About this time last year, there was quite a bit of speculation about the impact of the Trump administration’s tariffs. As we have grown to expect, there was a wide “spectrum of speculation,” from those that expected a collapse of our society to those that thought they would bring about a miraculous return of manufacturing to the United States. Nothing so dramatic has occurred, of course, but at least now we have some trade and price data to review to determine what has really happened since the tariffs were implemented. This brief analysis will narrowly focus on specific products used in the grain milling processes and use a simple measure — effective tariff rates — to come to some conclusions.

Let’s begin with a brief review of the Harmonized Tariff System codes (HTS) that describe milling equipment. These are the “10-digit” codes that provide the highest level of specificity and are focused primarily on flour production and grain cleaning and milling machines and parts:

  • 8437.80.0010: Flour mill and grain mill machines, generally from original equipment manufacturers (OEM)
  • 8437.80.0090: Primarily grain cleaning machines and related equipment for grain processing, and generally OEM
  • 8437.90.0010: Parts of flour and grain milling machines that support 8437.80.0010 and .0090 above, and generally OEM
  • 8437.90.0090: Other parts for flour and grain milling, but usually generic equipment and not generally OEM. This is a catch-all category that represents a broad spectrum of manufacturers and can include generic and refurbished equipment.

The top two codes, HTS 8437.80.0010 and 8437.80.0090, describe capital improvements in milling and include, for the most part, complete OEM machines for milling and cleaning. The international trade is dominated by manufacturers in Europe, particularly Switzerland, Spain and Italy, with importers paying a nominal tariff of 15% in 2025.

The “parts of” codes, HTS 8437.90.0010 and .8437.90.0090, are generally for replacement of parts that wear out in use and are regularly replaced on specific timetables. The 8437.90.0010 describes OEM of primarily European origin, while 8437.90.0090, which includes a much wider distribution of products, and generally not OEM products, is dominated by imports from China, Mexico and Canada.

Regarding the year-to-date comparisons, the table below shows the imports by product, as defined by the tariff code categories, from 2024-2025. The reduction in imports for 2025 was driven by a sharp decline in import values of complete OEM milling machines, by 79.4%. Overall customs value of all these products fell by 33.2%, as seen below in Table 1.

Effective Tariffs Consider Both Trade Value and Duties Paid

One of the best ways to review the impact of tariffs on these products is a measure that incorporates the import value (the declared customs values, as in Table 1 above) and the actual tariffs paid by importers. It is simply the total duties paid divided by their value. With effective tariffs, we can aggregate all collected tariff duties together — in all the authorities used by the Trump administration — and relate them to the actual trade value.

The average effective tariffs for all these products ranged between 2% and 3% throughout 2024, as seen below. The chart shows that in March 2025 they rose quickly from 3% to more than 20% by October, based on the application of the Trump administration’s tariffs that included the Section 301 tariffs on imports of European manufacture, and the recently rescinded International Economic Emergency Powers Act (IEEPA) tariffs on China. Regarding monthly import values, these fell from a high of $15.5 million in April 2024 to about $4.1 million in November 2025, as seen below.

Tariff Arbitrage:An Unintended Consequence?

Beginning in 2025, tariff rates grew sharply for all these products, except for those that could meet the United States-Mexico-Canada Agreement (USMCA) requirements for rules of origin and related restrictions. For the top suppliers of the OEM products, which originate primarily from Spain, Italy and Switzerland, these products faced nominal tariff rates of 15% from the Trump administration’s Section 301 trade authority.

The tariff impacts reveal a preference to avoid tariffs by focusing on importing from Canada and Mexico. As seen in Table 2 below, imports from Mexico and Canada were flat for 2024-2025. U.S. imports of milling machines and parts from Mexico and Canada increased for two of the four product codes, with the largest percentage increases in 8437.80.0010 (complete OEM milling machines) and 8437.80.0090 (complete grain OEM cleaning machines). Imports under the other tariff codes declined slightly.

*We can expect importers to focus their purchasing decisions on U.S.-produced and USMCA-compliant machines and parts. This is a rational response to the tariffs on European and Chinese equipment. In 2024, the cost of USMCA compliance was not an important issue for OEM products since the tariffs for EU- and Swiss-origin machines and parts were also zero.

In preparation for the upcoming review of the USMCA agreement that begins in July, this study provides some insights. If the USMCA is maintained as is, we can expect milling machine and parts importers to continue this kind of tariff arbitrage, or “tariff-hacking,” to reduce tariff payments. It will accelerate in 2026, since EU- and Swiss-origin products are subject to the new 10% Section 122 tariffs — bringing their tariff burden to 25% — while USMCA-compliant products remain tariff-free.

Brian Goggin is a seasoned agricultural economist and former senior official at the U.S. Department of Agriculture’s Foreign Agricultural Service (FAS). His career spans more than three decades across international trade, food assistance and agricultural development. He now advises governments, NGOs and private‑sector clients through his consultancy, Goggin & Associates, based in Virginia. He can be reached at briangoggin52@gmail.com.