International Trade & Supply Chain

As tensions run high between Washington and Moscow over a possibly imminent Russian invasion of Ukraine, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated today four (4) current and former Ukrainian officials under Executive Order (“EO”) 14024 dated April 15, 2021.  In a press release issued earlier today, OFAC asserted the Russian Federal Security Service (“FSB”) “recruit[s] Ukrainian citizens in key positions to gain access to sensitive information, threaten the sovereignty of Ukraine, and then leverage these Ukrainian officials to create instability in advance of a potential Russian invasion.”  OFAC also noted that Russian agents have sought to influence U.S. elections since at least 2016.

Continue Reading OFAC Sanctions Four Ukrainian Officials for Acting on Russia’s Behalf; Additional Russia Sanctions Could Follow

In an October 21, 2021 interim final rule (“IFR”), the Bureau of Industry and Security (“BIS”) published long-awaited “cybersecurity items” controls in Categories 4 (Computers) and 5, Pt. 1 (Telecommunications) of the Commerce Control List (“CCL”) and followed the IFR up on November 12, 2021 with relevant FAQs.  The IFR will impose new export controls on certain “cybersecurity items” that relate to “intrusion software” or “IP network communications surveillance.” The IFR, originally scheduled to become effective on January 19, 2022, will now become effective on March 7, 2022.  In the January 12, 2022 notice announcing the delay, BIS stated it “may consider some modifications for the final rule” and indicated it would “provide the public with additional guidance.”  Below we describe the IFR as it currently stands.  We will update readers when BIS implements any additional edits to the IFR and/or updates its guidance.

Continue Reading BIS Delays Implementation of New Cybersecurity Items Interim Final Rule

On January 12, 2022, Chemical Products Corporation (“CPC” or “Petitioner”), filed a petition for the imposition of antidumping and countervailing duties on imports of barium chloride from India.

Continue Reading Petition Summary: Barium Chloride from India

Husch Blackwell’s third-annual international trade law year-in-review report provides a detailed look at how 2021 played out and takes a peek at how 2022 might develop. As companies begin to strategize on what a second year of the Biden administration will bring, we hope the framework presented in our report will help your business maximize potential cost savings and minimize potential risks as enforcement activity continues to rise and supply chains remain under pressure well into the coming year.

Continue Reading Download Report | International Trade Law: 2021 Year in Review & Outlook for 2022

On January 1, 2022, the new Harmonized Tariff Schedule (HTS) will take effect with a number of significant updates for importers and exporters.  The World Customs Organization (WCO) made approximately 350 amendments which will impact a substantial number of products and product groups being imported into the U.S. In addition to new classifications, importers should also take note of the updated tariff descriptions, legal notes, and product descriptions. The new changes are expected to account for the continued advances in technology and developing global priorities. The updated version can be found here along with the official change record.

Continue Reading New Harmonized Tariff Schedule Updates Set to Take Effect in January 2022

On December 29, 2021, Mid Continent Steel & Wire, Inc. (“Mid Continent” or “Petitioner”), filed a petition for the imposition of antidumping and countervailing duties on imports of certain steel nails from India, Sri Lanka, Thailand and Turkey. Additionally, the petition alleges that imports of certain steel nails from Oman are unfairly subsidized and requests the imposition of countervailing duties.

Continue Reading Petition Summary: Certain Steel Nails from India, Oman, Sri Lanka, Thailand and Turkey

On December 28, 2021, the U.S. Department of Commerce published a notice initiating new administrative reviews for antidumping duty (AD) and countervailing duty (CVD) orders with November anniversary dates. Listed below are the countries and products named in the notice:
Continue Reading Commerce Initiates New Administrative Reviews on AD/CVD Orders

On December 23, 2021 President Biden signed H.R. 6256, wide-reaching legislation aimed at preventing the importation of goods “mined, produced or manufactured wholly or in part with forced labor” from China, in particular the Xinjiang Uyghur Autonomous Region (the “XUAR”).  See Text – H.R.6256 – 117th Congress (2021-2022): To ensure that goods made with forced labor in the Xinjiang Uyghur Autonomous Region of the People’s Republic of China do not enter the United States market, and for other purposes. | Congress.gov | Library of Congress.  The bill specifically references cotton, tomatoes and polysilicon, but in fact covers all types of products as well as manufacturers and even companies involved in the recruitment and transport of workers.
Continue Reading President Biden Signs Wide-Reaching Legislation Targeting Goods Allegedly Involving Forced Labor from China