President Trump Announces Steel And Aluminum Tariffs With Exemptions For Canada And Mexico

by Dickinson Wright
Contact

Dickinson Wright

President Donald Trump surprised even his own senior staff on March 1 when he announced his intention to impose global tariffs of 25% on steel and 10% on aluminum. He followed that with statements that there would be no exemptions for any country, even close allies like Canada, and that the tariffs would be in place “for a long period of time”. The President promised to act promptly and carried through with his promise when he signed two presidential proclamations on March 8 imposing tariffs on steel and on aluminum under the authority of Section 232 of the Trade Expansion Act of 1962. But despite earlier statements that there would be no exemptions, the proclamations provide a conditional exemption for steel and aluminum products from Canada and Mexico, substantially softening the impact within the NAFTA region, at least for the time being.

The proclamations also opened the door to other countries that have important security relationships with the United States to obtain an exemption or modification of the tariffs by discussing alternative ways to address threats to U.S. national security caused by steel and aluminum imports from those countries.

Another door was opened to requests for exclusions from the tariffs by affected parties in the United States in cases of insufficient U.S. capacity or in cases involving specific national security considerations. Procedures for exclusion requests are due to be issued by the US Department of Commerce no later than March 18.

What does all of this mean for affected firms? And what should they do now?

Scope and Application of the Tariffs

The tariffs have a broad scope and users of steel and aluminum will need to determine whether they or those in their supply chains are the importers of record of any steel or aluminum products covered by the proclamations. The tariffs will be effective with respect to all goods entered, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on March 23, 2018.

The steel tariffs of 25% cover a wide range of steel products, classified under the Harmonized Tariff Schedule (HTS) 6 digit levels 7206.10 through 7216.50, 7216.99 through 7301.10, 7302.10, 7302.40 through 7302.90, and 7304.10 through 7306.90.

The aluminum tariffs of 10% cover products falling under HTS headings for (a) unwrought aluminum (HTS 7601); (b) aluminum bars, rods, and profiles (HTS 7604); (c) aluminum wire (HTS 7605); (d) aluminum plate, sheet, strip, and foil (flat rolled products) (HTS 7606 and 7607); (e) aluminum tubes and pipes and tube and pipe fitting (HTS 7608 and 7609); and (f) aluminum castings and forgings (HTS 7616.99.51.60 and 7616.99.51.70). The proclamation does not however cover bauxite or alumina feedstock; nor does it cover aluminum waste and scrap or aluminum powders or flakes.

Many of the products covered by the proclamation are also subject to antidumping and countervailing duty orders for steel and aluminum products from China and other countries. Although the proclamations do not address the issue, Section 232 duties will presumably be imposed in addition to any applicable antidumping and countervailing duties.

Commerce’s Section 232 Review

Section 232 of the Trade Expansion Act of 1962 established a rarely-used procedure that grants broad authority to the President to act against imports that threaten to impair national security. The Act does not set out a specific definition of “national security”. It does however contemplate that factors beyond traditional national defense considerations that may weaken the internal economy, such as impact of foreign competition on domestic industries, may be taken into account in the determining whether national security is impaired.

In April 2017, Secretary of Commerce Wilbur Ross initiated investigations under the Act to determine the effect of imported steel and aluminum on national security. Consistent with past practice, the Secretary determined that “national security” for purposes of Section 232 includes “the general welfare of certain industries, beyond those necessary to satisfy national defense requirements, which are critical to minimum operations of the economy and government.”

In his January 2018 reports to the President, the Secretary concluded that the present quantities and circumstances of both steel and aluminum imports were “weakening our internal economy” and threatened to impair national security as defined in Section 232. In the case of steel imports, the Secretary determined that the only effective means of removing the threat of impairment was to reduce imports to a level that should, in combination with good management, enable U.S. steel mills to operate at 80 percent or more of their rated capacity. In the case of aluminum imports the Secretary determined that removal of the threat required a reduction of imports to a level that will provide the opportunity for U.S. primary aluminum producers to restart idled capacity and utilize 80 percent of production capacity.

Commerce’s Section 232 Recommendations and the President’s Proclamations

In the steel investigation, the Secretary made two alternative recommendations to achieve the stated objective. The first was either a global tariff of 24 percent or a worldwide quota of 63 percent of 2017 aluminum import levels, applied on a country and steel product basis. The second alternative was a tariff of 53 percent on imports of steel from Brazil, South Korea, Russia, Turkey, India, Vietnam, China, Thailand, South Africa, Egypt, Malaysia and Costa Rica, with all other countries limited to 100 percent of their 2017 import volumes.

In his steel proclamation, President Trump followed the first recommended alternative of a global tariff, but raised the tariff rate from the recommended 24 percent to 25 percent and excluded Mexico and Canada.

Similarly, in the aluminum investigation, the Secretary made two alternative recommendations to achieve the stated objective. The first was either a global tariff of 7.7 percent or a worldwide quota of 86.7 percent of 2017 aluminum import levels. The second alternative was a tariff of 23.6 percent on aluminum imports from China, Hong Kong, Russia, Venezuela and Vietnam, with all other countries limited to 100 percent of their 2017 import volumes. These five countries were selected because they are the source of substantial imports due to overcapacity or are potential unreliable suppliers or likely sources of transshipped aluminum from China.

President Trump’s aluminum proclamation followed the first recommended alternative of a global tariff, but at 10 percent rather than the recommended 7.7 percent rate. As with the steel tariff, the aluminum tariff will not apply to Canada or Mexico.

Country Exemptions Subject to Further Negotiations

In both the steel and aluminum reports, Commerce Secretary Ross noted that the President could grant an exemption from the tariffs or quotas based on an overriding economic or security interest of the United States. The potential steel exemption would be limited to 100 percent of each exempted country’s 2017 imports to prevent exempted countries from producing additional steel for export to the United States or encouraging other countries to seek to transship steel to the United States through the exempted countries. The potential aluminum exemption would be limited to the amount of prior imports from the exempted country or might exempt all imports from that country. Aluminum exemptions could also be conditioned on a willingness to work with the United States to address global excess capacity and other challenges facing the U.S. aluminum industry. The reports note that an exemption of any country from the tariffs would however require a reduction of any quota or an increase in the tariff applied to non-exempt countries to offset the effect of the exempted imports.

In President Trump’s proclamations, there was no increase in the tariff rates from his previously announced levels to offset the effect of the exempted imports from Canada and Mexico. But the exemption of those countries is not absolute. The President’s proclamations state that Canada and Mexico present a special case considering shared commitments in national security concerns and in addressing excess capacity in the steel and aluminum industries, as well as physical proximity, economic integration, exports of U.S. steel and aluminum to those countries and the close relation of U.S. economic welfare to our national security. Given those factors, the President determined that the necessary and appropriate means to address the threat to the national security posed by imports of steel and aluminum from Canada and Mexico is to continue ongoing discussions and exempt steel and aluminum imports from those countries from the tariff “at least at this time.” Besides this linkage to the current renegotiation of the North American Free Trade Agreement, the proclamations also express an expectation that Canada and Mexico will act to prevent transshipment of steel and aluminum through their countries.

While no other countries were granted exemptions in the proclamations, the President stated that any country with which the United States has a security relationship is welcome to discuss alternative ways to address the threatened impairment of the national security caused by imports from that country. If a satisfactory alternative is agreed, an exemption or modification of the tariff maybe granted.

Exclusions of Products

In his reports to the President, Commerce Secretary Ross recommended an appeal process by which affected U.S. parties could seek an exclusion from the tariff or quota. Exclusions would be granted based on a demonstrated lack of sufficient U.S. production capacity of comparable products or on specific national security considerations. All appeals would be subject to a public comment period and would be led by the Commerce Department in coordination with the Defense Department and other appropriate agencies. In general, appeals would be resolved within 90 days of filing of a completed application and may be granted for a limited period or granted subject to termination if the conditions for the exclusion change. As in the case of country exemptions, the Secretary would consider whether any exclusion requires that the quota or tariff on the remaining products needs to be adjusted to ensure that the stated objectives are achieved.

In President Trump’s proclamations, he authorized relief from the duties for steel and aluminum articles that are not produced in the United States in a sufficient and reasonably available amount or of a satisfactory quality, as well as in cases involving specific national security considerations. Requests for exclusion must be made by a directly affected party located in the United States. Decisions on requests will be made by the Commerce Secretary, in consultation with the Secretary of State, the Secretary of the Treasury, the Secretary of Defense, the United States Trade Representative, the Assistant to the President for National Security Affairs, the Assistant to the President for Economic Policy, and such other senior Executive Branch officials as the Secretary deems appropriate. The proclamations directed the Commerce Secretary to issue procedures for requests for exclusions by March 18.

What to do now

The imposition of Section 232 tariffs will have far-reaching effects not only within industries utilizing steel and aluminum, but also in unrelated sectors that may be the subject of retaliatory action by other countries. Here are some points to review in evaluating the impact of the tariffs and potential actions to mitigate the effect going forward.

-- First, evaluate imported products against the scope of the proclamations.

The products covered by the proclamations are described by reference to their tariff classifications. The affected classifications are indicated above. If the classification of your product is not listed, it will not be subject to the Section 232 tariffs and you can stop reading. If it is listed, the following points may be relevant.

-- Review contracts for the purchase or sale of affected steel or aluminum products.

Contracts may include price adjustment provisions that could be a basis to shift the burden of the tariffs between buyer and seller. Note however that general concepts of force majeure may not be applicable in these circumstances.

-- Consider whether the production process can be modified.

For example, would it be possible to import secondary aluminum production based on recycled scrap which is not the subject of the aluminum proclamation? Or is it feasible to utilize aluminum or steel sourced from the U.S. or an exempt country in the production of downstream products outside the U.S.?

-- Determine whether grounds exist to seek an exclusion.

The grounds for exclusion are limited and any appeal seeking an exclusion will need to be supported by substantial supporting evidence that demonstrates either the lack of sufficient US production capacity of comparable products or national security-based considerations. Commerce’s broad interpretation of “national security” should allow arguments based on a broader set of factors than just national defense.

-- Consider possible movement of sourcing to a country that is not covered by the proclamations, currently only Canada and Mexico

Note that transshipment of non-exempt steel or aluminum products to an exempt country will not avoid the impact of the tariffs and may expose the importer to penalties for attempts to circumvent the tariffs if the actual country of origin is not declared.

-- Investigate whether exports of steel or aluminum products are eligible for duty refund

Under U.S. customs law, ordinary duties paid on imported goods that are later exported or used in goods that are exported may be subject to a refund, referred to as drawback. The rules governing drawback are complex and exports to a NAFTA country are subject to special rules. The potential treatment of Section 232 duties for drawback purposes is not clear. Customs regulations specify certain duties that are and are not subject to drawback. While antidumping and countervailing duties are expressly excluded, the regulations do not explicitly address Section 232 duties. Note also that many supply contracts provide for assignment of drawback rights by the supplier to the purchaser.

-- Monitor retaliatory actions proposed by other countries

Potential retaliation by other countries is expected to be structured to exert political pressure on key members of Congress. Toward that end, high-profile products in sectors unrelated to steel and aluminum that are made in the districts of targeted Congressmen and Senators are potential candidates for retaliatory action. Potential product targets include, among others, steel and aluminum made in the U.S., automobiles, furniture and cherries (Michigan), bourbon (Kentucky), motorcycles and cranberries (Wisconsin), citrus products (Florida, California), retail products such as clothing, and soybeans and other agricultural products. These actions could be caught up in challenges at the World Trade Organization and in the courts. Lobbying will be intense.

 

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Dickinson Wright | Attorney Advertising

Written by:

Dickinson Wright
Contact
more
less

Dickinson Wright on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at www.jdsupra.com) (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.