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ITC Section 332 Proceedings: Investigation into Economic Impacts of Section 301 and 232 tariffs.

By John Brew & Frances P. Hadfield on May 10, 2022
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On May 10, the US International Trade Commission (ITC) issued a Federal Register notice stating that it will conduct an investigation into the economic impacts of the Section 301 and 232 (global steel and aluminum) tariffs on US industries.  See Notice.

The ITC will hold a hearing, and accept pre-hearing and post hearing briefs.  The following are the relevant dates:

  • July 6, 2022: Deadline for filing requests to appear at the public hearing.
  • July 8, 2022: Deadline for filing prehearing briefs and statements.
  • July 14, 2022: Deadline for filing electronic copies of oral hearing statements.
  • July 21, 2022: Public hearing.
  • August 12, 2022: Deadline for filing post-hearing briefs and statements.
  • August 24, 2022: Deadline for filing all other written submissions.
  • March 15, 2023: Transmittal of Commission report to Committees.

This investigation, conducted pursuant to Section 332, may be used by the USTR to determine what products should be removed from Section 301 tariffs. Importers should consider participating in the Section 332 proceedings to obtain relief from 301 tariffs. 

Photo of John Brew John Brew

John Brew is the former chair of Crowell & Moring’s International Trade Group and a partner in the firm’s Washington, D.C. office.

John has extensive experience in import and export trade regulation, collaborating with corporations, trade associations, foreign governments, and nongovernmental organizations on…

John Brew is the former chair of Crowell & Moring’s International Trade Group and a partner in the firm’s Washington, D.C. office.

John has extensive experience in import and export trade regulation, collaborating with corporations, trade associations, foreign governments, and nongovernmental organizations on customs administration, enforcement, compliance litigation, legislation, and policy matters. He represents clients in proceedings at the administrative and judicial levels as well as before Congress and the international bureaucracies that handle customs and trade matters. John advises clients on all substantive import regulatory issues handled by U.S. Customs and Border Protection and Immigration and Customs Enforcement, such as classification, valuation, origin, marking, tariff preference programs, other agency regulations, admissibility, customs brokerage, Section 321, drawback, foreign trade zones, duty recovery programs, import restrictions, quotas, audits, prior disclosures, penalties, investigations, Customs Trade Partnership Against Terrorism and trade compliance programs, importations under bond, the Jones Act, and vessel repairs.

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Photo of Frances P. Hadfield Frances P. Hadfield

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving…

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving customs compliance, audits, customs enforcement, as well as import penalties.

Frances represents clients before the U.S. Court of International Trade and the U.S. Court of Appeals for the Federal Circuit, as well as in proceedings at the administrative level. She advises corporations on both substantive federal and state regulatory issues that involve U.S. Customs and Border Protection, the Federal Trade Commission, Food and Drug Administration, and U.S. Fish & Wildlife in matters pertaining to product admissibility, audits, classification, import restrictions, investigations, marking, licenses, origin, penalties, and tariff preference programs.

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  • Posted in:
    Antitrust, Competition and Trade
  • Blog:
    International Trade Law
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source

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