The proposal for the US Tariff Accountability Act, introduced earlier this year, is already generating considerable debate, particularly among those tasked with navigating the complexities of international trade compliance. While still under legislative review, and therefore subject to possible (perhaps even substantial) amendment, the basic contours of the proposed law are clear enough to warrant serious attention. If passed in something close to its current form, the act would represent a significant shift in how US firms are expected to account for and disclose the impacts of tariff measures on their supply chains. Whether one views this as long overdue or, perhaps, as an administrative burden in the making probably depends on where one sits in the broader ecosystem of trade, policy, and procurement.
At its core, the Tariff Accountability Act seeks to bring greater transparency to the ways in which tariffs — often deployed as blunt instruments of trade policy — ripple through supply chains, affecting price formation, sourcing decisions, and ultimately the costs borne by consumers and businesses. The legislation would require companies to publicly disclose detailed information about the impact of tariffs on specific supply routes and product categories. This includes, crucially, data on price, origin, and volume of imported goods subject to tariff regimes. The intent, one assumes, is to allow for more informed debate about the efficacy of tariffs and their real-world consequences. But intent and outcome do not always align perfectly — something seasoned compliance professionals are, of course, well aware of.
So where does that leave trade compliance teams in the interim, as the legislative process grinds on? Many, understandably, are weighing whether to act now or to wait for more certainty. Yet there’s a growing sense that preparation, even if provisional, is the safer course. This isn’t simply about anticipating legal requirements; it’s about being positioned to respond flexibly as and when reporting obligations crystallise. And in that respect, firms that have already begun collecting, standardising, and analysing data on supplier prices, origins, and volumes will almost certainly find themselves at an advantage when deadlines do eventually arrive. The challenge, though, lies in the detail — or rather, in the gaps. Price data, for instance, is not always captured at a level of granularity sufficient to satisfy what the act might require. Origin can be surprisingly tricky to pin down with precision in complex supply chains. And volume data, while often more straightforward, still presents difficulties when goods are consolidated or re-exported en route.
What’s emerging, slowly perhaps but steadily, is a picture of the kind of internal systems firms might need to build or enhance. There’s no singular blueprint — no one right way — for how to do this. But the outlines are becoming clearer. It involves building out data infrastructure capable of capturing supplier-level information consistently across procurement categories. It means putting processes in place for verifying origin claims, especially for high-tariff-risk goods. It may also involve scenario planning — trying to model how changes in tariff rates or structures could affect key supply routes or cost structures. This is not a new idea in trade compliance, but the proposed act gives it renewed urgency, or at least adds another layer of complexity.
Scenario analysis, in this context, isn’t about predicting the future with certainty (a fool’s errand, as most would agree). It’s about mapping possible futures and understanding how different tariff configurations could impact operational or financial exposure. There is, of course, a temptation to treat such exercises as theoretical — useful perhaps for the purposes of discussion, but not actionable. Yet in practice, firms that engage seriously with scenario analysis often discover risks, or opportunities, that might otherwise have gone unexamined. The trick, if that’s the right word, is to ensure that these exercises are grounded in real data rather than assumptions layered upon assumptions.
It’s also worth considering, if only briefly, what this shift might mean beyond compliance per se. The proposed act signals a broader expectation that firms should be able to articulate, with a reasonable degree of clarity, how trade policy choices — in this case, tariffs — shape their business decisions. That’s not something all companies have historically been asked to do, at least not publicly. It suggests a move towards a more data-driven, transparent engagement between private sector actors and trade policymakers. Whether this leads to better policy outcomes is, of course, an open question. But the direction of travel seems, at this point, hard to ignore.
Some trade compliance officers have raised a different sort of concern — one not about the technical demands of data collection or reporting but about the potential for unintended consequences. If tariff impacts are disclosed in detail, could that information be used in ways that firms find uncomfortable? Might it, for example, expose sourcing strategies that competitors could exploit? Or trigger political scrutiny of sourcing decisions made for entirely commercial reasons? These are not trivial issues, and they highlight the tension that often exists between transparency and commercial confidentiality.
At this stage, then, what seems most prudent is for compliance teams to continue building out their data capabilities, even in the absence of final legislative text. Waiting for full clarity before acting is tempting, certainly. But in this case, the costs of inaction — or of rushed action once requirements are finalised — could outweigh the risks of preparing in advance. And if nothing else, the discipline of engaging seriously with supply chain data now will likely pay dividends, whatever shape the final law takes.