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USTR Tai Takes Control of Trump Tariffs: Some Section 301 Tariffs Suspended and Others May Be Implemented on Six Countries With...

USTR is soliciting comments and has scheduled hearings regarding the potential imposition of Section 301 tariffs of up to 25% in response to the Digital Services Tax adopted by Austria, India, Italy, Spain, Turkey, and the...more

Meyer Decision: First Sale Remains a Savings Avenue for Importers

First sale appraisement currently remains a legally viable duty savings avenue, including for transactions with vendors in NMEs. On March 1, 2021, Judge Thomas J. Aquilino, Jr. of the US Court of International Trade (CIT)...more

Arent Fox's Advance Look at Hot Button Trade Issues For 2021

Looking towards 2021 and a new Administration, Arent Fox's International Trade & Investment group has prepared a series of primers on six key areas that can impact your business: The Biden Transition, Special Tariffs,...more

Wait Is Over: USMCA Border Enforcement Begins

US tariffs are applied at the time of import and so the elevated role played by US Customs and Border Protection should not be underestimated. While the Customs section begins with the analysis “The Wait Is Over: USMCA Border...more

US “China Tariffs” - What to Expect from a Biden Administration

Since trade policy almost always involves the application of tariffs, we begin with “China Tariffs – What to Expect from the Biden Administration,” an issue top of mind for many executives who have business interests in China...more

Origin Verification Procedures: Similarities to the NAFTA in the USMCA

The USMCA permits CBP to verify whether a good entered with a claim for preferential tariff treatment qualifies as originating by: (1) Written request or questionnaire to the importer, exporter, or producer of the good...more

New Analysis: CBP Takes First Step Towards Full USMCA Implementation

In an April 20, 2020 message to the trade community, US Customs and Border Protection (CBP) released the long-awaited United States–Mexico–Canada Agreement (USMCA) Interim Implementing Instructions (CBP Instructions). This...more

New Textile and Apparel Rules for the USMCA

The USMCA textile and apparel rules of origin are generally based on the “yarn forward” rule, which requires the formation of the yarn (spinning or extruding) and all processes following yarn formation to occur in the USMCA...more

CBP Instructions for USMCA Recordkeeping

Any importer who claims preferential tariff treatment under the Agreement for a good imported into the United States from a USMCA country must keep the following documentation for a period of no less than five years from date...more

Who Can Make a USMCA Certification?

The USMCA does not require the use of CBP Form 434, as there is no prescribed format for certificate of origins under the USMCA. These certifications are to be completed by the exporter, producer, or importer certifying that...more

New Automotive Origin Rules for the USMCA

Appendix I, Automotive Rules of Origin and Procedures, to the CBP Instructions provides guidance on the USMCA automotive rules of origin by incorporating the appendix to Chapter 4 of the USMCA Implementation Act (Automotive...more

Importing Under COVID-19: Companies Suffering Financial Hardship Receive 90-Day Reprieve to Pay Duties

Effective yesterday, the US government is making available a temporary 90-day postponement of certain import payment deadlines for companies and individuals experiencing “significant financial hardship” due to the economic...more

COVID–19 Duty Deferral Option Withdrawn by CBP Amidst Continued Requests by Congress for Such Action

After initially accepting requests from importers in light of the novel coronavirus (COVID–19) pandemic to defer payment of duties—a means of relief that the Trump Administration had reportedly been considering—US Customs and...more

COVID-19 Impact on Section 301 China Tariffs: USTR Excludes Some Healthcare Products, Solicits Requests to Exclude More

On Wednesday, March 25, 2020, the U.S. Trade Representative (USTR) published a Federal Register notice requesting comments on the removal of Section 301 tariffs from Chinese medical-care products—including those that have...more

The Importation of Personal Protective Equipment for Treatment of COVID-19

News reports show that because of the spread of the novel coronavirus (COVID-19) pandemic, hospitals and medical facilities are overwhelmed and threaten to strain the healthcare system. Masks, ventilators, and gowns are...more

Holiday Rush: Section 301 Tariff Developments Impact US Importers

Section 301 of the Trade Act of 1974, 19 U.S.C. § 2411, authorizes the president to take retaliatory action if it is determined that a trade act, policy, or practice of a foreign government is unreasonable or discriminatory...more

US Opens A New Front in Trade Wars with Proposed France Duties

Parties seeking changes to the proposed list of tariff subheadings or to lower duties should take advantage of this comment period. Why is USTR proposing additional duties on French imports? Under Section 301, USTR can...more

The Time is Now: Here’s the Latest on Avoiding China Tariffs

As part of the Trump Administration’s longstanding “trade war” with China over Chinese government trade practices related to technology transfer, intellectual property, and innovation that the Administration has determined to...more

Don’t Let the Opportunity To Lower Your Duty Payments Pass You by — Miscellaneous Tariff Bill Process Now Underway

On October 11, 2019, the US International Trade Commission (ITC) began accepting petitions as part of the 2019 Miscellaneous Tariff Bill (MTB) process. Under this process, a member of the public may request that Congress...more

End-of-Summer Section 301 China Tariffs Roundup: New Tariffs, New Deadlines, New Uncertainty

List 4A goes into effect, all Section 301 tariffs to increase by 5 percent, USTR deadlines loom, and the President orders American companies to “search for alternatives” to China sourcing. This is your end-of-summer Section...more

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