We are pleased to announce that our team’s fourth-annual international trade law year-in-review report was published just before the New Year. In it, we take a detailed look at howContinue Reading International Trade Law: 2022 Year in Review & Outlook for 2023
On September 16, 2022, the Biden Administration announced the final rule regarding a two-year pause on the imposition of new anticircumvention duties on imports of solar cells and modules from…Continue Reading BIDEN ADMINISTRATION PAUSES NEW SOLAR ANTICIRCUMVENTION TARIFFS WITH FINAL REGULATIONS RELATED TO IMPORTS OF SOLAR PANELS
Husch Blackwell’s latest podcast, The Justice Insiders, provides a unique perspective on some of the country’s most interesting criminal cases and issues related to compliance, internal investigations and regulatory…
Continue Reading Why Russia Sanctions Matter – Even if You’re Not an Oligarch
Effective January 13, 2022, the U.S. Census Bureau’s (“Census”) Automated Export System (“AES”) began issuing a response code 66Q notifying Electronic Export Information (“EEI”) filers whenever they enter an export…
Continue Reading AES Now Requires Consistency with EAR Destination-Based Controls; Census Will Not Remove Domestic EEI Requirement for Puerto Rico & U.S. Virgin Islands Shipments
As previously reported in our International Trade Insights blog, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) added Chinese telecommunications giant Huawei Technologies Co. Ltd. (“Huawei”) and sixty-eight of its affiliate companies to the BIS Entity List effective May 16, 2019. This designation prohibits anyone inside or outside of the United States from exporting, re-exporting or making an in-country transfer of commodities, software or technology that is subject to the U.S. Export Administration Regulations (“EAR”) to any of the listed Huawei companies without an appropriate license from BIS. Commodities, software and technology are “subject to the EAR” when they are of U.S. origin (regardless of whether they are located inside or outside the U.S.), physically present in the U.S., moving in transit through the U.S. or produced outside of the U.S. with qualifying amounts of controlled U.S.-origin content. The BIS designations for these Huawei companies require BIS to evaluate any license applications according to a general presumption of denial. BIS has also issued a Temporary General License (covered here in the International Trade Insights blog) which authorizes limited transactions with Huawei Entity List companies under certain contracts that existed on or before May 16, 2019. This Temporary General License is currently scheduled to expire on August 19, 2019.
Continue Reading Trump Administration and BIS Announce Willingness to Issue Huawei Export Licenses; Criteria for Issuing Such Licenses Still Unclear
On May 8, 2019, USTR released its federal register notice on the tariff increase for the third tranche (List 3) Section 301 tariffs on China. The duty rate on the estimated $200 billion worth of Chinese products will increase from 10% to 25% effective 12:01am ET on Friday, May 10, 2019. The notice also announces that an exclusion process will be instituted for these products in a separate notice.
The rate increase to 25% means that entries of goods
- entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on May 10, 2019, and
- exported to the United States on or after May 10, 2019 will now be subject to an additional tariff of 25%. Entries must be subject to both qualifiers-meaning that if a shipment has been exported prior to May 10, 2019 it will still be subject to the 10% duty rate. However, if the shipment is exported after 12:01am ET on May 10 the 25% duty rate will apply. To see our full post, click here.
On May 13, 2019, the Ministry of Commerce of the People’s Republic of China (“MOFCOM”) announced that it will offer a tariff exclusion process for importers in China that face serious economic or social consequences due to higher tariffs on U.S. goods. …
Continue Reading China Offers Tariff Exclusion Process on U.S. Goods