CBP announced on October 6, 2025, that it will not issue refunds or any payments related to drawback claims, post-summary corrections and protests during the government shutdown which began on October 1, 2025.
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.
The first seven weeks of the second Trump Administration has revealed that tariffs are going to be a primary tool in the administration’s trade arsenal to address both domestic and foreign trade policy goals. What is critical to understand is that tariffs are only a viable tool if U.S. Customs and Border Protection (“CBP”) can…
Effective April 17, 2024, U.S. Customs and Border Protection (“CBP”) has amended its regulations implementing the Enforce and Protect Act of 2015 (“EAPA”), a statute granting increased authority to investigate allegations of evasion of antidumping and countervailing duty (“AD/CVD”) orders. The amendments were issued in a final rule of March 18, 2024, and they are…
On March 28, 2024, CC Metals and Alloys, LLC (“CCMA”) and Ferroglobe USA, Inc.(“Ferroglobe”) (“Petitioners”), filed a petition for the imposition of antidumping and countervailing duties on ferrosilicon from the Federative Republic of Brazil (“Brazil”), the Republic of Kazakhstan (“Kazakhstan”), Malaysia, and the Russian Federation (“Russia”).
SCOPE OF THE INVESTIGATION
The following language describes…

A recent ruling analyzed whether certain functions performed in preparation for filing an entry with U.S. Customs and Border Protection (“CBP”) arise to the level of “Customs Business” that must be performed by a licensed broker. Ruling HQ H326926, issued to Heizwerthy Customs & Freight Solutions (“Heizwerthy”), states that allowing an unlicensed company to extract…

On December 26, 2023, the United States Trade Representative (“USTR”) announced that it will further extend 352 reinstated exclusions and 77 COVID-related exclusions to duties imposed on goods from China pursuant to Section 301 of the Trade Act of 1974 until May 31, 2024. USTR imposed Section 301 duties in four tranches or “lists,” and…
On December 8, 2023, Senators Bill Cassidy and Sheldon Whitehouse introduced a new version of the Customs Modernization bill to amend the Tariff Act of 1930. The new proposal comes over two years after Senator Cassidy initially proposed draft legislation, which we explained in a prior post. The most recent proposed bill aims to…
On July 26, 2023, the Forced Labor Enforcement Task Force (“FLETF”) issued the first annual update to its guidelines for enforcing the Uyghur Forced Labor Prevent Act (“UFLPA”) in a Report to Congress titled “2023 Updates to the Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s…
The Department of Homeland Security announced on August 1, 2023, that it is adding three entities to the Uyghur Forced Labor Prevention Act (“UFLPA”) Entity List, the consolidated register of four lists required by section 2(d)(2)(B) of the UFLPA.