Chain of Custody, Tariffs, and Reimbursement: The New Realities for Construction Projects

Introduction

Tariffs used to be a complicated backdrop to construction. Now they are front and center.

Steel, aluminum, and copper are carrying 50 percent duties. Trade partners are adding their own tariffs in response. And as of today, de minimis exemptions have been eliminated, which means even the smallest shipments, like a box of screws or copper couplings, come with new costs and new documentation requirements.

For contractors and owners, this isn’t about panic. It’s about preparation. The smart teams are already adapting their budgets, requiring documentation on every submittal, and connecting costs directly to contract administration.

The question isn’t whether volatility will continue, it’s how ready you’ll be when it hits.

Budgets and Documentation Under Pressure

A budget set at design is already outdated by procurement. Add in tariffs and duty changes, and the numbers can shift dramatically by the time materials reach the site. What used to be sourced through contingencies now requires active management.

Small items that once seemed negligible can push your tariff exposure above thresholds faster than expected. That forces tough choices: source domestically, absorb the cost, or request a waiver. None of those choices should be made after the fact.

Every shift in sourcing also creates a ripple in compliance. Certificates of origin, manufacturer attestations, and heat stamps aren’t just paperwork, they are the difference between reimbursement and rejection.

With the loss of de minimis, shipments that never raised flags before now require full documentation. Each invoice, each submittal, and each package becomes part of the chain of custody. If that chain is incomplete, dollars are at risk.

Innovative Project Controls

The new reality in construction is complexity layered on complexity. At ABW Consulting, we use AI to develop tools that cut through the noise and deliver clarity. We help teams adapt quickly when tariffs shift and compliance standards tighten, ensuring projects stay both transparent and reimbursable.

Our framework delivers:

• Clear identification of compliance requirements and the supporting documentation for materials during preconstruction.

• Verified submittals with missing records flagged before review.

• Real-time tariff tracking tied to ship dates and procurement decisions.

• A complete, transparent package prepared for audit and payment.

This is the future of construction, and resilient teams are already planning for it.

From Buy/Build to Tariff Recovery

We’ve been talking for months about Buy America Build America compliance. Tariffs are the next layer. And here’s the connection: the same chain of custody that proves compliance also unlocks tariff reimbursement. When your documentation is airtight, compliance is more than protection, it becomes a strategy for financial recovery.

Compliance is no longer optional. These are risks that can halt payment, delay reimbursement, or increase costs if left unmanaged. And with de minimis gone, even the smallest materials now carry big consequences. The difference between lost funding and protected reimbursement comes down to project controls that anticipate risk, capture documentation, and link compliance to recovery.

At ABW Consulting, we help contractors, owners, and municipalities prepare instead of react. Our project controls, developed with AI, provide clarity in budgets, strength in documentation, and confidence in reimbursement. Because in today’s construction environment, your paperwork is more than paper, it’s your path to payment.