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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

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

Arent Fox's Advance Look at Hot Button Trade Issues For 2021

Looking towards 2021 and a new Administration, Arent Fox's International Trade & Investment group has prepared a series of primers on six key areas that can impact your business: The Biden Transition, Special Tariffs,...more

GSP Reauthorization Up in the Air

Our final section returns to trade policy with three narrower but equally important articles – the first in regard to US renewal of GSP benefits and the tension between the Biden administration's promise to protect US workers...more

Wait Is Over: USMCA Border Enforcement Begins

US tariffs are applied at the time of import and so the elevated role played by US Customs and Border Protection should not be underestimated. While the Customs section begins with the analysis “The Wait Is Over: USMCA Border...more

Tracking the Biden Trade Transition and Transition Teams

This is Washington and so we start and end with US trade policy. Our team is tracking the Biden Transition, starting with the introduction of Katherine Tai, nominee for the next US Trade Representative....more

Origin Verification Procedures: Similarities to the NAFTA in the USMCA

The USMCA permits CBP to verify whether a good entered with a claim for preferential tariff treatment qualifies as originating by: (1) Written request or questionnaire to the importer, exporter, or producer of the good...more

New Analysis: CBP Takes First Step Towards Full USMCA Implementation

In an April 20, 2020 message to the trade community, US Customs and Border Protection (CBP) released the long-awaited United States–Mexico–Canada Agreement (USMCA) Interim Implementing Instructions (CBP Instructions). This...more

New Textile and Apparel Rules for the USMCA

The USMCA textile and apparel rules of origin are generally based on the “yarn forward” rule, which requires the formation of the yarn (spinning or extruding) and all processes following yarn formation to occur in the USMCA...more

CBP Instructions for USMCA Recordkeeping

Any importer who claims preferential tariff treatment under the Agreement for a good imported into the United States from a USMCA country must keep the following documentation for a period of no less than five years from date...more

Who Can Make a USMCA Certification?

The USMCA does not require the use of CBP Form 434, as there is no prescribed format for certificate of origins under the USMCA. These certifications are to be completed by the exporter, producer, or importer certifying that...more

New Automotive Origin Rules for the USMCA

Appendix I, Automotive Rules of Origin and Procedures, to the CBP Instructions provides guidance on the USMCA automotive rules of origin by incorporating the appendix to Chapter 4 of the USMCA Implementation Act (Automotive...more

Importing Under COVID-19: Companies Suffering Financial Hardship Receive 90-Day Reprieve to Pay Duties

Effective yesterday, the US government is making available a temporary 90-day postponement of certain import payment deadlines for companies and individuals experiencing “significant financial hardship” due to the economic...more

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