The latest on Russia sanctions from the International Trade and Supply Chain Team
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International Trade & Supply Chain

July 6, 2022, will mark the four-year anniversary of the institution of Section 301 tariffs against approximately $370 Billion in imports from China into the United States.  In light of this anniversary, the Office of the United States Trade Representative (“USTR”) is commencing the first phase of its Four-Year Review Process, which will allow representatives of domestic industries which benefit from the trade actions to submit comments on whether or not the Section 301 tariffs should continue.  In a notice to be published in the Federal Register on May 5, 2022 (unpublished version available here), USTR is requesting interested parties to address whether the imposition of the tariffs has been beneficial.  Comments from domestic interested parties must be submitted in a 60-day window prior to the four-year anniversary.  The first round of comments will be accepted between May 7, 2022, and July 5, 2022, for the List 1 tariffs which are set to expire on July 6, 2022.  Comments related to the List 2 tariffs will be accepted between June 24, 2022, and August 22, 2022, as those tariffs are set to expire on August 23, 2022.
Continue Reading USTR Announces Opportunity for Domestic Industry Parties to Comment on Continuation of Section 301 Tariffs

On March 30, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) modified and expanded a list of aircraft that have flown into Russia in apparent violation of the Export Administration Regulations (“EAR”).  We more thoroughly discussed the implications of this list – which was first published on March 18, 2022 – in our blog post here.  The updated list adds 73 additional Boeing-manufactured aircraft and modifies tail and/or serial number information for 13 aircraft previously listed on March 18, 2022.  The full list of owners/operators include Aeroflot, AirBridge Cargo, Aviastar-TU, Alrosa, Atran, Azur Air, Nordstar, Nordwind, Pegas Fly, Pobeda, Rossiya, Royal Flight, S7 Airlines, and Utair (FC Chelsea owner Roman Abramovich’s private Gulfstream jet is also on the list).
Continue Reading BIS Modifies and Expands List of Russian-Controlled Aircraft Subject to the EAR Known or Suspected to Have Violated the EAR

On March 23, 2022 the U.S. Trade Representative (“USTR”) reinstated 352 Section 301 China tariff exclusions that had expired December 31, 2020.  The list of reinstated exclusions can be found here: Reinstatement of Certain Exclusions Previously Extended | United States Trade Representative (ustr.gov) The 352 reinstated tariff exclusions are retroactive to October 12, 2021 and extend forward through December 31, 2022.
Continue Reading USTR Reinstates 352 Section 301 China Tariff Exclusions. Importers May Have Opportunities For Refunds

On March 11, 2022, President Biden issued an Executive Order (“EO”) that prohibited the importation into the United States of fish, seafood, and preparations thereof; alcoholic beverages; non-industrial diamonds; and any other products of Russian Federation origin as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State and the Secretary of Commerce.  Because the Executive Order lists no effective date, implementation will be immediate.  No exceptions are listed for such products that are in transit and the EO specifically states that the prohibitions apply “notwithstanding any contract entered into or license or permit granted prior to the date of this order.”

Continue Reading Biden Issues Executive Order Prohibiting Certain Imports and Calls for Congressional Action to Revoke Permanent Normal Trade Relations With Russia

The U.S. Department of Commerce (“Commerce”) announced on Friday that it was set to resume trade missions starting as early as March 2022.  Trade missions are government- led programs where members of the trade can meet directly with foreign industries and officials to explore potential business opportunities.  The COVID-19 pandemic brought these missions to a sudden halt in March 2020 and no trade missions have occurred in the past 24 month.  The International Trade Administration (“ITA”) is now preparing to resume in-person trade missions, where possible.

Continue Reading Commerce Trade Missions Set to Resume in March 2022

On February 8, 2022, the Department of Commerce (“Commerce”) announced in the Federal Register the opportunity to request an annual administrative review for products that are currently subject to antidumping and countervailing duties. The products and countries that have been listed in the Federal Register notice are the following:

Continue Reading Opportunity to Request Administrative Review

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