New 'Trusted Importer' Program Offers 10-Year Tariff Waivers, Creating Two-Tier Trade System

The Trusted Importer and Competitive Manufacturing Act of 2025 is setting up a fast lane for international trade, but only for a select group of companies. The bill creates a new “Trusted Importer Program,” managed by the Secretary of Commerce and U.S. Customs and Border Protection (CBP), which allows certified companies to get significant tariff reductions or even full waivers for up to 10 years.

This isn’t a program for every business. To get certified, importers must show strong financial health, tight supply chain security, compliance with all trade laws, and, crucially, that they promote U.S. manufacturing competitiveness. If they qualify, the President—coordinating with Commerce and the U.S. Trade Representative (USTR)—gets the authority to slash the tariffs they pay on approved imported goods (Sec. 2).

The VIP Pass for Global Supply Chains

Think of this as a Global Entry pass for corporations. For large companies that import massive amounts of components or finished goods, this program could mean millions in savings. For example, a major electronics manufacturer importing specialized chips could see their input costs drop significantly if their existing tariffs are waived. This could potentially lower the cost of the final product for consumers, or at least boost the company’s profit margins, which is a clear benefit for those who can afford the compliance costs.

However, the price of admission is high. Certification requires incredibly robust internal controls and security measures, which means this program is primarily designed for established, large-scale importers. Smaller businesses that import goods but lack the massive compliance departments necessary to meet these stringent requirements are likely shut out, creating a two-tiered system where the biggest players get preferential pricing on imports, potentially undercutting smaller competitors who still have to pay the full tariff rate.

Where the Tariff Protections Stop

While the bill grants broad authority for tariff reduction, it includes some important guardrails. The President cannot waive tariffs that are in place due to anti-dumping or countervailing duty orders (AD/CVD), which are tariffs meant to counteract unfair trade practices from foreign governments. Similarly, certain tariffs imposed under Section 201 investigations (intended to protect domestic industries from import surges) are also off-limits for reduction (Sec. 2). This means that specific, targeted protections for domestic industries remain intact, at least on paper.

But here’s the rub: the bill allows the reduction of other tariffs for Trusted Importers. If a U.S. manufacturer relies on a general tariff for protection against foreign competition, and a massive certified importer suddenly gets that tariff waived, the domestic manufacturer is effectively facing subsidized competition. The bill attempts to balance this by requiring the President to consider the “competitiveness of U.S. manufacturers” and the “protection of domestic supply chains” when making tariff decisions, but these terms are highly subjective and leave a lot of room for interpretation by the executive branch.

The Long-Term Trade-Offs

The license is valid for 10 years and renewable, giving certified companies long-term cost predictability. Conversely, the Secretary of Commerce can revoke the license for issues like fraud, failure to keep records, or facilitating smuggling—a necessary check against abuse (Sec. 2).

Twice a year, Commerce and CBP must report to Congress on the program’s impact, specifically noting any “potential harm to domestic manufacturing.” This reporting requirement is critical because it’s the only formal mechanism for assessing whether the cost savings for large importers are coming at the expense of U.S. producers. The success of this program hinges entirely on how rigorously the Commerce Department defines and enforces the requirement that importers must “promote U.S. manufacturing competitiveness,” balancing cheap imports against domestic jobs. This is a significant grant of power to the executive branch to shape import costs for specific, favored companies over the next decade.