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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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The Biden Administration has taken new actions related to forced labor in the Xinjiang region that may affect the supply for material critical for solar panels: U.S. Customs and Border Protection (CBP) issued a Withhold Release Order (WRO), the Department of Commerce (Commerce) updated its Entity List, and the Department of Labor (Labor) updated its “List of Goods Produced by Child Labor or Forced Labor.”  These updates are part of an increased emphasis on both forced labor issues and a crackdown on goods from China’s Xinjiang province, and come on the heels of the G7 Summit that was held in mid-June.  The White House indicated that the Administration’s actions are a “translation” of the commitments made at the G7 denouncing forced labor in the Xinjiang region.

On March 29th, the Office of the United States Trade Representative (“USTR”) announced the suspension of all U.S. engagements with Burma (Myanmar) under the 2013 Trade and Investment Framework Agreement (“TIFA”), effective immediately.  Pursuant to this announcement, the United States will be suspending all government-to-government meetings following the military coup that occurred in February and the related escalation in violence by Burma’s military against its people.

U.S. Customs & Border Protection (CBP) issued a forced labor finding on March 29, 2021 against Top Glove Corporation Bhd. (Top Glove), a Malaysian manufacturer of disposable gloves, a product which has been in high demand during the pandemic.  As a result, port directors may seize certain disposable gloves of Top Glove’s at U.S. ports…

On March 18, 2021, Katherine Tai was confirmed as the U.S. Trade Representative.  Tai will be the first woman of color in this role.

Tai’s nomination hearing focused on a worker and labor-centric trade policy as well as a return to multilateralism, which we believe will include more active participation in the World Trade Organization. …

On January 13, 2021 U.S. Customs and Border Protection (CBP) issued a Withhold Release Order regarding cotton products and tomato products produced in China’s Xinjiang Uyghur Autonomous Region (XUAR) effective February 13, 2021.  The agency stated that: “CBP issued a Withhold Release Order (WRO) against cotton products and tomato products produced in Xinjiang based on…

Effective January 1, 2021 duty reductions under the Miscellaneous Tariff Bill (MTB) expired.  Additionally, Congress has not indicated when it might consider a new MTB bill.  As a result of the MTB expiring, over 1,600 products will immediately face increased tariffs and over 2,500 products will be prevented from receiving anticipated duty reductions even though…

As previously reported, since October 18, 2019 the U.S. has imposed additional duties on various European origin goods (including aircraft, certain textiles and wearing apparel, hardware, cheeses, and other agricultural goods) due the ongoing Large Civil Aircraft (LCA) dispute with the European Union (EU).

On December 30, 2020, the U.S. Trade Representative (USTR) announced…

On October 2, 2020, the Office of the United States Trade Representative (USTR) issued a statement announcing the initiation of new investigations under Section 301 of the Trade Act of 1974 to determine whether Vietnam has been undervaluing its currency and to investigate Vietnam’s policies and practices as related to importing illegally harvested timber subsequently…

U.S. Customs and Border Protection (“CBP”) is preparing a regulatory change that would eliminate the $800 de minimis exemption for imports subject to Section 301 tariffs, according to a proposed rule submitted by CBP to the Office of Management and Budget (“OMB”) on September 2, 2020.  Reviews of the proposed rule by OMB and an interagency review are the final steps before the publication of a final rule in the Federal Register.