Who is the Importer of Record: Security Interests and the Right to Act As IOR
By:Ā 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 āowner or purchaserā 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.
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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 Intāl 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.
Key Legal Developments in 2023 Concerning United States Customs and International Trade
ByĀ Adrienne Braumiller, Founding Partner Harold Jackson, Associate Attorney Gavin Andersen, Braumiller Consulting Trade Advisor Section 301 Tariffs on Chinese goods continues to be at the forefront of international trade relations with China and the United States. As part of the four-year review required under the relevant statute (19 USC Ā§ 2417), the United States Trade […]
Using CBPās Enforcement Statistics to Assess Forced Labor Risk in the Supply Chain
The U.S. continues to spearhead enforcement against imported goods that were made using forced labor, and public enforcement statistics can help your company assess risks of forced labor.
Complying with BISās Advanced Computing and Semiconductor Manufacturing Rules ā Knowledge, Due Diligence, and Technology Thresholds
U.S. industries supplying Chinese facilities with products, equipment, software, and technology used in semiconductor development and production are subject to regulatory controls under the Export Administration Regulations (āEARā). New rules published by the Department of Commerceās Bureau of Industry and Security (āBISā) on October 13, 2022, 87 FR 62186, imposed additional license requirements regarding the […]
Primer on Forced Labor Enforcement for U.S. Importers
This Primer provides introductory guidance to complying with U.S. forced labor laws for importers, and includes an introductory overview to forced labor laws, U.S. Customs and Border Protectionās (CBP) authority to enforce forced labor laws, outlines importer requirements under The Uyghur Forced Labor Prevention Act, describes the detention processes for imported goods made with forced labor, lists key recommended compliance actions for adhering to U.S. forced labor laws, and provides helpful resources for complying with U.S. forced labor laws.
CBP Releases Guidance related to Complying with the Uyghur Forced Labor Prevention Act
U.S. Customs and Border Protection (āCBPā) released its first set of guidance relating to the Uyghur Forced Labor Prevention Act (āUFLPAā), which is set to take effect on June 21, 2022. CBPās guidance takes the form of a website that is a homepage for UFLPA-related guidance, FAQs, webinars, graphics, and CBP contact information. This essential UFLPA homepage can be accessed at: www.cbp.gov/trade/forced-labor/UFLPA.
