We’re now a month out from “Liberation Day,” the Trump administration’s launch to restructure global trade by increasing tariffs on imports into the US to levels not seen in over 100 years.  While “reciprocal tariffs” for most countries are currently on “pause” until July 9^th, 10% across-the-board tariffs remain in place for many countries, with tariffs against Chinese products currently at or greater than 145%. These tariffs create interconnected challenges requiring systematic attention.

While it is inevitable that some buyers in tariffed countries will shift their purchases from U.S. suppliers to avoid the tariffs, it is just as expected that many U.S. food companies will shift their purchasing to domestic supply chains to save costs. And as those food companies move away from expensive imports, domestic growers and manufacturers may experience demand surges, creating a fundamental safety challenge where production pressures increase faster than the food safety infrastructure.

Increased Capacity Leads to Increase Risks

Processing facilities operating beyond designed capacity may compromise existing food safety management systems. Rapid workforce expansion typically outpaces adequate food safety training, increasing food safety handling risks, while quality assurance programs designed for standard production volumes become stretched if production volumes increase substantially. Companies expanding domestic production should conduct comprehensive risk assessments before increasing capacity, with particular attention to known or reasonably foreseeable hazards that may be compromised under accelerated production schedules.

Supply Chain, Traceability and Recording Keeping Concerns

The economics of high-value imported foods like avocados, mangoes, meat, and specialty cheeses will fundamentally change under the tariff structure. When legitimate import channels become prohibitively expensive, sophisticated black market operations emerge that specifically target food supply chains. These operations present unique food safety hazards, as products may be transported without temperature monitoring or verification; traceability documentation is often falsified, eliminating the ability to conduct recalls; and products may be “washed” through multiple intermediaries to obscure origin.

Food Fraud

Product substitution represents perhaps the most immediate economically motivated adulteration (EMA) risk in this environment. When high-value ingredients face substantial tariff increases, suppliers may substitute lower-value alternatives without disclosure. For example, we might see conventional produce falsely labeled as organic to command premium pricing that offsets tariff costs. Similarly, expensive oils like extra virgin olive oil might be diluted with cheaper oils while maintaining premium labeling and pricing. Food companies will need to enhance receiving processes specifically to identify potentially diverted products by implementing enhanced documentation verification, supplier approval processes, and potentially laboratory testing to verify product authenticity and safety.

Companies facing margin compression commonly target operational efficiency measures that inadvertently compromise food safety systems through extended production runs between sanitation cycles allowing biofilm formation and harborage point development, reduced preventive maintenance increasing equipment failure risks during production, and reformulation to extend shelf-life requiring additional validation.

Similarly, economic uncertainty may cause some international and domestic food companies to delay capital investments in food safety-related infrastructure, continuing to use equipment that may be past its useful lifespan or more difficult to clean and maintain, leading to increased microbiological or physical hazards during production.

While most food items from Mexico and Canada that meet the United States-Mexico-Canada Agreement rules of origin remain tariff-free, the Canadian supply chain realignment (due to long-term uncertainty around US policies) may represent a more than temporary adaptation—it may reflect a fundamental restructuring of North American food trade that will have persistent effects even if tariffs are eventually removed. New supplier relationships will need to be established and a holistic assessment of food safety programs should be conducted as part of new supply identification and onboarding processes. Canadian companies may approach these changes as permanent structural adjustments requiring comprehensive revisions to supplier verification programs rather than as temporary workarounds. In preparing for these challenges, companies should implement a structured approach that includes:

• Conducting systematic vulnerability assessments of supply chains to identify specific points where tariff pressures create food safety risks.
• Developing enhanced verification processes for the specific risks of rapidly onboarded new suppliers.
• Revalidating critical control points under new operating conditions.
• Implementing targeted testing programs for high-risk imported products potentially subject to black market diversion.

In these uncertain times, navigating the complex intersection of international trade policy and food safety requires specialized expertise that combines regulatory knowledge, technical assessment capabilities, and strategic planning.

Editors Note: this article was originally published March 12, 2025 and was updated May 5, 2025