International Trade & Supply Chain

On August 29, 2018, President Trump issued proclamations announcing that companies will be able to request exclusions from the Section 232 quantitative limitations (i.e., quotas) for certain steel and aluminum products imported in to the United States.  In particular, this affects steel and aluminum imports from Argentina, Brazil, and South Korea.

After President Trump announced steel and aluminum tariffs on several of the country’s allies in March 2018, a number of EU countries, Mexico, and Canada immediately announced retaliatory tariffs against American products. Other trade partners and allies have also made plans to seek remedies through the North American Free Trade Agreement (NAFTA) and the World…

On August 7, 2018, the Office of the United States Trade Representative announced the second list of products that will be subject to an additional 25 percent tariff when imported from China.   After a public hearing and comment period, USTR ultimately only removed 5 tariff lines from the list proposed in its notice of June…

As previously reported, the Office of the United States Trade Representative (USTR) issued a notice proposing an additional 10 percent tariff on approximately 6,000 8-digit tariff codes estimated to cover approximately $200 billion worth of imports from China. Our blog post can be found here and the list of products can be found here.

On…

President Trump signed a new Executive Order on August 6, 2018, titled “Reimposing Certain Sanctions with Respect to Iran”. The Executive Order was timed to coincide with the last day of the 90-day wind-down period established for activities associated with certain sanctions relief authorized by the Joint Comprehensive Plan of Action (“JCPOA”).  As a result, the first round of sanctions against Iran will become effective at 12:01 a.m. on August 7, 2018.

The U.S. Trade Representative is proposing an additional 10 percent tariff on approximately 6,000 8-digit tariff codes estimated to be about $200 billion worth of imports.  The USTR has now set a third set of hearing and written submissions for those affected by this new set of proposed tariffs.  The schedule is as follows:

July…

On Friday, July 6, 2018, the Office of the U.S. Trade Representative (USTR) announced a process for obtaining product exclusions from the 25% tariffs imposed on certain products imported from China.  The tariffs went into effect on July 6, 2018.

USTR has set the following deadlines:

  • All product exclusion requests must be filed by October

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WHEN? On June 6, 2018, the Federal Maritime Commission took steps to simplify freight pricing requirements for Non-vessel Operating Common Carriers (“NVOCCs”) by “approving” changes to Negotiated Rate Arrangements (NRAs) and NVOCC Service Arrangements (NSAs). While many NVOCCs are still utilizing the fast disappearing tariff publication methods of meeting the regulatory shipping requirements, it is our opinion that the contemplated changes to NRAs and NSAs will win over the NVOCC community to their almost exclusive usage. While the “Final Rules” were approved, it was clear from the FMC meeting, that the written provisions were still at a drafting stage. In discussions with senior FMC staff, it is our understanding that the so-called “Final Rules” will be going to the Federal Register later this week. By law they are required to be posted on the Federal Register for 30 days before becoming effective. Therefore, a good bet would be that these rules will be effective sometime in the first week of August, 2018.