I work in a different industry (but still manufacturing) and it's mind boggling how much brain power and employee time is devoted to "correctly" interacting with the customs and importing system. I wouldn't be surprised if 30% to 40% of the total man hours at some companies are spent directly or indirectly related to the HTS system. This includes products built in North America - you still need to do a huge amount of accounting to show that you're meeting [one of the] the definition[s] of substantial transformation.

I can't really frame this as a global criticism either, the system has clearly evolved around the fact that importers of cheap overseas goods are constantly trying to game the rules to pay lower tariffs than competitors (see Ford with the Transit Connect).

The most frustrating part is political, and two parts:

* US politics have destabilized so much in the last decade that the rules are constantly changing, exceptions being granted and taken away, etc. This has dramatically increased the amount of brain share devoted to tariff engineering rather than product engineering.

* The tariff exclusion process (especially the recent Section 301 tariffs) is heavily lobbyist based. Small players are basically crushed while larger competitors are granted exclusions.