Redesign your product under the 15% metal line.
Since April 2026, a listed product under 15% steel, aluminium or copper by weight pays no Section 232 metals duty, and one over it can pay 25-50% on its full value. Cliffhanger redesigns yours to land under the line.
- Be first in line
- One email, when we open
- No spam
- Parsing BOMs and spec sheets0%
- Estimating metal weight sharesQueued
- Tracking every annex changeQueued
- Searching CBP rulingsQueued
- Drafting ruling requestsQueued
A redesign foundry that legally moves products under the 15% metal tariff line.
A product on the Section 232 metals lists now pays duty on its full value, unless metal is under 15% of its weight. Cliffhanger’s agents find the products closest to that line, partner designers make a genuine change, and the new design goes to CBP for a binding ruling before the first container ships.
- Step 01
Measures each product’s distance to 15%
From spec sheets and BOMs, agents estimate the metal share by weight, the gap to the line and the duty at stake per container.
- Step 02
Briefs a genuine redesign
A redesign brief for a vetted industrial-design or composite partner: less metal, the same safe and useful product.
- Step 03
Asks CBP before the first container
A factory change order and a draft binding-ruling request, signed off by a licensed customs broker or trade attorney.
Built for US importers and DTC brands of mixed-metal goods.
The under-15 SKU scan
Metal share by weight, distance to the line and duty at stake per container, for each SKU you send.
A redesign brief and a partner
A brief matched to a vetted industrial-design or composite partner, aimed at a real change that stays safe.
Change order and ruling request
The factory change order plus a draft CBP binding-ruling request, so the new design is classified before it ships.
First up: We send importers on the Section 232 lists the ‘distance to 15%’ of their three best-selling products, worked out from public spec sheets.
The world just changed.
What changed, and where it was reported.
A proclamation moved Section 232 metals duties to full customs value. Listed derivatives are hit only if metal is at least 15% of the article’s weight, at 50% or 25% tiers.
BDOProclamation 11032, in force from 2026-06-08 to 2027-12-31, re-tiered the derivatives again and, per trade advisories, kept low-metal products excluded.
C.H. RobinsonTariff engineering is lawful when the change is genuine (US v. Citroen, 1912; Merritt v. Welsh, 1881), but courts reject artificial changes made only to dodge duty (Heartland By-Products).
GingerControl
One person and 4 AI agents.
The agents, all day
- Parsing BOMs and spec sheets
- Estimating metal weight shares
- Tracking every annex change
- Searching CBP rulings
- Drafting ruling requests
What a person does
A licensed customs broker or trade attorney signs off every ruling request and classification opinion. Partner engineers check each redesign is safe and works (UL, CPSC), a partner lab weighs real samples, and a person signs every partner contract.
Is this legal?
Yes, when the change is genuine. Courts have accepted real redesigns for over a century, but CBP can reject a change made only to dodge duty, so every brief starts from what the product has to do.
Can you promise a ruling?
No. A licensed broker or trade attorney signs each request and CBP decides. We never promise the result.
What if the rules change again?
They might: the annexes have changed every few months. We track every change and CSMS message and tell you when a redesign is at risk of being outrun.
Be first through Cliffhanger’s door.
- Be first in line
- One email, when we open
- No spam