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Robert Stang

Bob focuses his practice on customs and international trade law. He brings 30 years of experience to a wide range of issues that affect inbound and outbound goods, including tariff classification, valuation, country of origin marking matters, free trade agreements, and special trade programs. He also has extensive customs compliance experience and regularly assists importers facing U.S. Customs and Border Protection (CBP) audits, penalties, seizures, redelivery notices and other agency enforcement activities. Bob works with importers and exporters proactively to achieve cost savings and structure programs that meet CBP "reasonable care" requirements. He also handles supply chain security issues, including Customs-Trade Partnership Against Terrorism (C-TPAT) enrollment, verification and annual reviews.

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Antibodies.

The Trump Administration has officially reduced tariffs on patented pharmaceuticals and associated pharmaceutical ingredients imported from the United Kingdom (UK) from 10% to 0%. This change, effective July 31, 2026, is the result of an agreement between the United States and the UK, which created a carve out for UK origin pharmaceutical products from the recent national security tariffs imposed on patented pharmaceuticals pursuant to Section 232 of the Trade Expansion Act of 1962 (Section 232).

On August 4, 2026 the Bureau of Industry and Security (BIS) published a notice seeking public comments on expanding tariffs applicable to certain steel, aluminum and copper derivative products under Section 232 of the Trade Expansion Act of 1962 (Section 232) to fourteen (14) additional derivative products.

The list of products proposed to be subject…

Court of International Trade

On August 3, 2026, the state attorney generals of twenty-five states (25) co-led by State of Oregon, Arizona and California filed a complaint in the Court of International Trade (CIT) challenging tariffs imposed under Section 301 of the Trade Act of 1974 (Section 301) to address forced labor. The complaint alleges that Section 301 forced labor tariffs are ultra vires, arbitrary, capricious and contrary to law.

This complaint by the 25 state attorney generals challenging the legality of the Section 301 forced labor tariffs, joins other lawsuits pending before the CIT that were filed by small business plaintiffs, Burlap and Barrel, Inc. and Collective Horology LLC.

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The Office of the United States Trade Representative (USTR) has announced the imposition of new Section 301 tariffs under the Trade Act of 1974. Following investigations into global forced labor policies, the USTR has determined that 60 economies have failed to adequately impose or enforce prohibitions on the importation of goods produced with forced labor. The tariffs take effect at 12:01 a.m. Eastern Time beginning July 24, 2026.

Sign at the United States Department of Justice in Washington, D

In March 2025, in a similar blog post to this one, Nithya Nagarajan and Robert Romashko forecasted that False Claims Act (“FCA”) enforcement would increase under the current tariff-focused trade policy regime. Sure enough, the Department of Justice (“DOJ”) recently announced two FCA resolutions involving allegations of failure to pay customs duties and evasion of antidumping and countervailing duties.

U.S. Customs and Border Protection (CBP) is expected to deploy the Uyghur Forced Labor Prevention Act (UFLPA) regional alert and postal code requirement this Friday, March 18, 2023.

According to CBP, the goal of the new measures is to provide an early notification to importers and their representatives that goods may have been produced in…

On February 24, 2023, the Biden Administration announced the imposition of additional tariffs on Russian imports of aluminum and approximately 100 other individual products.  The imposition of these additional tariffs was announced on the one-year anniversary of Russia’s invasion of Ukraine. The White House announced its continued support of Ukraine in a series of actions…

On February 23, 2023, U.S. Customs and Border Protection (“CBP”) released new guidance for importers seeking admissibility of goods under the Uyghur Forced Labor Prevention Act (“UFLPA”). The three guidance documents include an updated Frequently Asked Questions (FAQ), best practices for applicability reviews, and tips on submitting executive summaries and documentation when under an applicability…

On June 13th, Customs and Border Protection (“CBP”) released its Operational Guidance For Importers to prepare companies for the Uyghur Forced Labor Prevention Act (“UFLPA”). UFLPA enforcement is set to take effect June 21st and will apply a rebuttable presumption standard to imports tied in whole or in part to the Xinjiang Uyghur Autonomous Region or entities identified by the U.S. government on the soon to be published UFLPA Entity List.