Photo of Robert Stang

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.

White HouseWhy importers of steel and aluminum derivative products should consider challenging the administration’s imposition of additional Section 232 duties:

  • The processes followed by the administration in implementing additional Section 232 tariffs on steel and aluminum products not originally included in the Section 232 duties are procedurally flawed.
  • The institution of additional duties on products not

The U.S.-Mexico-Canada Agreement (“the USMCA”) passed the U.S. House of Representatives on December 19, 2019, by a vote of 385 to 41.  In order to be fully ratified by the United States, the USMCA must now be approved by the U.S. Senate, which has a total of up to 30 session days after the House

On December 10, 2019, House Speaker Nancy Pelosi stated in a press conference that Democrats had reached an agreement with the Trump Administration on the new U.S.-Mexico-Canada Agreement (“USMCA”) intended as a NAFTA update, clearing the way for Congress to vote on the trade agreement.  Speaker Pelosi called the agreement “a victory for America’s workers”

The U.S. International Trade Commission (ITC) announced on October 11, 2019 the opening of its system for accepting petitions for tariff relief under the American Competitiveness Act of 2016 (commonly referred to as the Miscellaneous Tariff Bill or MTB).  The MTB allows U.S. importers to petition for duty-free or reduced-duty treatment of imported products that

The Office of the U.S. Trade Representative (USTR) announced on June 19, 2019 an exclusion process for product exclusions from the tariffs on $200 billion of Chinese products (“List 3”). The exclusion process will open at noon (EDT) on June 30, 2019.

The exclusion process for List 3 will be slightly different from the process involved for the List 1 and 2 exclusions. USTR is opening a portal at http://exclusions.USTR.gov/ for requestors to file exclusion requests and interested parties to comment on them. Among other information, the questions in the exclusion request form will require data on the company’s gross revenues, percentage of total gross sales for which the requested product accounted, and the amount of sourcing of the product from domestic or third-country suppliers.

On Tuesday, May 21, 2019, USTR and the Office of Management and Budget (“OMB”) published in the Federal Register a request for comments on the Section 301 exclusion process for Tranche 3 tariffs which were increased from 10% to 25% on May 10, 2019. The notice also included a draft exclusion request form for the List 3 products. The draft exclusion request form includes more data requirements on U.S. and third-party sourcing, overall gross revenue, and on whether the company has applied for and/or received previous exclusion requests.

On Sunday, May 5, 2019, President Trump announced via Twitter that the tariff rate on the third tranche (List 3) of Section 301 tariffs would be increasing from 10% to 25% on Friday, May 10, 2019. According to the tweet, the reason for the increase is that the trade deal negotiations are moving “too slowly” and China’s attempt to “renegotiate.”

In the tweet the President also stated that an additional $325 billion dollars’ worth of goods “will be shortly” taxed at a rate of 25%.