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New CIT Case Challenges Section 301 Tariffs on List 3 Goods: Interested Importers Should Consider Filing Separate Claims

CLIENT ALERT: New CIT Case Challenges Section 301 Tariffs on List 3 Goods: Interested Importers Should Consider Filing Separate Claims No Later Than September 18th

by Melissa Proctor • September 16, 2020

A recently filed suit filed in the Court of International Trade (CIT) seeks refunds of all Section 301 tariffs imposed to date on List 3 goods imported from China. Interested companies may also file their own independent claims with the CIT challenging the tariffs on both the List 3 and List 4A; however, those claims […]


State-Treasury-and-Commerce-issue-Joint-Advisory-on--North-Korea-Ballistic-Missile-Procurement-Activities

State Treasury and Commerce issue Joint Advisory on North Korea’s Ballistic Missile Procurement Activities

by Melissa Proctor • September 1, 2020

The US Departments of State, Treasury and Commerce today issued a joint advisory to alert industry sectors worldwide to North Korea’s ballistic missile procurement activities, key North Korean procurement entities and the deceptive techniques employed by North Korean proliferators and procurement networks. The advisory urges companies to be aware of these activities and techniques, as […]


Customs Announces Additional 45-day Transition Period For Compliance With New Country Of Origin Marking Requirements For Imported Goods Produced In Hong Kong

Customs Announces Additional 45-day Transition Period For Compliance With New Country Of Origin Marking Requirements For Imported Goods Produced In Hong Kong

by Melissa Proctor • August 28, 2020

Customs and Border Protection (CBP) issued a CSMS Message on August 21st (CSMS #43729326) announcing a new 45-day transition period for compliance with the new country of origin marking requirements for imported goods that are products of Hong Kong.  CBP has decided to give importers more time to comply with the new requirements and is […]


BIS Issues Notice Of Proposed Rulemaking For Certain Foundational Technologies

BIS Issues Notice Of Proposed Rulemaking For Certain Foundational Technologies

by Melissa Proctor • August 27, 2020

Today, the Commerce Department’s Bureau of Industry and Security (BIS) issued its notice of proposed rulemaking for certain foundational technologies and seeks public comments on the technologies that should be considered for additional export controls under the Export Administration Regulations (EAR) (15 C.F.R. Parts 730 – 774). Specifically, BIS is soliciting comments on the following: […]


BIS Adds 60 New Parties To The Entity List

BIS Adds 60 New Parties To The Entity List

by Melissa Proctor • August 27, 2020

Today, the Commerce Department’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) (15 C.F.R. Parts 730 – 774) by adding sixty (60) parties from China, France, Hong Kong, Indonesia, Malaysia, Oman, Pakistan, Russia, Switzerland and the United Arab Emirates to the Entity List for the following reasons— Attempted diversion of controlled […]


CBP Consider 56 Comments Submitted In Response To Proposed Amendments To The Customs Brokers Regulations

CBP Consider 56 Comments Submitted In Response To Proposed Amendments To The Customs Brokers Regulations

by Melissa Proctor • August 17, 2020

August 17, 2020 CBP recently closed the comment period on its proposed changes to the customs brokers regulations in 19 CFR Part 111. A total of fifty-six (56) comments were submitted—most were concerned with ambiguity in the proposed regulatory language, while others suggested substantive amendments. CBP will evaluate the comments and decide whether to make […]


Customs Announces New Country of Origin Marking Requirements for Imported Goods Produced in Hong Kong

Customs Announces New Country of Origin Marking Requirements for Imported Goods Produced in Hong Kong

by Melissa Proctor • August 11, 2020

Customs and Border Protection (CBP) issued a General Notice on August 11th notifying the public that imported goods produced in Hong Kong must be marked to indicate China as their country of origin. , The new requirements stem from the President’s recent Executive Order 13936 which formally suspended Hong Kong’s special trade status with the […]


BIS Issues Final Rule Suspending License Exceptions Under The Export Administration Regulations For Hong Kong

BIS Issues Final Rule Suspending License Exceptions Under The Export Administration Regulations For Hong Kong

by Melissa Proctor • July 31, 2020

Today (July 31, 2020), the BIS published its Final Rule revising the Export Administration Regulations (15 C.F.R. Parts 730 – 774) (EAR) and suspending license exceptions that were previously applicable to Hong Kong. License exceptions are authorizations under the EAR that allow exports, reexports or in-country transfers without a license from the BIS provided that […]


The Suspension of Hong Kong’s Special Trade Status Poses New Export, Sanctions and Import Compliance Requirements on U.S. Companies

The Suspension of Hong Kong’s Special Trade Status Poses New Export, Sanctions and Import Compliance Requirements on U.S. Companies

by Melissa Proctor • July 30, 2020

On July 14, 2020, President Trump issued Executive Order 13936 formally suspending Hong Kong’s special trade status under U.S. law. Several weeks earlier, on May 27, 2020, the Department of State certified to Congress that Hong Kong is no longer sufficiently autonomous from the People’s Republic of China (PRC) by virtue of, among other things, […]


USMCA Certification Requirements and Sample Template

USMCA Certification Requirements and Sample Template

by Melissa Proctor • July 27, 2020

Under the United States-Mexico-Canada Agreement (USMCA) that entered into force on July 1, 2020, there is no required certificate of origin form or specified format for exporters, producers, or importers to use to certify that their goods satisfy the USMCA origin criteria and qualify for preferential trade benefits. Instead, importers must have a written certification […]