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232 Investigation of Pharmaceuticals: Potential Tariffs and Tight Comment Deadline

Effective April 5, the United States imposed a 10% baseline tariff on imports from nearly all countries, excluding products from Canada and Mexico, and those products contained in the Harmonized Tariff Schedule of the United...more

Commerce Initiates 232 Investigation on Semiconductors and SME, Paving the Path for Potential Tariffs

On April 1, the US Secretary of Commerce initiated a section 232 “national security” investigation, “to determine the effects on national security of imports of semiconductors, semiconductor manufacturing equipment (SME), and...more

New 25% Auto Tariffs Announced Under Section 232: What Importers and Auto Suppliers Need to Know

On March 26, the Trump Administration announced a sweeping new trade action: a 25% tariff on imported automobiles and certain automobile parts from all countries, under Section 232 of the Trade Expansion Act of 1962....more

The USMCA Advantage: Avoiding the 25% Tariff for Your Company’s Bottom Line

The latest US tariff actions have rattled North American trade, but businesses that understand the United States-Mexico-Canada Agreement (USMCA) have a significant advantage....more

Trump Tariff Headlines – From Talk to Action

As of this writing on February 3, the president’s long awaited new tariffs have been officially announced via Executive Orders (EOs) from the White House for Canada, Mexico, and China. They confirm media reports of new 25%...more

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

Preliminary Antidumping Duties Go In Effect on Imports of Products Containing Aluminum Extrusions From Multiple Countries

As a follow up to our March 1 alert on Imported Products Containing an Aluminum Extrusion Part or Any Extruded Aluminum, the US Department of Commerce (DOC) has announced the preliminary antidumping dumping duties affecting...more

US Trade Rules Playing Larger Role for Manufacturers of Trucks and Truck Parts Tariffs and Geopolitics: Dual Challenges...

Trade tensions between Washington and US trading partners, notably China, have complicated many supply chain decisions — what to buy, from where, made by whom, and at what tariff cost. Recent statements from senior Biden...more

Re-Thinking Strategies for Classification Challenges Ahead for New EV Technologies

Application of US trade laws rely on the proper classification of the imported product. It triggers tariff preference benefits when properly applied, and enforcement scrutiny when not....more

Washington’s Focus on the Electric Vehicle Supply Chain in 2023

If a picture is worth a thousand words, the “photo-op” of the president test driving Ford’s new electric F-150 in May of 2021 was the burning image that foretold the US policy direction for the electric mobility...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

The End of China Tariffs? USTR Four-Year Review on the Horizon

The US Trade Representative (USTR) has issued a Federal Register notice to initiate the first step of a statutory review process to determine whether China tariffs issued pursuant to Section 301 of the Trade Act of 1974...more

Washington Urges Canada Not To Pursue a Digital Services Tax, Warns of Retaliatory Tariffs on Imports From Canada

In December 2021, Canada announced plans to impose a digital services tax, or DST. A few days later, the Office of the US Trade Representative (USTR) expressed opposition indicating that if Ottawa were to pursue this plan,...more

USTR Tai Takes Control of Trump Tariffs: Some Section 301 Tariffs Suspended and Others May Be Implemented on Six Countries With...

USTR is soliciting comments and has scheduled hearings regarding the potential imposition of Section 301 tariffs of up to 25% in response to the Digital Services Tax adopted by Austria, India, Italy, Spain, Turkey, and the...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

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

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

COVID–19 Duty Deferral Option Withdrawn by CBP Amidst Continued Requests by Congress for Such Action

After initially accepting requests from importers in light of the novel coronavirus (COVID–19) pandemic to defer payment of duties—a means of relief that the Trump Administration had reportedly been considering—US Customs and...more

COVID-19 Impact on Section 301 China Tariffs: USTR Excludes Some Healthcare Products, Solicits Requests to Exclude More

On Wednesday, March 25, 2020, the U.S. Trade Representative (USTR) published a Federal Register notice requesting comments on the removal of Section 301 tariffs from Chinese medical-care products—including those that have...more

COVID-19 Trade Update: Potential Duty Payment Deferrals and Border Shutdowns

The coronavirus (COVID-19) is affecting all elements of society – with changes coming every day. These changes include the import, trade and transportation sectors. We will keep you updated on these changes as they occur....more

The Time is Now: Here’s the Latest on Avoiding China Tariffs

As part of the Trump Administration’s longstanding “trade war” with China over Chinese government trade practices related to technology transfer, intellectual property, and innovation that the Administration has determined to...more

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