When the Tariff Accountability Act was signed into law in December 2021, it was, in many respects, a formal acknowledgment of something industry participants and economists had been pointing out for years: that tariffs, though often wielded as blunt instruments of trade policy, generate complex and sometimes unintended ripple effects throughout supply chains. The Act compels the U.S. Trade Representative (USTR) to do what perhaps should have been standard practice all along—report on the actual supply-chain impacts of newly imposed tariffs. Early industry responses to this legislation in 2022, particularly from sectors like steel and aluminum, have ranged from cautious optimism to quiet skepticism.
At its core, the Act introduces a degree of accountability and, at least in theory, data-driven policymaking. Yet in practice, the question remains: will the reporting requirements under the Tariff Accountability Act meaningfully change how tariffs are designed and applied? Or will they simply add another layer of bureaucracy to an already complex regulatory landscape? There’s no easy answer. The initial reports issued in early 2022 provided some insight into the policy’s ambitions but fell short of offering a truly granular picture of supply-chain dislocations. One could argue that’s to be expected this early in the process, given the difficulty of disentangling tariff impacts from other macroeconomic forces.
For steel and aluminum producers, the Act’s passage prompted a flurry of activity—mostly behind the scenes—as firms tried to prepare for more rigorous scrutiny of how tariffs affect their cost structures and pricing strategies. A key priority for these companies has been gathering reliable input-cost data from Tier 1 suppliers. This task is not straightforward. Supply chains in these industries can be surprisingly opaque, with information asymmetries and proprietary concerns making it hard to obtain consistent data.
One useful resource that firms have begun to leverage is the publicly available Census import data. While this data doesn’t provide perfect visibility into every transaction, it does offer a valuable proxy for tracking price trends in imported raw materials and semi-finished goods. Companies are using these import records to cross-check supplier claims about cost pressures tied to tariffs. For example, if a supplier attributes a price increase to higher input costs for imported steel slabs, the importing firm can look at Census data to assess whether import prices for these slabs have, in fact, risen in line with those claims.
But the effort shouldn’t stop there. Firms need to adopt a more systematic approach—building internal databases that integrate these public import data sets with their own procurement records. This can help identify patterns, such as which inputs are most sensitive to tariff changes, or where pricing claims by suppliers diverge from observable market trends. It’s painstaking work, no doubt. But in an environment where cost justifications could increasingly be subject to regulator or customer scrutiny, it may well be worth the effort.
Equally challenging is mapping the downstream price impacts of tariffs, particularly as they filter through to consumer markets. The Act calls for a clear understanding of these impacts, yet isolating the influence of tariffs from other inflationary forces is a task fraught with methodological pitfalls. Some producers and trade groups have begun experimenting with the use of consumer price index (CPI) components as a tracking tool.
The logic here is that certain CPI categories—say, major appliances or motor vehicles—can serve as proxies for industries where steel and aluminum play a significant role. By correlating tariff timelines with price movements in these categories, analysts can at least begin to form hypotheses about tariff-induced inflation. Of course, correlation isn’t causation. And in a year like 2022, when global supply chains were still reeling from pandemic disruptions and energy shocks, drawing clean lines of causality is next to impossible. But these exercises still offer value. They help firms and policymakers identify where deeper investigation is warranted, where anomalies emerge, or where pricing trends defy expectations.
Some firms are taking this a step further by building internal models that attempt to weight the contribution of tariff-related cost increases to final consumer prices. These models rely not just on CPI data but also on proprietary production cost breakdowns, supplier invoices, and—where accessible—contractual pricing terms. The results of such models aren’t perfect, and companies should be cautious in how they present or rely on them. But they do represent a move toward more sophisticated and evidence-based tariff impact analysis, which, after all, is what the Tariff Accountability Act seems to demand.
One interesting side note that emerged in early industry discussions is the question of how this new reporting framework might affect lobbying behavior. Some companies have expressed hope that more transparent and data-rich impact assessments will help them make a stronger case for tariff exemptions or adjustments. Others are less convinced, worrying that the reporting process could simply become another forum where entrenched interests compete to spin the data in their favor. That tension—between transparency and advocacy—was probably inevitable.
It’s also worth mentioning that the data-gathering and reporting exercises being undertaken by steel and aluminum producers have knock-on benefits beyond pure compliance or lobbying objectives. By forcing firms to engage more deeply with their supply-chain cost structures, the Act may be driving, albeit indirectly, better internal analytics and risk management practices. Whether that translates into more resilient or competitive supply chains over the long term is a separate question—one that, frankly, will take years to answer.
Steel and aluminum producers would be wise to focus on building the internal capabilities needed to meet both the letter and the spirit of the Tariff Accountability Act’s requirements. That means not only collecting and analyzing input-cost and CPI-related data but also documenting methodologies clearly, so that their submissions to USTR withstand scrutiny.