Episode 1: Aircraft Parts and Tariffs: How Duties Rose From $15M to $200M
Former International Trade Compliance Director - Lufthansa
Gail Walentynowicz, LCB, CCS, is a global trade compliance strategist with over 25 years of experience in international trade, customs brokerage, logistics, and supply chain management. Most recently, she served as Director of International Trade Compliance at Lufthansa Technik Component Services, leading import and export compliance in the aviation sector. A Licensed Customs Broker and Certified Customs Specialist, Gail brings expertise in regulatory compliance, risk mitigation, auditing, consulting, and business strategy, helping organizations achieve efficient, cost-effective, and compliant global operations.
Gail Walentynowicz, who led international trade compliance at Lufthansa Technik Component Services, explains how a company moving 2.1 million aircraft components saw US duties go from about $15 million a year to almost $200 million in 2025, and about $100 million after the IEEPA ruling. She covers why general-use parts miss the civil aircraft exemption, classification errors that cost over $50 million, what can be outsourced, and why audits are won with source documents.
5 Key Findings
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The civil aircraft exemption does not cover general-use parts
Valves in 8481 and electronic controllers in 8537.10 also go into trucks, ships and rail cars, so they pay duty. Add steel and aluminum duties and a 3.7% rate on controllers became 53.7%.
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Origin follows the factory, not the supplier
Buying a part from Boeing in the US does not make it American. Boeing and Airbus have components made in China, India, France and elsewhere, and that factory decides which duties apply at entry.
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Small classification errors grow into eight-figure bills
Entering everything under Chapter 88 and claiming US goods returned where it did not apply led to a 2019 CBP audit and a prior disclosure for 2015 to 2017. With interest, the bill passed $50 million.
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You can outsource the work but not the liability
Lufthansa Technik handed brokerage and freight handling to service providers for liability reasons, even though it is not necessarily cheaper. Filing can be outsourced. Responsibility for errors stays with the importer, its board and Gail personally.
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Audits are defended with source documents
A 2019 audit found 14 areas of non-compliance, record keeping among them, and the group later answered more than 75 CF-28 requests. Electronic data counts only when the supplier's own documents stand behind it.
Advice to the Professional
From Gail Walentynowicz
Hire people with real experience. Gail says this work takes five to ten years to learn, so a graduate cannot run a program alone. Keep a trade lawyer and a consultant on speed dial, bring them in early for anything involving Department of Defense contracts, and get more than one opinion before acting on legal advice.
Give clerical work to brokers who already have the systems and staff, then make sure they receive accurate data from you. Keep the paper behind every claim: bills of materials, manufacturer’s affidavits, origin records and vendor details on their own letterhead.
Conclusion
Gail’s numbers show how fast duty exposure can change. The companies that cope best ask compliance early, classify parts by what they are rather than where they end up, and keep documents behind their data.