admin | 21 October 2026

Customs & Taxation / Import & Export

A newly transmitted customs circular changes the landed-cost calculation for certain imports of corrugating medium, but the measure is narrower than its tariff headings may initially suggest. Bureau of Customs CMC No. 237-2026 circulates Department of Trade and Industry DAO No. 26-02, series of 2026, imposing a definitive general safeguard duty on covered corrugating medium under AHTN 2022 subheadings 4805.12.00, 4805.19.10 and 4805.19.90. The order was published on 27 September 2026 and states that it took effect upon publication.

The decisive product distinction is that the order excludes recycled corrugating medium. The covered description refers to corrugating medium manufactured not from recycled material, with a grammage between 90 and 175 grams per square metre and Ring Crush Test values within the specifications stated in the order. This means an AHTN code is necessary but not, by itself, sufficient to settle liability. Composition, grammage and technical specifications must agree with the declaration and supporting product literature; a vague invoice description such as “paper roll” leaves a classification and coverage question unresolved.

For covered shipments, the measure is a specific duty charged by weight rather than an ad valorem percentage. The schedule is ₱3,652 per metric ton during the first year, ₱3,287 per metric ton during the second year and ₱2,958 per metric ton during the third year. The order states a three-year period from 27 September 2026 through 26 September 2029. The declining schedule is commercially significant because the shipment’s relevant import date, not merely the purchase-order date, may determine which annual amount applies.

Worked example. Assume a first-year importation contains 20 metric tons of covered non-recycled corrugating medium from a non-exempt origin. The safeguard component is 20 × ₱3,652, or ₱73,040. That figure is not the entire border cost: the ordinary customs duty, import VAT and other lawful charges must still be calculated under the applicable valuation and tax rules. Importers should therefore add a separate safeguard line to the landed-cost model instead of blending it into the supplier’s unit price or treating it as a substitute for the regular tariff.

Country of origin is the second control point. Annex A of the DTI order lists developing countries and separate customs territories excluded from the definitive measure. Exclusion is not established by the port of loading, the seller’s address or the currency on the invoice. The importer should identify the actual country of origin and retain competent origin evidence that corresponds with the goods. If an exemption is claimed, the declaration file should show why the shipment falls within the annex and should be consistent with the invoice, packing list, transport document and product specifications.

The measure must also be distinguished from the earlier provisional cash-bond proceeding involving recycled corrugating medium. The present order’s text records that prior bonds on recycled corrugating medium entering or withdrawn from warehouses for consumption beginning 8 October 2025 were to be returned following termination of that proceeding. A refund instruction for those earlier recycled-material bonds does not erase the new definitive duty on covered non-recycled material. Mixing the two proceedings can lead either to an unnecessary payment or to an unsupported non-payment position.

Before arrival, the importer and its independent customs broker should reconcile five items: the exact AHTN subheading, fibre composition, grammage, Ring Crush Test specification and origin. Supplier declarations and laboratory or mill specifications should use the same commercial description as the purchase documents. Where a contract was priced before the order, the parties should also review who bears newly imposed import charges under their agreed Incoterm and tax clauses; customs liability and contractual cost allocation are related questions, but they are not the same question.

The broader lesson is that trade remedies operate at the intersection of technical product identity and legal timing. A tariff database search may show the ordinary rate, yet a safeguard measure can add a separate, time-limited charge for a defined product and origin. Importers of paper and packaging inputs should update item masters and purchasing controls now, then monitor later BOC and DTI issuances for amendments or implementation guidance. The defensible position is the one supported by the operative order, the shipment’s actual specifications and a complete origin record—not by a shorthand description of the goods.

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