Proposed Elimination of First Sale Customs Valuation Method

New legislation introduced in the U.S. Senate proposes eliminating the use of the “First Sale” customs valuation method and requiring importers to declare customs value based on the last sale prior to export to the United States. At this time, this is proposed legislation only. No changes have been enacted, and U.S. Customs and Border Protection (CBP) valuation procedures remain unchanged.

Under current customs valuation rules, eligible importers may use the First Sale method to declare value based on the initial sale in a multi-tier supply chain, provided specific documentation and compliance requirements are met. This method allows duty to be assessed based on the earlier transaction value, which may reduce duty exposure and improve the predictability of landed costs.

If enacted, the proposed legislation would require valuation based on the final sale to the U.S. importer. This could increase the declared customs value and result in higher duty liability, particularly for goods subject to Section 301 tariffs, “reciprocal” tariffs, or Section 232 duties.

What this means for your supply chain planning

There is no immediate change to customs valuation requirements. You may continue using First Sale valuation where your transactions qualify, and documentation requirements are met.

However, because this proposal could materially affect duty exposure if enacted, you may wish to review whether your current import valuation structure relies on First Sale and assess potential exposure under a Last Sale valuation scenario. Early evaluation will help you understand potential cost impact and prepare for future regulatory changes.

Maersk’s Trade Services team can support valuation reviews, duty exposure modeling, documentation assessments, and strategic planning aligned with your sourcing and customs compliance structure.

If you would like assistance assessing your exposure or preparing for potential regulatory changes, please contact your Maersk representative or compliance.mcsi.nam@maersk.com.

We will continue to monitor developments and share updates accordingly.

Anything you need, we’re here to help

Solutions

Logistics services

We meet customer needs from one end of the supply chain to the other.
Headset

Contact us

Our dedicated team of experts are here for you.
Find Prices

Ready to ship?

Look up rates for new shipments and inland tariffs.
Stay informed
Sign up for news and insights
Stay ahead of the curve with valuable supply chain trends sent directly to your inbox

I agree to receive logistics related news and marketing updates by email, phone, messaging services (e.g. WhatsApp) and other digital platforms, including but not limited to social media (e.g., LinkedIn) from A. P. Moller-Maersk and its affiliated companies (see latest company overview). I understand that I can opt out of such Maersk communications at any time by clicking the unsubscribe link. To see how we use your personal data, please read our Privacy Notification.

By completing this form, you confirm that you agree to the use of your personal data by Maersk as described in our Privacy Notification.

Thank you for signing up
You have now signed up for newsletters. You will shortly receive an email which will explain how to set your newsletter preferences and unsubscribe.
Subscribed
You can unsubscribe anytime.