On August 10, 2020, U.S. Customs & Border Protection (CBP) issued a notice that goods produced in Hong Kong will need to be marked as a product of China starting on September 25, 2020. The marking changes are the result of the July 14, 2020 Executive Order on Hong Kong Normalization that ended Hong Kong’s special trade status.

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.
Customs Announces Extension of Deadline to File Post Summary Correction
Customs has posted CSMS #43528998 (July 31, 2020) reminding the trade community that as per the modification to the Post Summary Correction (“PSC”) procedure announced in the Federal Register on August 14, 2019 (84 FR 40430), the deadline for filing a PSC has been extended in cases where an importer requests and is granted an…
President Trump’s Executive Order Ends Hong Kong Country of Origin
On July 14, 2020, President Trump signed into law an Executive Order that ends Hong Kong’s differential treatment compared to the People’s Republic of China (“PRC” or “China”). The President’s action follows the Chinese government’s decision in late May to impose new national security legislation on Hong Kong that outlaws any act of “secession,” “terrorism,”…
USTR Announces Additional Duties on Cosmetics and Handbags from France, Delays Effective Date Until January 2021
On July 10, 2020, the U.S. Trade Representative (USTR) announced that it would impose a 25 percent additional duty on certain cosmetics, soaps and cleansing products, and handbags that are products of France, valued at $1.3 billion, due to the French Digital Services Tax (DST). Nevertheless, USTR delayed the application of the duties for as…
USMCA Set to Enter Into Force on July 1, 2020
The U.S.-Mexico-Canada Free Trade Agreement (USMCA) will displace NAFTA and become effective July 1, 2020. Though similar to NAFTA in many ways, key changes in the USMCA include provisions for digital trade, implementation of new local labor standards in the automotive sector, and the adjustment of the rules of origin for a wide variety of…
USTR Opens Online Portal to Solicit Input on Products to Carousel, Duty Rate in Large Civil Aircraft Section 301 Tariff Action
The U.S. Trade Representative (USTR) issued a draft Federal Register notice outlining its process to review the Section 301 duties imposed on imported goods pursuant to the Large Civil Aircraft Dispute with the European Union (EU). This review is required by statute (Section 306(b)(2) of the Trade Act of 1974) and may result in goods…
White House Issues Executive Order Providing Agencies with Regulatory Enforcement Discretion to Promote Economic Recovery
The Trump Administration issued its Executive Order on Regulatory Relief to Support Economic Recovery (the “EO”) on May 19, 2020 (Executive Order). The EO seeks to remedy the economic impact of the ongoing COVID-19 pandemic by removing certain administrative barriers and providing flexibility in the implementation and enforcement of other administrative provisions and…
CBP Issues Guidance Update on Section 232 and Section 301 Exclusion Refunds
On May 1, 2020 U.S. Customs and Border Protection (CBP) published an update to their previous guidance on Section 232 product exclusions granted by the Department of Commerce (DOC) and Section 301 product exclusions granted by the United States Trade Representative (USTR). The CBP message stated that these exclusions may be retroactive for unliquidated entries…
United States–Mexico–Canada Agreement (USMCA) Set to Take Effect July 1, 2020
On April 24, 2020, U.S. Trade Representative Robert Lighthizer notified Congress that Mexico and Canada had taken the necessary additional measures to comply with their commitments under the United States–Mexico–Canada Agreement (USMCA). The U.S. also notified the governments of Mexico and Canada that the U.S. had completed its domestic procedures to implement the USMCA. Mexico…
USTR Announces New Section 301 Product Exclusions for List 3
On April 22, 2020, the United States Trade Representative (“USTR”) issued new product exclusions pertaining to the 25% Section 301 List 3 Tariffs. The new list of exclusions includes one 10-digit HTSUS subheading (8424.90.9080 covering parts of certain projecting, dispersing or spraying devices) and 107 specially prepared product descriptions corresponding to a particular HTSUS subheading.…