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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.

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.

As stated in our earlier post, the Secretary of the Treasury and U.S. Customs and Border Protection (CBP) have postponed the deadline for payment for the deposit of certain estimated duties, taxes, and fees for importers experiencing a significant financial hardship due to the coronavirus disease (COVID-19) for up to 90 calendar days.

CBP

On April 20, 2020, the Secretary of the Treasury and U.S. Customs and Border Protection (CBP) announced via the CBP Customs Service Messaging System (CSMS #4243171) that they would be postponing the deadline for payment for the deposit of certain estimated duties, taxes, and fees for importers who have experienced a “significant financial hardship” due

Shipping containersU.S. Customs and Border Protection (“CBP”) announced in CSMS #42364745, issued April 14, 2020, that due to the high volume of inquiries the agency is migrating from its COVID-19 Relief Imports email address to the COVID-19 Relief Imports Web Portal, which is designed to address inquiries related to the importation of medical supplies to

On Friday, March 20, 2020 Customs announced that it was accepting requests for short-term relief from payment of estimated duties, taxes and fees due to the COVID-19 emergency, as discussed here.

Nevertheless, on March 26, 2020, Customs issued “Additional Guidance for Entry Summary Payments Impacted by COVID-19” that revised the information and

On March 24, 2020 the New York Field Office of Customs and Border Protection (CBP) issued Informational Pipeline  20-001-NYFO concerning Imports of Pandemic Response Materials in response to increased COVID-19 cases in the greater New York City area and across the nation. The Pipeline indicated that many of these shipments are legitimate, but also noted

UPDATED: March 25, 2020 – Several U.S. executive branch agencies along with federal courts are instituting significant operational changes.  These changes have either already been implemented or are anticipated at the U.S. government agencies and courts which manage international trade-related concerns in the coming weeks due to personnel and public safety concerns over the COVID-19

Short term case-by-case relief to approved importers:  On Friday, March 20, 2020 at 4:52 PM Customs issued the following message:

Due to the severity of  Novel Coronavirus Disease (COVID-19), U.S. Customs and Border Protection (CBP) will approve on a case by case basis additional days for payment of estimated duties, taxes and fees due to

On March 13, 2020, the Canadian Parliament approved the U.S.-Mexico-Canada Agreement (the “USMCA” in the United States or “CUSMA” in Canada), with Royal Assent, Canada’s equivalent to a U.S. presidential signature, following shortly thereafter.  As a result, Canada became the final of the three countries to approve the revised NAFTA free trade agreement.  Before implementing

On February 14, 2020, the Office of the U.S. Trade Representative (USTR) announced that it had completed its review of the current Section 301 tariffs due to the ongoing Large Civil Aircraft dispute with the European Union (EU).  As previously reported, various European goods (including aircraft, certain textiles and wearing apparel, hardware, cheeses, and other