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
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
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
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
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
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
After more than a year of debate in the U.S. Congress as to the scope and enforceability, the Uyghur Forced Labor Prevention Act (UFLPA or Act) passed Congress with strong bipartisan support. President Biden has publicly...more
The UFLPA aims to clamp down on the import of items produced by alleged forced labor in and relating to the XUAR. On 16 December 2021, the US Senate unanimously passed the Uyghur Forced Labor Prevention Act (UFLPA),...more
On Thursday, 24 June 2021, the Biden administration took various actions against solar product manufacturers in the Xinjiang region, which will have implications on the supply chain for the construction of solar energy...more
On May 4, 2021, U.S. Customs and Border Protection (CBP) announced the seizure of a shipment containing 3.97 million nitrile disposable gloves that, according to CBP, is directly linked to forced labor practices in Malaysia. ...more
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
In case there was any doubt as to where the Biden administration stands on forced labor enforcement, United States Customs and Border Protection (CBP) stated recently that its “message to the trade community is clear: Know...more
On January 13, U.S. Customs and Border Protection (“CBP”) issued a new Withhold Release Order (“WRO”) under Section 307 of the Tariff Act of 1930 on all cotton products and tomato products from the entire Xinjiang region of...more
CBP has issued a “region-wide” WRO on cotton and tomato products “grown or produced” by entities “operating in” the XUAR. In a press release, CBP states that the order covers “apparel, textiles, tomato seeds, canned tomatoes,...more
On January 13, 2021, United States Customs and Border Protection (CBP) issued an order blocking all imports of cotton and tomato products from China’s Xinjiang Uighur Autonomous Region. The order, intended to address CBP’s...more