U.S. International Trade Commission
On April 2, 2025, President Trump announced a new 10% global “reciprocal” tariff on U.S. imports from all countries, with higher tariff rates for a large number of countries that range from 11 to 50% ad valorem (the...more
U.S. Customs and Border Protection (CBP), under the U.S. Department of Homeland Security, published a Notice of Proposed Rulemaking on Jan. 21, 2025 (Jan. 21 NPRM), narrowing the scope of the administrative exemption under...more
On January 14, 2025, U.S. Customs and Border Protection (CBP) issued a proposal to alter its regulations regarding de minimis imports. Section 321(a)(2) of the Tariff Act of 1930 currently authorizes duty exemptions, as well...more
On November 25, 2024, President-elect Trump announced that he would impose an additional 10% tariff on China, and 25% tariffs on Mexico and Canada, garnering considerable attention both for their potential to reshape the U.S....more
In today’s complex global marketplace, businesses are increasingly confronted with the challenges of supply chain disruptions, rising costs, and fierce competition—all exacerbated by trade remedy tariffs. While many of these...more
U.S. Customs and Border Protection (CBP) issued a forced-labor finding against Kingtom Aluminio S.R.L. (“Kingtom”), a Chinese-owned aluminum extruder in the Dominican Republic. CBP determined that aluminum extrusions, profile...more
[Written by: Mike Smiszek, Senior Trade Advisor, Braumiller Consulting Group] Several tribunals and courts were established at various periods of America’s history to resolve trade-related litigation, both at the trial and...more
There is an increasing demand to do something about the de minimis shipments under §321 of the Tariff Act (19 USC 1321). What is §321? Let’s take a look at some of the text from Title 19: “The Secretary of the Treasury,...more
In February 2024, Customs and Border Protection (CBP) began taking a new approach to Uyghur Forced Labor Prevention Act (UFLPA) enforcement—questionnaires. Once again, the solar industry is among the first targets, vanguards...more
On July 2, 2024, the Federal Trade Commission announced a “refreshed version” of the agency’s Complying with the Made in USA Standard guidance document. The refreshed guidance document includes, without limitation, updated...more
From Wikipedia: De minimis is a Latin expression meaning “pertaining to minimal things”, normally in the terms de minimis non curat praetor. (“The praetor does not concern himself with trifles”) or de minimis non curat lex...more
Telemedicine Owner Pleads Guilty to $136 Million Medicare Fraud - A licensed nurse practitioner in New Jersey, Jean Wilson, pleaded guilty to conspiracy to commit health care fraud and wire fraud. According to court...more
On December 8, 2023, Senators Bill Cassidy and Sheldon Whitehouse introduced a new version of the Customs Modernization bill to amend the Tariff Act of 1930. The new proposal comes over two years after Senator Cassidy...more
In 2022, Customs and Border Protection (“CBP” or “Customs”) processed $3.35 trillion in imports, issued 2,121 penalties, and collected $19.3 million from penalties and liquidated damages. Section 1592 of the Tariff Act of...more
The fight against forced labor in trade is not a new concept. For decades, the United States has banned the importation of goods produced with forced labor through the U.S. Tariff Act of 1930 (“Tariff Act”). Section 307 of...more
Companies invest in securing supply chains from disruption by economic and political factors, financial difficulties of suppliers, and, as we’ve recently seen, global pandemics. For those either importing goods or relying on...more
Automakers and their suppliers have long been participants in unfair trade investigations before the International Trade Commission (“ITC”), but the scope and subject matter of automotive-related investigations is evolving....more
Enforcement actions by U.S. Customs and Border Protection (CBP) are increasingly more intensive and less lenient than in the past based on our experience. It is not uncommon in today’s regulatory enforcement landscape for...more
The rebuttable presumption of the Uyghur Forced Labor Prevention Act ("UFLPA") took effect on June 21, 2022. As a reminder, under this presumption for purposes of Section 307 of the Tariff Act of 1930, goods produced in the...more
Forced Labor Enforcement Task Force issues required enforcement strategy, including guidance to importers. On June 21, 2022, the key operative provision of the Uyghur Forced Labor Prevention Act (UFLPA) entered into...more
On January 24, 2022, the U.S. Department of Homeland Security (“DHS”) published a notice in the Federal Register requesting public comments on the implementation of the new regional import restriction affecting goods from the...more
Will 2022 Be the Year of Supply Chain Ethics? Effective June 21, 2022, in an effort to address forced labor concerns, U.S. law will broadly prohibit imports of products from China’s Xinjiang Uyghur Autonomous Region...more
On December 23, 2021, President Biden signed the bipartisan Uyghur Forced Labor Prevention Act (UFLPA or the “Act”), Pub. L. No. 117-78, which will ban the importation of all goods sourced from the People’s Republic of...more
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