Commentary

By James Ferry

Compliance paralysis is the real threat to Q3 freight volumes, not vessel capacity or consumer demand.

Somewhere right now, a procurement manager is staring at a third-quarter purchase order and deciding not to sign it. Not because demand has softened; because nobody can tell them what their duty rate will be on July 25.

That compliance paralysis— multiplied across thousands of importers— is the real threat to third-quarter freight volumes, not vessel capacity or consumer demand.

On July 24, the temporary 10 % global import surcharge imposed under Section 122 of the Trade Act of 1974 expires, to be replaced by proposed Section 301 tariffs of between 10 % and 12.5 % on 60 trading partners for allegedly failing to impose and enforce forced labor laws.

Most logistics providers are treating this as a back-office regulatory event. It isn’ t. It is the most consequential volume-disruption risk of the 2026 freight year.

The pre-deadline surge is real. Shippers who have done the compliance work are pulling forward third-quarter demand, booking capacity now to land cargo before July 24 and avoid the uncertainty entirely. But this frontloading is masking a more dangerous dynamic: The moment the deadline passes, those shippers stop. Their demand has already been consumed. And the importers who couldn’ t calculate their exposure— who froze instead of acting— will still be frozen. The result is not a soft landing; it is a demand cliff that follows the rush.

The Trump administration’ s intent is to have the new Section 301 tariff framework operational the moment Section 122 expires.

Simultaneously, a restructured Section 232 framework, effective April 6, now applies duties to the full customs value of finished goods containing foreign steel, aluminum or copper, not merely the value of the metal content. Products where foreign metal content exceeds 15 % by weight face a 25 % duty on their entire customs value.

For a corporate procurement team, this is an untenable position. They are committing to ocean freight and overseas manufacturing costs without knowing what their harmonized tariff schedule( HTS) exposure will be when the vessel reaches a US port of entry.

In international trade, regulatory ambiguity functions as a cost increase. If a beneficial cargo owner( BCO) cannot calculate its landed cost with confidence, it cannot price goods for the second half of the year.

When compliance departments signal that a product line might face an additional 12.5 %— or cumulative rates exceeding 37.5 % for China- origin goods where existing Section 301 duties of 25 % stack on top of the new 12.5 % replacement rate— procurement managers do not roll the dice. They halt. They delay production runs. I have seen this directly: Importers who moved aggressively in the first quarter are now sitting on their hands, waiting for a Federal Register notice before committing to a single container booking.

The downstream symptoms are already visible. Importers are avoiding fixed-rate forwarder volume commitments because their procurement forecasts are written in sand. Drayage operators in major inland hubs see hesitance in warehouse space commitments for August and September. A purchasing freeze in June manifests as a measurable drop in container arrivals by late August, well into peak season.

The market is splitting into two distinct groups. Reactive importers are watching headlines and planning to adjust after July 24 passes. By the time they recalculate margins, book factory capacity and secure equipment, the peak season window will have closed. Their freight providers will feel this gap directly.

Proactive BCOs are not waiting for clarity; they are engineering it. They are running HTS classification audits, modeling best- and worstcase duty exposure, and establishing structural alternatives now, including bonded warehouse strategies, country-of-origin restructuring, and US-origin metal content qualification, to mitigate Section 232 full-value exposure. These companies will not freeze. Their containers will move.

The difference between these two camps is not company size or procurement sophistication. It is access to trade compliance expertise before the deadline, not after it.

For freight forwarders, ocean carriers and drayage operators, the implication is direct: Your asset utilization is tied to your clients’ compliance readiness. If you are not actively asking your importer clients how they are preparing for the post-July 24 tariff transition, you are entering peak season without visibility into your own demand pipeline.

The freight providers who emerge from 2026 with volumes intact will not simply be the ones who moved the most boxes. They will be the ones who understood that in a tariff-defined market, compliance intelligence is the new capacity.

James Ferry is the founder of trade compliance consultancy Ferry Trade Group.

email: james @ ferrytrade. com

62 Journal of Commerce | July 6, 2026 www. joc. com