By Bruce Leeds, Senior Counsel, Braumiller Law Group Determining what export controls apply to semiconductor devices can be a challenging task. Most controls on semiconductor devices
Exporting to Russia is already a challenge. There are OFAC sanctions arising out of the Ukraine/Crimea situation, Military End User controls, and the usual export licensing requirements.
In a Federal Register Advance Notice of Proposed Rulemaking, dated Oct. 28, 2020, U.S. Customs & Border Protection (CBP) proposed a program for continuing education for licensed individual customs brokers.
Colleges and universities – Ivy covered buildings with students and faculty engaged in academic pursuits.
Colleges and universities – Hotbeds of export control concerns. What??
The halls of academia have increasingly become involved with export control issues. There are several ways that universities are potentially affected by export controls, including:
Determining the country of origin of imported articles has become increasingly important in recent years. There has long been a requirement that imported articles be marked with the name of the country of origin. Country of origin also determines eligibility for special duties or free trade agreements.
One of the major changes to come out of this trade agreement is elimination of the NAFTA Certificate of Origin. Instead, the USMCA replaces the Certificate of Origin with a certification. In this regard, the USMCA will more closely resemble other free trade agreements, such as the Korean and Australian, which also utilize a certification.
Your company exports to Canada and Mexico. So:
So long as you can produce a Certificate of Origin everything is taken care of
NAFTA and USMCA are import things, so if you are an exporter you have no concerns
The importers in Canada and Mexico are the only ones who have to deal with the requirements
On Jan. 1, 2020 the Japan-United States Free Trade Agreement went into effect. The agreement provides duty-free, or reduced duty treatment, for certain Japanese imports into the U.S. and certain U.S. exports to Japan. The implementation details were printed in the Federal Register on Dec. 30, 2019 (84 FR 72187).
The Bureau of Industry & Security (BIS) of the Department of Commerce announced that it was adding Huawei Technologies Co., Ltd. to the Entity List on May 16, 2019. Not just this Huawei company in China, but also 68 non-US affiliates of Huawei located in 26 countries.
In a Federal Register Notice dated April 12, 2019, the Office of the US Trade Representative (USTR) announced the initiation of an investigation into European Union (EU) subsidies of large aircraft. The notice also contained a list of European origin aircraft and other products targeted for potential additional duties.
