The latest on Russia sanctions from the International Trade and Supply Chain Team
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On January 18, 2023, Cleveland-Cliffs Inc. and the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union, collectively known as (“Petitioners”), filed a petition

Continue Reading Petition Summary: Certain Tin Mill Products from Canada, China, Germany, Netherlands, South Korea, Taiwan, Turkey and the United Kingdom

On December 16, 2022, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) published a rule adding 35 entities from China and one entity from Japan to the Entity

Continue Reading BIS Adds 35 Chinese Entities to Entity List for Supporting China’s Military Modernization Efforts and Nine Russian Entities for Failure to Complete Satisfactory End-Use Checks

On December 2, 2022, the Department of Commerce (“Commerce”) announced its preliminary circumvention determination with respect to certain solar cells and modules exported from Cambodia, Malaysia, Thailand, and Vietnam.  Commerce

Continue Reading Commerce Finds Solar Cells and Modules from Cambodia, Malaysia, Thailand, and Vietnam Circumventing AD/CVD Orders

On September 28, 2022, the Coalition of Freight Coupler Producers (“CFCP” or “Petitioner”), filed a petition for the imposition of antidumping duties pursuant to section 731 of the tariff act

Continue Reading Petition Summary: Certain Freight Rail Couplers and Parts Thereof from the People’s Republic of China and the United Mexican States                                                                                                            

On June 13th, Customs and Border Protection (“CBP”) released its Operational Guidance For Importers to prepare companies for the Uyghur Forced Labor Prevention Act (“UFLPA”). UFLPA enforcement is set to take effect June 21st and will apply a rebuttable presumption standard to imports tied in whole or in part to the Xinjiang Uyghur Autonomous Region or entities identified by the U.S. government on the soon to be published UFLPA Entity List.

Continue Reading CBP Releases Uyghur Forced Labor Prevention Act (UFLPA) Guidance for Importers

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 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 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

The Office of the United States Trade Representative (“USTR”) announced in a notice that 81 COVID specific product exclusions would be extended for an additional 6 months, with all COVID exclusions receiving an additional 16-day transition period. The exclusions on the 81 products was set to expire on November 14, 2021, but will now be pushed back until May 31, 2022, allowing these medical – care products to remain free from additional duties upon importation. The announcement comes after USTR requested public comments on August 27, 2021 on whether the exclusions should be further extended.
Continue Reading USTR Grants 6-Month Extension on Exclusions for 81 COVID-Related Products