Trade Compliance | The 3TGs
HS Codes  ·  Export Controls

Trade
Compliance

Navigate cross-border complexity with confidence. HS classification, export controls, country of origin, and denied party screening - structured, documented, and audit-ready.

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By The Numbers

Trade Data at Scale

0
HS Codes Classified
and Documented
0
Export Control
Screenings Completed
0
Section 232 Metal
Declarations Documented
0
Suppliers Engaged
for Trade Data
Workstream Breakdown
Distribution across active trade compliance service areas
Supplier Trade Data Status
Current engagement status across supplier portfolio
Service Deliverables

What You Receive

Every engagement produces structured, documented outputs - not advice and a summary email. The deliverables below are standard across The 3TGs' trade compliance engagements.

See What Applies to You
  • Formal HS code determination reports with classification rationale and supporting tariff schedule references, at product and supplier level
  • ECCN classification reports with EAR and EU Dual-Use Regulation (2021/821) jurisdiction analysis
  • Country of origin determination letters applying CBP substantial transformation rules and tariff engineering analysis
  • Section 232 metals declarations tracing aluminum (smelt and cast), steel (melt and pour), and copper (melt and pour) to country-of-production at supplier level
  • Domestic content assessments for BAA (48 CFR Part 25) and BABA (2 CFR Part 184) government procurement bids, with waiver pathway documentation where thresholds are not met
  • Free trade agreement origin qualification analysis for USMCA, KORUS, and EU preferential regimes with supporting supplier data and certificate management
  • Denied party screening reports against OFAC, BIS Entity List, EU Consolidated List, and UN sanctions lists with documented methodology
  • Regulatory market access maps identifying applicable requirements before products enter new jurisdictions
Target Clients

Who It Applies To

  • Manufacturers exporting goods to the EU, United States, or other regulated markets where HS classification, export controls, or market access requirements apply
  • Government contractors and subcontractors subject to Buy American Act (48 CFR Part 25) and Build America, Buy America Act (2 CFR Part 184) domestic content requirements
  • Steel, aluminum, and copper importers and processors subject to Section 232 tariff obligations requiring country-of-production documentation at smelt-melt-pour level
  • Manufacturers and exporters of dual-use goods, technology, or software subject to EAR jurisdiction or EU Dual-Use Regulation classification and licensing requirements
  • Companies entering new markets that need jurisdiction-specific regulatory mapping before the first shipment crosses the border
900+
Suppliers engaged for trade data collection
Across Section 232, country of origin determination, and denied party screening programs. Supplier data collection is the operational hard part. The 3TGs manages it end-to-end - from template design to response validation.
Regulatory Frameworks

Key Requirements

Each framework below carries independent classification, documentation, and reporting obligations. Non-compliance with one does not create a safe harbor under another - and misclassification in one area frequently creates cascading issues across the rest.

01
HS Code Classification
The Harmonized System assigns every physical product a 6-digit global code, extended to 10 digits nationally - Schedule B in the US, CN in the EU. Accurate classification determines the applicable tariff rate, FTA eligibility, and export control jurisdiction. Misclassification compounds across every import and export entry filed.
WCO HS 2022  ·  Schedule B  ·  EU CN
02
Export Controls and Dual-Use
Items with civilian and military applications - including software, technology, and technical data, not just physical goods - are subject to licensing requirements under EAR (15 CFR 730-774) and EU Dual-Use Regulation 2021/821. Both regimes align to the Wassenaar Arrangement for strategic goods. ECCN classification determines license requirements by destination, end-use, and end-user.
EAR  ·  EU Dual-Use 2021/821  ·  Wassenaar
03
Section 232 Metals
Section 232 of the Trade Expansion Act (19 USC 1862) authorizes tariffs on steel, aluminum, and copper imports on national security grounds. Tariff treatment depends on country-of-production - determined at the smelt and cast step for aluminum, and the melt and pour step for steel and copper. Country of shipment, fabrication, or finishing is not the operative test.
19 USC 1862  ·  CBP Country-of-Production Rules
04
Buy American Act and Build America, Buy America
The Buy American Act (48 CFR Part 25) requires that manufactured products purchased by the federal government be produced in the United States from U.S.-source components. Build America, Buy America (2 CFR Part 184) applies parallel requirements to infrastructure projects funded under IIJA. The two regimes use different content thresholds, component cost formulas, and waiver mechanisms.
48 CFR Part 25  ·  2 CFR Part 184  ·  IIJA
05
Preferential Trade Agreements
USMCA, KORUS, EU-Korea FTA, CETA, and other agreements reduce or eliminate tariffs for goods qualifying as originating from a partner country. Qualification requires meeting rules of origin - typically a tariff shift, regional value content threshold, or both. Documentation requirements and supplier data obligations vary by agreement and product category.
USMCA  ·  KORUS  ·  EU Preferential Origin
Compliance Gaps

The Regulatory Landscape

Trade compliance gaps are not abstract risks. Each one creates a specific, traceable liability. The six patterns below appear repeatedly in engagements with companies that have not yet built systematic trade documentation processes.

HS Classification
Classification Gaps Drive Tariff Exposure
When HS codes are assigned without formal determination methodology, companies accumulate misclassification risk across their product catalog. Underpaid duties create customs liability. Overpaid duties are unrecoverable without amendment filings. Either outcome is avoidable with scoped, documented classification work before goods are entered.
Export Controls
Export Control Jurisdiction Begins Before the Shipment
EAR jurisdiction attaches to items of U.S. origin regardless of where they are subsequently transferred. EU Dual-Use Regulation applies to transfers out of the EU and to certain intra-company movements. Companies that discover jurisdiction issues at the port have already incurred a compliance failure - one that cannot be corrected retroactively.
Section 232
Section 232 Declarations Must Trace to Process Step
Country-of-production declarations for Section 232-covered metals must be traceable to the smelt and cast step for aluminum, and the melt and pour step for steel and copper. Country of shipment, fabrication, or finishing is not the operative test. Supplier attestations without traceable documentation carry customs audit risk and potential tariff reclassification.
Government Procurement
BAA and BABA Are Parallel Regimes With Different Rules
The Buy American Act (48 CFR Part 25) and Build America, Buy America Act (2 CFR Part 184) apply to different funding streams and use different domestic content thresholds and component cost formulas. Companies working across federal and IIJA-funded projects must track compliance separately under each regime and cannot rely on a single combined analysis for both.
Sanctions
Sanctions Updates Require Continuous Screening
OFAC, BIS, EU, and UN sanctions lists are updated without advance notice. A transaction cleared in one screening cycle may be prohibited in the next. Companies without systematic, recurring screening workflows - covering suppliers, customers, and intermediaries, not just direct counterparties - carry unquantified risk on every transaction they close.
Our Approach

How The 3TGs Helps

The 3TGs works across the full trade compliance stack - from initial HS classification through to ongoing screening workflows - producing documentation that holds up under customs review, customer audits, and regulatory examination. All engagements are scoped, fixed-fee, and documented to audit-ready standard.

01 - Classification
HS Classification Programs
We conduct scoped classification engagements at product and supplier level, producing documented determinations with a clear methodology trail. Every classification is traceable, reviewable, and built to hold up under customs audit - including the ECCN analysis that frequently runs in parallel for the same product set.
02 - Export Controls
Export Control Documentation
From ECCN determination to jurisdiction analysis under EAR and EU Dual-Use Regulation 2021/821, we build the classification documentation, screening records, and process infrastructure that keeps transfers compliant. Classifications are aligned to the Wassenaar Arrangement, with end-use and end-user considerations documented throughout.
03 - Section 232
Section 232 Declaration Programs
We build supplier-level country-of-production declaration programs that trace aluminum, steel, and copper to the smelt, cast, melt, or pour process step. The output is a documented declaration package that supports preferential tariff claims, exclusion applications, and customs audit responses at the correct level of traceability.
04 - Government Procurement
BAA and BABA Content Assessments
We analyze domestic content compliance for government procurement bids under both BAA (48 CFR Part 25) and BABA (2 CFR Part 184), applying the correct threshold and component cost formula for each regime. Where thresholds are not met, we identify and document applicable waiver pathways before bids are submitted.
05 - Screening and Market Access
Denied Party Screening Workflows
We design systematic screening processes across OFAC, BIS, EU, and UN lists, build escalation protocols for potential matches and false positives, and establish recurring monitoring cycles that keep screening current as lists are updated. We also support regulatory market access pre-clearance for new jurisdictions before products ship.

Start the Conversation

Trade compliance that moves with your business

Whether you need an initial applicability assessment, a scoped classification program, or a full trade compliance engagement, The 3TGs scopes to your specific situation. Fixed fees. Audit-ready outputs. No retainer required to start.

Email info@3tgs.org UK +44 20 3996 3623 US +1 209 286 0756 Address 207 Regent Street, Third Floor, Suite 8, London W1B 3HH
HS Classification· Export Controls· Country of Origin· Section 232· USMCA· Buy American Act· BABA· Denied Party Screening· ECCN Classification· Tariff Engineering· EAR· EU Dual-Use Regulation· Wassenaar Arrangement· OFAC Screening· Preferential Origin· HS Classification· Export Controls· Country of Origin· Section 232· USMCA· Buy American Act· BABA· Denied Party Screening· ECCN Classification· Tariff Engineering· EAR· EU Dual-Use Regulation· Wassenaar Arrangement· OFAC Screening· Preferential Origin·