China

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) has announced that it is further restricting access by Huawei Technologies Co. Ltd. and its designated non-U.S. affiliates (“Huawei”) to U.S.-produced technology and software.  As we have previously discussed, BIS first added Huawei to its Entity List on May 15, 2019 and has continued to impose additional export restrictions on Huawei under the U.S. Export Administration Regulations (“EAR”).  Most recently, BIS published a Federal Register notice to implement the following enhancements.  Although BIS published this Federal Register notice on August 20, 2020, the following rule changes took effect retroactively as of August 17, 2020:

On August 10, 2020, U.S. Customs and Border Protection (CBP) issued a notice announcing that goods produced in Hong Kong and exported to the U.S. must now be marked as a product of China (e.g., Made in China), which we covered in a previous post here.  The marking changes were originally set

On August 10, 2020, U.S. Customs & Border Protection (CBP) issued a notice that goods produced in Hong Kong will need to be marked as a product of China starting on September 25, 2020. The marking changes are the result of the July 14, 2020 Executive Order on Hong Kong Normalization that ended Hong Kong’s special trade status.

On August 6, 2020, the White House issued two (2) Executive Orders (“EO”) banning the popular China-based social media app TikTok and the messaging and electronic payments app WeChat.  Both orders are scheduled to take effect in 45 days (approximately September 21, 2020). While a U.S. ban on TikTok, owned by Beijing-based ByteDance Ltd., had been anticipated, especially after India banned the app earlier this year, the EO on Tencent Holding Ltd.’s (“Tencent”) WeChat was not anticipated and has significant potential business ramifications.

The United States Trade Representative (“USTR”) issued new product exclusions pertaining to the Section 301 List 4A tariffs.  The current tariff is 7.5%.  The new exclusions include one ten-digit HTS subheadings and 9 specific product descriptions that together cover 25 separate exclusion requests.  The full list of excluded products is available here.  According to

On July 30, 2020, the Coalition of American Chassis Manufacturers (“Petitioners”), filed a petition for the imposition of antidumping and countervailing duties on certain chassis and subassemblies from China.

SCOPE OF THE INVESTIGATION

The merchandise covered by this investigation are chassis and subassemblies thereof, whether finished or unfinished, whether assembled or unassembled, whether coated or