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Nithya Nagarajan

Nithya’s extensive background in U.S. trade issues spans 25 years and includes various roles in a number of federal government agencies, including the Department of Commerce Department of Justice, and the U.S. Court of International Trade. She assists clients with administrative and regulatory actions before the Department of Commerce, International Trade Commission and U.S. Customs and Border Protection (CBP) and defends clients in appeals before the Court of International Trade, Court of Appeals for the Federal Circuit, NAFTA panels and the World Trade Organization. In addition to her body of U.S. experience, Nithya is also well-versed in international trade issues in China and India.

On September 9, 2026, the American Pizza Boxes Manufacturers Coalition (comprised of Smurfit Westrock plc and Pratt Industries, Inc.) and the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union (USW) (collectively Petitioners) filed a petition for the imposition of antidumping duties on imports of corrugated pizza boxes from the People’s Republic of China (China), Malaysia, and the Republic of Türkiye (Turkey), and countervailing duties on imports from Turkey.

On September 1, we posted on the Government Enforcement, Compliance & Investigations Report about how a Taiwan-based LED manufacturer and its U.S. subsidiary agreed to pay $5.15 million to resolve False Claims Act allegations that they evaded Section 301 tariffs by transshipping Chinese-origin LEDs through Taiwan. The settlement, announced August 5, 2026 by the U.S. Attorney’s

CBP to Verify Importer of Record Information on Form 5106

CBP announced it is executing enhanced enforcement procedures to verify the accuracy of importer of record information provided on CBP Form 5106, and importers of record or their brokers must submit complete and accurate information by September 18 to avoid consequences. The initiative follows the

On August 6, 2026, the White House issued another proclamation Adjusting Imports of Polysilicon and its Derivatives into the United States. This is the follow up to the Section 232 Investigation on polysilicon and polysilicon derivative products that was initiated in July 2025.
 
The proclamation concurs with the previous Commerce Department finding that

U.S. Customs and Border Protection (“CBP”) issued a Federal Register notice that it is now ready to execute “executing enhanced enforcement procedures.”  CBP has indicated that it will start verifying importer of record information provided by each importer on CBP Form 5106, and importers of record have until September 18, 2026, to correct any errors

On August 13, 2026, the White House Office of Trade and Manufacturing Policy released a report identifying more than 40 countries it characterizes as presenting an elevated risk of illegal transshipment of Chinese-origin goods into the United States. The report also states that an artificial-intelligence-driven enforcement tool, referred to as “Detective Border,” is under development to support U.S. Customs and Border Protection (CBP) in detecting and interdicting such shipments.

On July 31, 2026, President Trump issued proclamation “To Facilitate Positive Adjustment to Competition From Imports of Quartz Surface Products,” introducing a tariff-rate quota (“TRQ”) that will go into effect on August 15, 2026 on imports of certain quartz surface products under Section 203 of the Trade Act. The action follows a recommendation from the International Trade Commission in May 2026, which found that increased import volumes of quartz are harming the domestic quartz industry.

On July 29, 2026, the Hydraulic Cylinders Fair Trade Coalition and its individual members, Aggressive Hydraulics, Inc., Hol-Mac Corporation, Ligon Hydraulics, Prince Manufacturing Corporation, PTC Alliance LLC, Rosenboom Machine & Tool, Inc., Scot Industries, Inc., Stillwell Inc., and Texas Hydraulics, Inc. (Petitioners) filed petitions requesting the imposition of antidumping duties on imports of certain linear hydraulic cylinders and parts thereof (Hydraulic Cylinders) from Canada, China, India, Mexico, and South Korea, and countervailing duties on imports from China, India, and Mexico.