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CBP Confirms No Additional Chinese Tariffs on Goods from HK

August 12, 2020

On August 12, CBP confirmed that the recent revocation of Hong Kong’s “special status” and updated China marking requirements would not render goods of Hong Kong origin subject to the additional Section 301 tariffs imposed on most goods of Chinese origin. CBP stated that “the change in marking requirements does not affect country of origin determinations for purposes of assessing ordinary duties under Chapters 1-97 of the HTSUS or temporary additional duties under Chapter 99…

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US Revokes Hong Kong’s “Special Status” – UPDATED 8/24

By Joseph W. Rohe, LCB, CCS

August 10, 2020

UPDATE: CBP has extended the compliance period for origin marking for an additional 45 days. In an effort to allow importers ample time to comply with EO requirements for goods produced in Hong Kong to be appropriately marked with the origin of “China”, CBP is extending the transition period through November 9, 2020. Accoringly, effective November 9, Hong Kong goods entered or withdrawn from warehouse for consumption must be marked as products of China. As…

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Canadian Aluminum to Again Face 10% Tariff

By Joseph W. Rohe, LCB, CCS

August 7, 2020

On August 6 the Trump Administration announced that it would reimpose the 10% aluminum tariff on imports of Canadian “non-alloy unwrought aluminum” classified under HTS subheading 7601.10. The move has not garnered widespread support from industry or the US Chamber of Commerce, who called it “a step in the wrong direction.” The Administration’s proclamation claims an 87% increase in imports of Canadian non-alloyed unwrought aluminum between June 2019 and May 2020; however, the US Aluminum…

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USMCA Certificates of Origin – What you need to know.

By Joseph W. Rohe, LCB, CCS

July 8, 2020

The fact that the US-Mexico-Canada Agreement (“USMCA”), which replaced NAFTA on July 1, does not require any particular form Certificate of Origin (“COO”) has left many importers and exporters confused on the proper manner of certifying goods as “originating” under USMCA. The new trade agreement dispensed with the formality of the Form 434 COO under NAFTA, but has left to the trade the determination of how to format and structure the certifying document. Though no…

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Treasury’s Final FIRRMA Regulations: New Foreign Investment Restrictions in Tech, Infrastructure and Data

By Nevena Simidjiyska

January 30, 2020

Starting Feb. 13, 2020, U.S. companies in tech, infrastructure and data seeking minority or controlling foreign investment will require approval from the Committee on Foreign Investment in the United States (CFIUS) before closing certain transactions. The change stems from the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA), which was signed into law by President Donald Trump in 2018, expanding CFIUS’ jurisdiction to review certain foreign acquisitions of and investments in U.S. businesses on…

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Apple’s Lesson: Screening Software Alone Won’t Prevent Export Violations

By John Cornell Fuller

December 16, 2019

apple-store-in-bangkok-picture-id1134921314

Apple Inc.’s recent settlement with the Treasury Department’s Office of Foreign Assets Control (OFAC) has exposed a potentially costly wrinkle in complying with international trade regulations. While sanctions screening technologies may help a company catch and report errors, this software alone will not absolve faults and shortcomings in a company’s overall export compliance programs. The compliance woes at Apple serve as a signal to businesses of all sizes that rely on third-party sanction screening software.…

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Certain Transactions with the Government of Venezuela are Authorized

By Michelle Rosenberg

November 13, 2019

On November 5, 2019 the Office of Foreign Assets Control (OFAC) issued two General Licenses (GLs) authorizing specific transactions involving the Government of Venezuela and categories of persons blocked by Executive Order 13884 (E.O. 13884). E.O. 13884 was signed by President Donald Trump earlier this year on August 5, 2019. E.O 13884 was intended to increase pressure on the Nicolas Maduro regime by blocking property and property interests of the Government of Venezuela under U.S.…

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USMCA…maybe next year?

By Joseph W. Rohe, LCB, CCS

October 3, 2019

Now that Canadian PM Justin Trudeau has dissolved Parliament and called for a general election (to be held October 21), chances of seeing the USMCA ratified by all three member states this year has become an increasingly remote possibility. However, the good news for USMCA supporters is that NAFTA’s replacement continues to enjoy support in Canada in both the Conservative and Liberal parties. In fact Andrew Scheer, leader of the Conservative party, has announced that…

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New Foreign Investment Restrictions on the Horizon in Tech, Infrastructure and Data

By Nevena Simidjiyska

September 27, 2019

U.S. companies in tech, infrastructure and data seeking foreign investment will require approval from the Committee on Foreign Investment in the United States (CFIUS) before closing certain transactions. Last year, President Trump signed into law the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA), which outlined the expansion of CFIUS jurisdiction to review certain foreign acquisitions and investments in U.S. businesses on grounds of national security. FIRRMA left the specifics to regulations to be…

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US/China Trade War Escalates

By Joseph W. Rohe, LCB, CCS

August 26, 2019

On Friday, August 23, the Trump Administration announced an increase in Section 301 tariffs following China’s announcement of retaliatory tariffs targeting $75 billion of US goods. The announcement, which came by way of tweet, provided that Section 301 tariffs on all List 1 through 3 goods would be elevated from 25% to 30% effective October 1. In addition, the administration announced that tariffs on List 4 goods-the first tranche of which goes into effect at…

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Blog Authors

CBP Confirms No Additional Chinese Tariffs on Goods from HK

US Revokes Hong Kong’s “Special Status” – UPDATED 8/24

Canadian Aluminum to Again Face 10% Tariff

USMCA Certificates of Origin – What you need to know.

Treasury’s Final FIRRMA Regulations: New Foreign Investment Restrictions in Tech, Infrastructure and Data

Apple’s Lesson: Screening Software Alone Won’t Prevent Export Violations

Certain Transactions with the Government of Venezuela are Authorized

USMCA…maybe next year?

New Foreign Investment Restrictions on the Horizon in Tech, Infrastructure and Data

US/China Trade War Escalates

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