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
3/5/2021
/ China ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Economic Sanctions ,
Enforcement Actions ,
Forced Labor ,
Global Magnitsky Act ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
Proposed Legislation ,
Securities and Exchange Commission (SEC) ,
Supply Chain ,
Tariff Act of 1930 ,
Withhold Release Orders (WROs)
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
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
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
1/5/2021
/ Audits ,
Automotive Industry ,
C-TPAT ,
Certifications ,
China ,
Corporate Counsel ,
Customs and Border Protection ,
Enforcement Actions ,
EU ,
Federal Maritime Commission ,
Forced Labor ,
Free Trade Agreements ,
NAFTA ,
Tariffs ,
UK ,
United States-Mexico-Canada Agreement (USMCA) ,
Withhold Release Orders (WROs)
The Department of Homeland Security (DHS) blocked imports of cotton products from a major Chinese state-owned firm in the Xinjiang Uighur Autonomous Region (XUAR) on December 2, saying the company uses forced labor of ethnic...more
The US Government has taken action recently to step up enforcement against forced labor.
As particular regions come under increased media scrutiny, the issue has renewed interest in Congress, which is considering several...more
10/26/2020
/ Child Labor ,
China ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Economic Sanctions ,
Forced Labor ,
International Emergency Economic Powers Act (IEEPA) ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Supply Chain ,
Tariff Act of 1930 ,
U.S. Treasury ,
US Department of State ,
Withhold Release Orders (WROs)
On September 14, 2020, the Department of Homeland Security (DHS) through Customs and Border Protection (CBP) issued new withhold release orders (WRO) aimed at entities involved in the importation, downstream manufacturing,...more
As previously reported, on July 14, 2020, the President signed Executive Order 13936 on Hong Kong Normalization. As a result, CBP has issued a new marking requirement for goods that are produced in Hong Kong which enter...more
There is a risk that garments made from cotton produced by XPCC could be subject to a Customs and Border Protection withhold release orders.
Fashion and luxury goods companies need to be concerned about the recent...more
8/26/2020
/ China ,
Customs and Border Protection ,
Economic Sanctions ,
Entity List ,
Exports ,
Forced Labor ,
Imports ,
Retailers ,
Supply Chain ,
U.S. Commerce Department ,
U.S. Treasury
Under the TFTEA, CBP has taken an increasingly enforcement-minded posture to prevent and penalize the importation of goods produced using forced labor into the United States.
On August 13, 2020, CBP announced that it had...more
8/20/2020
/ China ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Forced Labor ,
Importers ,
New Guidance ,
Risk Assessment ,
Risk Mitigation ,
Supply Chain ,
Trade Facilitation and Trade Enforcement Act ,
Withhold Release Orders (WROs)
Because of the time needed to mark, pack, and ship goods from Hong Kong to the US, it is imperative that importers act quickly to ensure compliance with this new requirement.
As reported previously and as a result of the...more
8/12/2020
/ Ad Valorem Tax ,
China ,
Compliance ,
Customs and Border Protection ,
Executive Orders ,
Exports ,
Federal Register ,
Goods or Services ,
Hong Kong ,
Importers ,
Imports ,
Tariff Act of 1930
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
4/24/2020
/ Cross-Border Transactions ,
Customs and Border Protection ,
Exports ,
Free Trade Agreements ,
Imports ,
Mexico ,
NAFTA ,
Tariffs ,
Trade Preferences Rules ,
Trade Relations ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
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
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
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
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
The Federal Emergency Management Agency has left many important questions blowing in the wind as a result of a Notification of Exemptions action published for public inspection on Friday, April 17, 2020. The final action will...more
News reports show that because of the spread of the novel coronavirus (COVID-19) pandemic, hospitals and medical facilities are overwhelmed and threaten to strain the healthcare system.
Masks, ventilators, and gowns are...more
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 Department of Homeland Security (DHS) recently released a Department-wide strategy to combat human trafficking, child exploitation and forced labor in the supply chain.
The strategy will build on current efforts on...more
Last week, the Trump Administration announced a plan to crack down on the sales of contraband and counterfeit goods online. The steps will affect a number of parties in the supply chain from importers and sellers to customs...more
2/6/2020
/ Best Practices ,
Corporate Counsel ,
Counterfeit Goods Regulation ,
Counterfeiting ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
E-Commerce ,
Executive Orders ,
Imports ,
Intellectual Property Protection ,
Pirating ,
Section 321 ,
Supply Chain ,
Trump Administration
On January 15, 2020, President Trump and Chinese Vice Premier Liu Hu signed the long-awaited US-China Trade Agreement after nearly two years of a trade war that has resulted in crippling tariffs on almost $500 billion worth...more
1/24/2020
/ China ,
Customs and Border Protection ,
Exports ,
Imports ,
Section 301 ,
Supply Chain ,
Tariffs ,
Trade Agreements ,
Trade Relations ,
Trade Wars ,
Trump Administration ,
US Trade Policies