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As the (Customs and Trade) World Turns: September 2024

Welcome to the September 2024 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

USTR Requests Comments on Proposed China Section 301 Tariff Modifications, Including Up to 100% Increases and a (Limited) New...

Following last week’s long-awaited report on the statutory four-year review of the Section 301 tariffs, the Office of the United States Trade Representative (USTR) issued a Federal Register notice on the proposed...more

In a Single Action, DHS Adds 26 Entities to the UFLPA Entity List – Importers and Textile Companies Should Expect More Supply...

In an unprecedented, but anticipated, move last Friday, the US Department of Homeland Security (DHS) expanded the Uyghur Forced Labor Prevention Act (UFLPA) Entity List with the addition of 26 new Chinese textile companies in...more

As the (Customs and Trade) World Turns: March 2024

Welcome to the first issue of “As the (Customs and Trade) World Turns,” our new monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

United States-China Trade Updates to Ring in the New Year

Recent government actions illustrate that US-China trade relations will continue to be a focus as the United States enters an election year. We’ll continue to monitor developments regarding Section 301 tariffs — will they...more

China Import Duties Here to Stay? CIT Upholds Section 301 Tariffs

On March 17, 2023, the Court of International Trade upheld the legality of Section 301 tariffs on Chinese origin products included on the Office of the US Trade Representative’s List 3 and List 4A, however the case will...more

USTR Launches “Phase 2” of Four-Year China Tariff Review

As detailed in our previous alerts, the Section 301 statute (19 USC § 2417), includes a “termination provision” stating that the Section 301 tariffs will terminate after a period of 4 years, unless a representative of the...more

Opportunity for Companies to Comment on Uyghur Forced Labor Prevention Act Enforcement From January 24-March 10, 2022 

On January 24, 2022, The US Department of Homeland Security (DHS), on behalf of the Forced Labor Task Force (Task Force), published a Federal Register Notice to request public comments regarding the implementation of the...more

Uyghur Forced Labor Prevention Act Becomes Law: Importers Must Prepare for Increased Enforcement and Detentions at the Border

US importers should participate in the Task Force's comment and hearing process to flag due diligence challenges and formulate the strategy to enforce the import prohibitions. What to Know - Effective June 21, 2022, 180...more

Biden Administration Unveils Long-Awaited Process to Reinstate China Product Exclusions

On October 5, 2021, the United States Trade Representative (USTR) announced the Biden Administration’s highly-anticipated China trade policy, including a comment request process that will be used to determine whether Section...more

WorldSmart: How Businesses Can Mitigate Risk of Forced Labor in Their Supply Chains  [Audio]

In the latest WorldSmart podcast, International Co-Chairs Hunter Carter and Malcolm McNeil sit down with Customs & Import Compliance Partner Angela Santos to discuss the global forced labor problem, how forced labor can...more

CBP Issues WRO on Solar Materials Made By Chinese Companies

Forced Labor Enforcement Continues to Escalate as Commerce Restricts Exports to 5 Additional PRC Companies - Withhold release order was issued that will prohibit imports of products produced in whole or part from silica...more

Meyer Decision: First Sale Remains a Savings Avenue for Importers

First sale appraisement currently remains a legally viable duty savings avenue, including for transactions with vendors in NMEs. On March 1, 2021, Judge Thomas J. Aquilino, Jr. of the US Court of International Trade (CIT)...more

CBP Aggressively Investigating QSP Imports From Malaysia Through EAPA

CBP is leveraging the EAPA to target various industries based on a suspicion of evading AD/CVD duties by aggressively scrutinizing imports potentially covered by an AD/CVD order. On March 4, 2021, US Customs and Border...more

New Bills in Congress May Lead to Region-Wide Ban on Goods from Xinjiang Region of China

Review Your Supply Chain and Establish Compliance Plans Because Forced Labor Laws are Here to Stay - If passed, these bills will grant US Customs and Border Protection authority for a region-wide WRO enabling the agency...more

CBP Issues FAQs on Xinjiang Forced Labor, Apparel & Tomato Importers Due Diligence Required to Avoid Exclusion of Goods

Companies in the fashion, luxury, and agricultural spaces should take action in response to the forced labor supply chain due diligence requirements Customs recently announced in connection with withhold release orders (WRO)...more

CIT Assigns Panel for 301 Litigation on US Imports From China — Update on Options to Recover China Tariffs

If your company has paid Section 301 duties on products of China included in List 3 and List 4(a), there may still be an opportunity to file a suit to potentially recover duties paid. On February 5, 2021, the US Court of...more

CBP Begins 2021 With Expansive New Enforcement Against Forced Labor

Just two weeks into CY 2021, US Customs and Border Protection (CBP) is expanding its enforcement efforts against forced labor in China. This follows months of increasing pressure from labor and human rights groups and...more

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