Bruce Leeds, Author at Braumiller Consulting Group

Section 232 Investigation of Commercial Aircraft, Jet Engines and Parts

June 9, 2025

In a recent Federal Register notice the Bureau of Industry & Security (BIS) of the Department of Commerce announced that “On May 1, 2025, the Secretary of Commerce initiated an investigation to determine the effects on the national security of imports of commercial aircraft and jet engines, and parts for commercial aircraft and jet engines. This investigation has been initiated under section 232 of the Trade Expansion Act of 1962, as amended (Section 232).” The investigation may take up to 270 days but it can be concluded sooner.

USMCA – We Have Some Good News and Some Terrible News

April 8, 2025

As is well known the US has imposed duties of 25% on imports from Canada and Mexico. This means that those imports will take the regular duty plus 25%. For example, a switchgear assembly classified under 8537.10.91 made in Canada or Mexico will take a duty of 2.7% plus the special tariff of 25% for a total rate of 27.7% of the value.

Out of This World! Proposed New Regulations on Space and Spacecraft

December 16, 2024

On October 23, 2024, the Directorate of Defense Trade Controls published proposed changes to the International Traffic in Arms Regulations (ITAR) affecting exports of spacecraft and launch vehicles and related activities. Subsequently the department extended the comment period from Nov. 22 to Dec. 23, 2024. The Bureau of Industry & Security (BIS) of the Department of Commerce published corresponding proposed changes to the Export Administration Regulations on Oct. 23, 2024.

What’s Going on With Section 321 De Minimis Entries?

October 8, 2024

Not only are shipments under $800 exempt from duty but they are also exempt from Section 301 duties on Chinese products, Consumer Product Safety Commission requirements, import quotas and other requirements. Although they are supposed to be subject to Antidumping and Countervailing duty and Food & Drug Administration requirements, many low value shipments pass through the system without meeting these requirements.

A Head Scratcher

August 21, 2024

A product has a country of origin of China, is not subject to China 301 duties and is eligible for USMCA benefits when imported from Canada – Whaaat!?

Australia and United Kingdom License Exemptions on the Way!

June 10, 2024

Canada has long enjoyed International Traffic in Arms Regulations (ITAR) license exemptions and minimal controls for items subject to the Export Administration Regulations (EAR). What about some of our other friends, such as Australia and United Kingdom? There are ITAR license exemptions for these countries in Parts 126.16 and 126.17 of the ITAR.

What is the “First Sale” Rule and How Does it Affect Me?

February 5, 2024

The First Sale Rule applies in circumstances such as the example above. A US company places an order with a middleman in the US. The middleman in turn subcontracts to a foreign supplier. The supplier then ships the product either to the middleman or to the original US company that placed the order, meaning either could be the importer of record. The entered value could be the amount on the original purchase order or the price paid by the middleman to the foreign supplier.

Challenges Ahead! – Requesting to be Excluded From the Xinjiang Exclusions

November 10, 2023

In April of this year U.S. Customs & Border Protection (CBP) issued Headquarters Ruling H330077. The ruling was in response to a protest filed by an importer that had a shipment of wearing apparel excluded from entry under a Withhold Release Order (WRO) at the port of Newark, NJ. The wearing apparel was processed from cotton produced in India, made into yarn and fabric in China, and converted to wearing apparel in Cambodia. None of the parties to the transaction were located in the Xinjiang Region of China.

Hot Topics In International Trade: Customs Broker Modernization Regulations 19 CFR 111

November 3, 2023

Bruce Leeds discusses the changing landscape for customs brokers amid changes recommended by COAC (Commercial Customs Advisory Committee) which is an advisory committee to U.S. customs. The result are changes to modernize regulations through an overhaul of part 111 of the customs the regulations, including responsible supervision and control.

Customs Brokers: Giving Credit to Accreditors

August 7, 2023

U.S. Customs & Border Protection (CBP) published the Final Rule on continuing education for individual customs broker license holders in the Federal Register on June 23, 2023. This Final Rule made several changes to Part 111 of the Customs Regulations and imposed a continuing education requirement on individual license holders.

Bruce Leeds

Bruce Leeds

Section 232 Investigation of Commercial Aircraft, Jet Engines and Parts

USMCA – We Have Some Good News and Some Terrible News

Out of This World! Proposed New Regulations on Space and Spacecraft

What’s Going on With Section 321 De Minimis Entries?

A Head Scratcher

Australia and United Kingdom License Exemptions on the Way!

What is the “First Sale” Rule and How Does it Affect Me?

Challenges Ahead! – Requesting to be Excluded From the Xinjiang Exclusions

Hot Topics In International Trade: Customs Broker Modernization Regulations 19 CFR 111

Customs Brokers: Giving Credit to Accreditors

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