. So -- anyway, so what action can you take right now? So a couple of things. First is just make sure -- this is really important, to make sure that your data is really clean. So in regards to classification, origin, valuation, especially if you're sending that data to us or to your customs broker, make sure that data is really, really clean and solid. I know that there have been issues or we've encountered issues in the past, unfortunately, where customers had -- importers had a turnover in their department. They were sending data. It was very clean. And then unfortunately, when they turned over to new people, those folks maybe were not monitoring the data as closely. And that you can then run into all kinds of issues, as you can well imagine. So just make sure your data is clean, make sure you're really looking at your exposure to Section 232, Section 301. Of course, there's always enforcement around anti-dumping, countervailing duty, and understanding the entities in your supply chain, far upstream to make sure that you don't have any issues or red flags in regards to forced labor. And you can do some testing yourself. You could take -- and this is something you can do right now, is look at your most high-risk products or maybe those products that you're importing in the biggest number, and look at the raw materials, look at -- can you trace those products and the components all the way upstream to where did those components come from? Where do they originate? Do you know those entities? And you can build in, on a regular basis, just an audit program, auditing for those upstream entities, auditing for classification, valuation, origin. So these are things I know not necessarily easy to implement, but things that you can look at right now and start doing even for those -- again, you don't have to boil the ocean, start with a couple of your highest risk products or those that you import in the greatest number. But again, I can't stress enough the importance of the classification, origin, and valuation. Okay. We can go on to the next slide, Stephanie. So last but not least, everybody, we've definitely talked about this very, very important executive order on strengthening customs enforcement. It came out on June 3. I think of any document, this is, in my opinion, the most important document to read. This is as big, I think, as the 1993 Mod Act. So please, if you haven't had a chance to read it, I highly recommend that you read it. And we will be coming out with more information on this. We are doing specific webinars on the executive order starting at the very end of the month. You'll see the links here on this slide. We -- one here for the Americas and then for our colleagues and customers in Europe, Middle East, and Africa and Asia Pacific. This is such an important executive order. It affects everyone in the supply chain. So there will be more information shared at that time. We hope that CBP will have released more information on the executive order by that time as well. But regardless, we will talk about the milestones, what we believe it means to you as an importer, and what you can do right now. So anyway, if you haven't done so already, well, you will get the links to sign up for these webinars. So anyway, I will now pass it on to my colleague and friend, Ted.