Exposure mapping
Trace tariff exposure through the bill of materials — every ingredient, every origin — down to landed cost per SKU. Most food companies know their duty bill; few know which products are carrying it.
Consulting
The tariff is
part of the recipe.
Tariff classification and trade consulting for food importers and the companies that depend on them. Duties now shape formulation, sourcing, and margin the way any ingredient does — I help you treat them that way, with the food science to back every move.
Why now
The duty map is drawn at the tariff line.
The last two years rewrote the rules for imported food: new duties by country, then exemption lists carving out hundreds of agricultural lines — coffee, cocoa, bananas, beef — commodity by commodity, origin by origin. The carve-outs follow the tariff schedule, not the grocery aisle. Cocoa beans can enter free while a chocolate preparation made from them pays, and the difference between those two products is a formula.
That's the part most trade advice skips. Whether a product lands on the exempt line or the dutiable one comes down to composition and process — percent milk solids, percent sugar, how far the ingredient was transformed and where. Those are food-science questions. Answering them is the work I do.
Where I can help
Four places tariffs meet food.
Classification
Food is where classification gets technical. The chocolate lines of the tariff schedule split on thresholds like 21 percent milk solids or 60 percent sugar — the duty rate is literally written in the formula.
Tariff engineering
Reformulation and spec changes that legitimately change a product's duty treatment — proven on the bench for taste and function before anything is filed with your broker or counsel.
Sourcing strategy
Alternate origins and supplier qualification, judged by someone who knows what a switch does to the product — not just to the duty rate.
Has not a manufacturer a right to make his goods as he pleases?
— The U.S. Supreme Court, 1881, in a case about sugar
Older than you think
Tariff engineering began with food.
In 1881 the Supreme Court took up Merritt v. Welsh, a dispute over sugar duties that were graded by color. An importer's sugar was dark enough for the low rate; customs suspected the color had been left that way on purpose. The Court sided with the importer: make the product however you please, and the tariff must take it as it finds it. Designing a food to meet a tariff line is legal, more than a century settled — and it has always been a formulation problem.
The boundary matters just as much. A century later, a refiner mixed molasses into sugar syrup purely so it would clear customs at a lower rate, then stripped the molasses back out. The courts called that what it was — a fictitious product — and struck it down. The line between engineering and evasion is whether the product is real: really formulated, really sold, really what it says it is. I work on the right side of that line, and the science is how you stay there.
The work
What an engagement looks like.
Scoped projects, not retainers by default — each one built to leave your team knowing more than it did.
- 01
Tariff exposure assessment
A SKU-level model of where duties land across your portfolio: which products absorb them, which margins break first, and where the biggest levers are.
- 02
Classification review
A technical review of how your ingredients and finished goods are classified, with a plain-language dossier your broker or counsel can act on — the composition, the process, the reasoning.
- 03
Reformulation for duty
Feasibility work on formulation changes that shift duty treatment: what to change, whether it survives sensory and shelf life, and what it costs to make.
- 04
Origin and sourcing shifts
Qualifying alternate origins and suppliers before you commit — matched on functionality and flavor, not just price and rate.
- 05
Scenario planning
Modeling announced or threatened tariff actions against your actual portfolio — including whether your products sit on an exemption list or just near one — so a headline becomes a number before it becomes an invoice.
- 06
Briefings and training
Teaching your R&D, sourcing, and finance teams to read a tariff action and see the exposure in their own formulas — so the next one doesn't need a consultant.
Why me
I've sat on the importer's side of the desk.
I've spent my career building food supply chains that cross borders — sourcing ingredients globally, standing up industrial production, and carrying products from bench chemistry to shelves worldwide. Now I'm an importer myself. When I look at a tariff schedule, I see it the way your business does: as a line item on real containers of real food.
The difference is the science. Classification arguments, reformulation options, origin switches — in food, every one of them turns on composition and process. I can tell you not just whether a change moves the duty, but whether the product still tastes right afterward, because I can do the bench work myself.
The novel cases are the point. Big trade practices run on precedent — when a ruling exists, they'll find it. But food keeps outrunning the schedule: new ingredients, new processes, products the drafters never imagined. I've spent my career making foods the existing categories didn't have a shelf for. When there's no precedent to look up, the classification has to be built from first principles — composition, process, function — and argued as chemistry before it's argued as law. That's squarely my camp, and being independent means I can take a well-supported position where a bigger, more risk-averse shop would wait for someone else to set the precedent. For filings and formal rulings I work alongside your broker or counsel — but the argument they file starts at my bench.
Facing a tariff problem with food in it?
Tell me what you import and where it hurts. A first conversation costs nothing.