Caterpillar to Butterfly
The length of time it takes a caterpillar to turn into a butterfly depends on several factors including the butterfly’s species, host plant type, food availability, habitat threats, and weather conditions. The process of transformation is called metamorphosis, and it takes about two weeks for the butterfly to emerge from its chrysalis. Some transformations may take millions of years. Regardless of the time factor involved, substantial transformation is the key if you wish to convince CBP of the new country of origin. We love the science behind Global Trade Compliance which is all we do.
Country of Origin
Black Hole
Forced Labor Questionnaires: Another Helpful Hint
In February 2024, Customs and Border Protection (CBP) began taking a new approach to Uyghur Forced Labor Prevention Act (UFLPA) enforcement—questionnaires. Once again, the solar industry is among the first targets, vanguards among importers, hacking their way through new regulatory growth, hopefully exposing a clear way through for all who follow. Active enforcement mechanisms like questionnaires—and the Forced Labor Enforcement Task Force (FLETF) itself—are still evolving.
Hot Topics in International Trade – Reasonable Care with Kerry Wang
Braumiller Law Group VP Marketing sits down once again with BLG Senior Associate Attorney Kerry Wang to discuss CBP’s perspective on the meaning of Reasonable Care, and how that translates to international trade compliance.
Who is the Importer of Record: Security Interests and the Right to Act As IOR
By: Gavin Andersen, Law Clerk, LCB and Adrienne Braumiller, Founding Partner, Braumiller Law Group Last June (2023), in response to a ruling request from Your Special Delivery Services Specialty Logistics (YSDS), Customs and Border Protection (CBP) issued HQ H324098, clarifying what it means to be an “owner or purchaser” with sufficient financial interest to act as […]
Challenges Ahead! – Requesting to be Excluded From the Xinjiang Exclusions
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.
Customs and Border Protection
Dealing with CBP. Braumiller Consulting Group can help.
CAFC Refuses to Reverse CIT Decision on Reliquidation Order, Target, Home Products Litigation
This article examines Target Corporation v. United States, Slip Op. 23-106 (Ct Int’l Trade July 20, 2023), a recent ruling by the Court of International Trade (CIT) and its implications on liquidation matters.
Customs Brokers: Giving Credit to Accreditors
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.