The continuing invasion and occupation of parts of Ukraine by Russia have resulted in the imposition of strong sanctions on Russia and its ally Belarus by US agencies. Key parts of the Russia sanctions include actions taken by the Commerce Department Bureau of Industry and Security (“BIS”) and Treasury’s Office of Foreign Assets Control (“OFAC”)…
Section 232 of the Tariff Act empowers the president to impose “special” additional tariffs on imported items whose importation threatens the security of the defense industrial base. The idea behind the law was to protect the national industrial base against threats posed by cheaper, sometimes more durable imported competition of the same products. The Act…
One of the major tariff benefit programs administered by U.S. CBP is that of the U.S. Generalized System of Preferences or “GSP”. When GSP is in effect, qualifying products from 119 countries that are imported into the United States are entitled to duty-free status. But the product must meet certain qualifications, including that it was…
The U.S. has had an ongoing dispute with numerous foreign countries regarding their taxes on U.S.-origin digital services. These digital services taxes or “DSTs” are viewed as discriminatory against American digital firms who face high tax rates injurious to their businesses. Section 301 of the Trade Act of 1974 empowers the U.S. Trade Representative (“USTR”)…
Responding to Communist China’s concentration camps for its minority Uighur population which include allegations of forced labor, involuntary abortions and other abuse, the Customs & Border Protection Agency (“CBP”) has increased its focus on products that it suspects originate in their home province of Xinjiang. You may recall that CBP recently issued a Withhold Release…
In a Federal Register notice issued right before Christmas, the Bureau of Industry and Security (“BIS”) moved to implement the President’s removal of Hong Kong’s special status as a recognized, separate destination for the purposes of US export controls. The Administration took this action in response to steps taken by Communist China to fundamentally undermine…
If you import Christmas- related items, you are probably heartened when you first see US Harmonized Tariff Heading 9505 which covers, in part: “Festive, carnival or other entertainment articles . . .; parts and accessories thereof;” and specifically, Subheading 9505.10, “Articles for Christmas festivities and parts and accessories thereof:”. These are duty-free classifications when the…
As a US importer or a foreign exporter to the US, you may not have thought Antidumping (“AD”) or Countervailing duties (“CVD”) apply to your products. Think again. The following trends indicate that, while such extraordinary duties apply to a minority of US import shipments, such duties are becoming more prevalent and if they do…
Once you are issued your US Customs Broker License, you incur certain obligations that are tied to your retention of it. The major administrative requirement is to prepare and file the Triennial Status Report (“TSR”) every three years with CBP and to submit the accompanying fee to the agency: This is a simple form that lets…
If you import products made in the Sinkiang province of China or on its border, beware of tough new legislation that could lead to seizure of your imported products by CBP on the presumption that they were made with forced labor. For decades, Communist China has been accused of mistreating its Muslim Uyghur minority and…