HTSUS Archives - Customs & International Trade Law Firm https://diaztradelaw.com/category/htsus/ Jennifer Diaz Wed, 26 Jul 2023 16:40:29 +0000 en-US hourly 1 https://i0.wp.com/diaztradelaw.com/wp-content/uploads/2017/06/ms-icon-310x310.png?fit=32%2C32&ssl=1 HTSUS Archives - Customs & International Trade Law Firm https://diaztradelaw.com/category/htsus/ 32 32 200988546 Customs and Trade Law Weekly Snapshot https://diaztradelaw.com/customs-and-weekly-trade-snapshot-9/ https://diaztradelaw.com/customs-and-weekly-trade-snapshot-9/#respond Fri, 09 Dec 2022 13:45:15 +0000 https://diaztradelaw.com/?p=6617 Here is a recap of the latest customs and international trade law news:

 

 

 

 

U.S. Customs and Border Protection (CBP)

  • U.S. Customs and Border Protection (CBP) is imposing immediate import restrictions on fish and fish products from the New Zealand inshore set net and trawl fisheries deployed in the range of the Maui dolphin, a marine mammal species endemic to the on the west coast of the North Island in response to the United States Court of International Trade order (Slip Op. 22-130) and in cooperation with the National Marine Fisheries Service (NMFS).
  • CBP has implemented Split Processing at the Fort Erie/Peace Bridge Border Crossing for NEXUS/Free and Secure Trade (FAST) Trusted Traveler Programs (TTP) Enrollment Center. A similar split interview process was previously implemented successfully at the Alexandria Bay, N.Y. Port of Entry and Lansdowne Border Crossing and these initiatives represent key strategies to address ongoing demand.

The U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) 

  • The Department of the Treasury announced G7 and Australia, as current members of the Price Cap Coalition, on 2 December 2022 reached consensus on a maximum price of 60 U.S. dollars per barrel for seaborne Russian-origin crude oil in line with the unanimous decision by Member States of the European Union to endorse a price level for the price cap on seaborne Russian-origin crude oil.
  • OFAC is publishing the names of one or more persons that have been placed on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List) based on OFAC’s determination that one or more applicable legal criteria were satisfied. All property and interests in property subject to U.S. jurisdiction of these persons are blocked, and U.S. persons are generally prohibited from engaging in transactions with them.
  • OFAC is publishing the names of one or more persons that have been placed on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List) based on OFAC’s determination that one or more applicable legal criteria were satisfied. All property and interests in property subject to U.S. jurisdiction of these persons are blocked, and U.S. persons are generally prohibited from engaging in transactions with them.
  • OFAC is publishing the names of one or more persons that have been placed on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List) based on OFAC’s determination that one or more applicable legal criteria were satisfied. All property and interests in property subject to U.S. jurisdiction of these persons are blocked, and U.S. persons are generally prohibited from engaging in transactions with them.

Executive Office of the United States President

  • On December 5, the United States and Panama held the third meeting of the Environmental Affairs Council under the United States-Panama Trade Promotion Agreement (TPA). Assistant United States Trade Representative for Environment and Natural Resources Kelly Milton led the U.S. delegation, along with the U.S. Department of State’s Principal Deputy Assistant Secretary for the Bureau of Oceans and International Environmental and Scientific Affairs Jennifer Littlejohn.
    • The Parties highlighted their respective efforts to implement Environment Chapter commitments during the meeting, including their actions to strengthen environmental protection, enforce environmental laws, and promote public participation in environmental decision-making.
  • The United States and Bangladesh today convened the sixth meeting of the United States-Bangladesh Trade and Investment Cooperation Forum Agreement (TICFA) Council. The meeting was co-chaired by Christopher Wilson, Assistant United States Trade Representative for South and Central Asian Affairs, and Tapan Kanti Ghosh, Secretary, Bangladesh Ministry of Commerce. Both delegations included officials from trade, labor, agriculture, and other relevant ministries.

The Department of Commerce (DOC)

  • The U.S. Department of Commerce (DOC) has received requests to conduct administrative reviews of various antidumping duty (AD) and countervailing duty (CVD) orders with October anniversary dates. In accordance with Commerce’s regulations, we are initiating those administrative reviews.
  • DOC preliminarily determines that circular welded non-alloy steel pipe from the Republic of Korea (Korea) was sold at prices below normal value for Husteel Co., Ltd. and not sold at prices below normal value for Nexteel Co., Ltd. during the period of review (POR) November 1, 2020, through October 31, 2021. We invite interested parties to comment on these preliminary results.
  • DOC determines that Metalco S.A., the sole company subject to the 2020-2021 administrative review of the antidumping duty order on corrosion- resistant steel products from the People’s Republic of China, is part of the China-wide entity because it did not demonstrate its eligibility for a separate rate. The period of review (POR) is July 1, 2020, through June 30, 2021.
  • DOC determines that POSCO, a producer/exporter of certain carbon and alloy steel cut-to- length plate from the Republic of Korea, received de minimis net countervailable subsidies during the period of review (POR), January 1, 2020, through December 31, 2020.
  • DOC preliminarily determines that countervailable subsidies are being provided to producers and exporters of chlorinated isocyanurates from the People’s Republic of China  during the period of review (POR), January 1, 2020, through December 31, 2020. Interested parties are invited to comment on these preliminary results.
  • DOC preliminarily determines that sales of monosodium glutamate from the Republic of Indonesia have been made below normal value during the period of review (POR), November 1, 2020, through October 31, 2021. We invite interested parties to comment on these preliminary results.
  • DOC published the notice of initiation and preliminary results of changed circumstances reviews of the antidumping duty (AD) order on silicomanganese from India. For these final results, Commerce continues to find that NAVA Limited is the successor-in-interest to Nava Bharat Ventures Limited in the context of the AD order on silicomanganese from India. Furthermore, NAVA is entitled to NBVL’s AD cash deposit rate.
  • DOC preliminarily finds that Ratnamani Metals & Tubes Ltd. made sales of subject merchandise at less than normal value (NV) in the United States during the November 1, 2020, through October 31, 2021, period of review (POR).

Office of the U.S. Trade Representative (USTR)

  • United States Trade Representative Katherine Tai met with the European Commission Executive Vice President Valdis Dombrovskis to hold the first Ministerial Meeting of the Working Group on large civil aircraft. They affirmed the U.S.-EU Understanding on a Cooperative Framework for Large Civil Aircraft reached in June 2021 and agreed to continue the Working Group’s efforts to confront the challenges posed by China’s non-market economic policies.
  • USTR Katherine Tai, European Commission Executive Vice President Valdis Dombrovskis, and U.S. Department of Labor’s Deputy Undersecretary for International Affairs Thea Lee co-hosted the inaugural principals’ meeting of the U.S. – EU Trade and Labor Dialogue at the University of Maryland, College Park.
  • The Office of the U.S. Trade Representative, the U.S. Department of Labor, and the European Commission led today the inaugural principals’ meeting of the United States and European Union tripartite Trade and Labor Dialogue. The meeting included key U.S. and EU labor and business representatives, and focused on identifying opportunities for governments, labor unions, and businesses to collaborate to eliminate forced labor in supply chains.
  • USTR announced support for extending the deadline to decide whether there should be an extension of the World Trade Organization (WTO) Ministerial Decision on the TRIPS Agreement to cover the production and supply of COVID-19 diagnostics and therapeutics.

U.S. International Trade Commission (USITC)

  • The U.S. International Trade Commission (USITC)  has received a complaint entitled Certain Environmental Monitors with Side-Viewable Illumination and Components Thereof, DN 3657; the Commission is soliciting comments on any public interest issues raised by the complaint or complainant’s filing pursuant to the Commission’s Rules of Practice and Procedure.

 

If you have questions about these updates, contact our Diaz Trade Law attorneys at info@diaztradelaw.com or call us at 305-456-3830.

To receive an email notification whenever a new post is published, please subscribe to our weekly blog here.

]]> https://diaztradelaw.com/customs-and-weekly-trade-snapshot-9/feed/ 0 6617 Customs and Trade Law Weekly Snapshot https://diaztradelaw.com/customs-and-weekly-trade-snapshot-8/ https://diaztradelaw.com/customs-and-weekly-trade-snapshot-8/#respond Fri, 02 Dec 2022 13:45:37 +0000 https://diaztradelaw.com/?p=6615 Here is a recap of the latest customs and international trade law news:

 

 

 

 

U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC)

U.S. International Trade Commission (USITC) 

  • The U.S. International Trade Commission (USITC) has received a complaint entitled Certain Location-Sharing Systems, Related Software, Components Thereof, and Products Containing Same, DN 3655; the Commission is soliciting comments on any public interest issues raised by the complaint or complainant’s filing pursuant to the Commission’s Rules of Practice and Procedure.
  • USITC has determined to review in part the final initial determination issued by the presiding chief administrative law judge  on September 9, 2022. The Commission requests briefing from the parties on certain issues under review, as indicated in this notice.
  • USITC has determined to review in part the final initial determination issued by the presiding chief administrative law judge on September 9, 2022. The Commission requests briefing from the parties on certain issues under review, as indicated in this notice.
  • USITC as received a complaint entitled Certain Cabinet X-ray and Optical Camera Systems and Components Thereof, DN 3656; the Commission is soliciting comments on any public interest issues raised by the complaint or complainant’s filing pursuant to the Commission’s Rules of Practice and Procedure.

U.S. Department of State (DOS)

  • The Department of State (DOS) has submitted the information collection described below to the Office of Management and Budget (OMB) for approval. In accordance with the Paperwork Reduction Act of 1995 we are requesting comments on this collection from all interested individuals and organizations. The purpose of this Notice is to allow 30 days for public comment.

U.S. Consumer Product Safety Commission (CPSC)

  • The U.S. Consumer Product Safety Commission (CPSC) has determined that there is an unreasonable risk of injury and death, particularly to children, associated with clothing storage units (CSUs) tipping over. To address this risk, the Commission is issuing a rule regarding the stability of CSUs. 

Department of Commerce (DOC)

  • The Department of Commerce (DOC) updated two limits for the European Union Steel Tariff Rate Quota (TRQ) Program effective November 30, 2022 to align with production capabilities in Germany and Luxembourg. The effected steel HTS is 7301.10.0000 “Sheet Piling” under Chapter 99 HTS 9903.81.13. The quantity formerly listed for Country of Origin Germany has been reassigned to the quota limit for Country of Origin Luxembourg effective November 30, 2022.

United States Trade Representative (USTR)

  • The U.S. Trade Representative  (USTR) modified the actions in the Section 301 investigation of China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation by excluding from additional duties certain medical-care products needed to address COVID, and subsequently extended certain of these exclusions. The current COVID exclusions — covering 81 medical-care products — are scheduled to expire on November 30, 2022. This notice announces the U.S. Trade Representative’s determination to further extend the 81 COVID exclusions for an additional three months.
  •  USTR announced the United States and United Kingdom jointly hosted the 6th U.S.-UK Small- and Medium-Sized (SME) Dialogue yesterday, bringing together business representatives from both sides of the Atlantic to identify ways to expand bilateral trade and investment and to enhance broad and inclusive SME participation in that trade and investment.

U.S. Customs and Border Protection (CBP) 

  • U.S. Customs and Border Protection (CBP) personnel at all U.S. ports of entry will detain raw sugar and sugar-based products produced in the Dominican Republic by Central Romana Corporation Limited. CBP issued a Withhold Release Order (WRO) against Central Romana based on information that reasonably indicates the use of forced labor in its operations.
    • CBP identified five of the International Labour Organization’s 11 indicators of forced labor during its investigation:  abuse of vulnerability, isolation, withholding of wages, abusive working and living conditions, and excessive overtime.
  • CBP released a reminder for transportation carrier companies that transact with CBP’s ACE systems to please pay the Annual SCAC Code Renewal fee for this year (2022) by Monday, December 5th, to the National Motor Freight Traffic Association (NMFTA) if you have not done so already.  The NMFTA SCAC Code Renewal web link is SCAC Renewal and Application Wizard (nmfta.org).  If you have any questions about the renewal, please email customerservice@nmfta.org

Ocean Energy Management Bureau 

  • The Bureau of Ocean Energy Management (BOEM) will open and publicly announce bids received for blocks offered in the Cook Inlet Planning Area Outer Continental Shelf Oil and Gas Lease Sale 258 (Cook Inlet Sale 258), in accordance with the provisions of the Outer Continental Shelf Lands Act (OCSLA), as amended, and its implementing regulations.

U.S. Department of  Energy (DOE)

  • The U.S. Department of Energy (DOE) announces the availability of the preliminary analysis it has conducted for purposes of evaluating the need for amended energy conservation standards for non-weatherized oil-fired furnaces (NWOFs), mobile home oil-fired furnaces (MHOFs‘), weatherized gas furnaces (WGFs), weatherized oil-fired furnaces (WOFs‘), and electric furnaces (EFs).

U.S. Department of Agriculture (USDA) 

  • The United States Department of Agriculture’s (USDA) electronic system for propagative shipment processing will be offline for routine service maintenance, starting Friday, December 2, 2022, beginning at 6:00 p.m. EST, until Saturday, December 3, 2022, at 7:00 p.m. EST.
    • To ensure expedited agriculture clearance of propagative shipments during this time, we recommend the following:
      • For shipments requiring clearance on Saturday December 3, please contact the USDA plant inspection station that you currently work with regarding propagative shipments. This will avoid delays and ensure that all relevant information is available to conduct clearance activities. All shipments will be inspected per normal procedures; however, the document review, sample selection, and cargo release will take place outside of the system and will be processed electronically after the system is back online.

If you have questions about these updates, contact our Diaz Trade Law attorneys at info@diaztradelaw.com or call us at 305-456-3830.

To receive an email notification whenever a new post is published, please subscribe to our weekly blog here.

]]> https://diaztradelaw.com/customs-and-weekly-trade-snapshot-8/feed/ 0 6615 Customs and Trade Law Weekly Snapshot https://diaztradelaw.com/customs-and-weekly-trade-snapshot-5/ https://diaztradelaw.com/customs-and-weekly-trade-snapshot-5/#respond Thu, 10 Nov 2022 23:08:21 +0000 https://diaztradelaw.com/?p=6592 Here is a recap of the latest customs and international trade law news:

 

 

 

 

U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) 

  • The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is publishing the names of one or more persons that have been placed on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List) based on OFAC’s determination that one or more applicable legal criteria were satisfied. 
  • OFAC is publishing the names of one or more Russian nationals that have been placed on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List) based on OFAC’s determination that one or more applicable legal criteria were satisfied. 
  • OFAC designated four members of an Islamic State of Iraq and Syria (ISIS) cell operating in South Africa who have provided technical, financial, or material support to the terrorist group. Treasury also designated eight companies owned, controlled, or directed by the individuals in this ISIS cell. Treasury remains committed to exposing and disrupting terrorist financing on the African continent. 
  • OFAC designated pursuant to Executive Order (E.O.) 14014 one individual and one entity that facilitate weapons purchases for Burma’s military regime. This action, which is in conjunction with newly issued European Union sanctions, marks the second anniversary of the last general election in Burma on November 8, 2020, which was brutally overturned by a military coup on February 1, 2021. 
  • OFAC is publishing the names of one or more persons that have been placed on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List) based on OFAC’s determination that one or more applicable legal criteria were satisfied. 
  • OFAC is publishing the names of one or more persons and vessels that have been placed on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List) based on OFAC’s determination that one or more applicable legal criteria were satisfied. All property and interests in property subject to U.S. jurisdiction of these persons are blocked, and U.S. persons are generally prohibited from engaging in transactions 
  • OFAC designated Alex Adrianus Martinus Peijnenburg (Peijnenburg), Martinus Pterus Henri De Koning (De Koning), Matthew Simon Grimm (Grimm), and nine entities pursuant to Executive Order (E.O.) 14059 for supplying illicit fentanyl, synthetic stimulants, cannabinoids, and opioids to U.S. markets through internet sales and a host of shell companies. 
  • OFAC designated two business associates of a sanctioned al-Qa’ida financial facilitator and external operations plotter. The two individuals designated today are Mohamad Irshad Mohamad Haris Nizar and Musab Turkmen, who conducted businesses activities to assist Ahmed Luqman Talib (Talib), who was previously designated by OFAC for facilitating the international movement of individuals and finances in furtherance of al-Qa’ida’s objectives.
    • Australian authorities arrested Talib on March 25, 2021, and days later charged him with plotting incursions into foreign states for the purpose of engaging in hostile activities. 
  • OFAC is designating two individuals for engaging in transportation and procurement activities on behalf of the Democratic People’s Republic of Korea (DPRK). These individuals have acted on behalf of Air Koryo, an entity previously designated by OFAC for operating in the transportation industry in the DPRK economy. 

United States Department of Commerce (DOC)

  • The U.S. Department of Commerce (DOC) preliminarily determines that certain producers/exporters of certain hot-rolled steel flat products from the Republic of Korea received de minimis countervailable subsidies during the period of review. The DOC is rescinding this review with respect to 13 companies.  
  • DOC preliminarily determines that the sole mandatory respondent, Habas Sinai ve Tibbi Gazlar Istihsal Endustrisi A.S., a producer and exporter of certain hot-rolled steel flat products from the Republic of Turkey, did not make sales of subject merchandise in the United States at prices below normal value during the period of review.  
  • DOC preliminarily determines that Celik Halat ve Tel Sanayi A.S., a producer/exporter of prestressed concrete steel wire strand from the Republic of Turkey and sole respondent for this administrative review, received countervailable subsidies during the period of review.  
  • DOC and the U.S. International Trade Commission (USITC) have determined that revocation of the antidumping duty and countervailing duty orders on stainless steel sheet and strip from the People’s Republic of China would be likely to lead to the continuation or recurrence of dumping, net countervailable subsidies, and material injury to an industry in the US. Therefore, DOC is publishing a notice of continuation of these AD and CVD orders. 
  • DOC preliminarily finds that Soci Nouvelle des Couleurs Zinciques made sales of subject merchandise at less than normal value during the period of review. 
  • DOC determines that countervailable subsidies are being provided to the producers and exporters subject to the administrative review of carbon and alloy steel threaded rod (threaded rod) from the People’s Republic of China during the period of review  July 29, 2019, through December 31, 2020. 
  • DOC preliminarily determines that there were no shipments of merchandise subject to the antidumping duty order on stainless steel butt-weld pipe fittings from the Philippines during the period of review February 1, 2021, through January 31, 2022, from any of the companies under review. The DOC invites interested parties to comment on these preliminary results. 
  • DOC and  International Trade Administration (ITA), is organizing an Executive-Led Clinical Waste Management Mission to Indonesia and Malaysia on September 11-15, 2023. Clinical Waste Management Trade Mission to Indonesia and Malaysia– originally scheduled for March 6-10, 2023, is now postponed to September 11-15, 2023. The application deadline is now June 30, 2023. 
  • DOC determines that Jilin Bright Future Chemicals Co., Ltd. sold certain activated carbon from the People’s Republic of China at less than normal value during the period of review (POR), April 1, 2020, through March 31, 2021. Commerce also determines that Datong Juqiang Activated Carbon Co., Ltd. (Datong Juqiang) did not make sales of subject merchandise at less than normal value during the POR.  
  • DOC is initiating a changed circumstances review to determine if Kader Exports Private Limited is the successor-in-interest to the Liberty Group in the context of the antidumping duty  order on certain frozen warmwater shrimp from India. DOC preliminarily determined that Kader Exports is the successor-in-interest to the Liberty Group. 
  • DOC finds that Qufu Xinyu Furniture Co., Ltd. did not make sales of subject merchandise at less than normal value during the period of review October 9, 2019, through March 31, 2021; Shanghai Beautystar Cabinetry Co., Ltd. is part of the People’s Republic of China-wide entity; and Jiang Su Rongxin Wood Industry Co., Ltd. is the successor-in-interest to Jiangsu Rongxin Cabinets Co., Ltd.  

United States International Trade Commission (USITC)

  • The U.S. International Trade Commission (USITC) has received a complaint entitled Certain Automated Retractable Vehicle Steps and Components Thereof, DN 3653; the Commission is soliciting comments on any public interest issues raised by the complaint or complainant’s filing pursuant to the Commission’s Rules of Practice and Procedure. 
  • The USITC has issued a limited exclusion order against infringing products manufactured and/or imported by or on behalf of Proton Sports Inc. of Scottsdale, Arizona, and a cease-and-desist order against Proton. The investigation is terminated. 
  • The USITC has determined to issue a limited exclusion order barring entry of certain electrolyte containing beverages and labeling and packaging thereof that are imported by or on behalf of the following defaulting respondents: Carbonera Los Asadores de C.V.; Comercial Trevin˜o de Reynosa, S.A. de C.V.; Distribuidora Mercatto S.A. de C.V.; H & F Tech International S.A. de C.V.; Leticia Ange´lica Saenz Fernandez; Yoselen Susana Martinez Tirado; Grupo Comercial Lux del Norte S.A. de C.V.; and Caribe Agencia Express, S.A. de C.V. The investigation is terminated. 
  • The United States Patent and Trademark Office (USPTO), DOC, in collaboration with the United States Food and Drug Administration (FDA) and the Department of Health and Human Services, is announcing a public listening session on January 19, 2023. The purpose of the listening session is to seek public comments on proposed initiatives for collaboration between the agencies to advance President Biden’s Executive Order on ‘‘Promoting Competition in the American Economy’’.  
    • To assist in gathering public input, the USPTO and the FDA are announcing the establishment of a docket to track feedback received through this notice and a request for comments on these collaborative efforts. 
  • DOC received a countervailing duty petition concerning imports of paper file folders from India filed in proper form on behalf of the Coalition of Domestic Folder Manufacturers (the petitioner), the members of which are domestic producers of paper file folders. The Petition was accompanied by antidumping duty petitions concerning imports of paper file folders from the People’s Republic of China, India, and the Socialist Republic of Vietnam.  
    • DOC finds that the petitioner filed the Petition on behalf of the domestic industry because the petitioner is an interested party as defined in section 771(9)(F) of the Act. DOC also finds that the petitioner demonstrated sufficient industry support with respect to the initiation of the requested CVD investigation. 

United States Department of Agriculture (USDA)

  • The United States Department of Agriculture (USDA) proposal invites comments on updates to the Harmonized Tariff Schedule numbers for paper and paper-based packaging products in the Paper and Paper-Based Packaging Promotion, Research, and Information Order. In addition, this action proposes new language that allows assessment collection to continue even if HTS numbers change in the future. Comments must be received by December 7, 2022. 

United States Customs and Border Protection (CBP)

  • U.S. Customs and Border Protection (CBP) warns travelers to not bring counterfeit consumer goods back from overseas trips after officers last week seized more than $77,000 worth of clothing bearing unauthorized designer brand logos at Washington Dulles International Airport. 
  • CBP’S Jones Act Division of Enforcement (JADE) held local training to raise awareness of the 102-year-old federal statute, officially known as the Merchant Marine Act of 1920. U.S. Coast Guard (USCG) officers, along with CBP import specialists and other personnel, were in attendance to learn the complexities of the act which governs U.S. maritime cabotage. 

The Maritime Administration  (MARAD)

  • The Maritime Administration (MARAD) announced the renewal of the Voluntary Tanker Agreement Program and the publication of its revised Voluntary Tanker Agreement (VTA). The revised VTA replaces a prior version that was last published in September 4, 2008. After publishing the proposed text in the Federal Register in 2019 and hosting a public hearing in August 2020, MARAD has incorporated public input into the revised VTA. 

 

If you have questions about these updates, contact our Diaz Trade Law attorneys at info@diaztradelaw.com or call us at 305-456-3830.

To receive an email notification whenever a new post is published, please subscribe to our weekly blog here.

]]> https://diaztradelaw.com/customs-and-weekly-trade-snapshot-5/feed/ 0 6592 Customs Bulletin Weekly, Vol. 56, October 26, 2022, No. 42 https://diaztradelaw.com/customs-bulletin-weekly-vol-56-october-26-2022-no-42/ https://diaztradelaw.com/customs-bulletin-weekly-vol-56-october-26-2022-no-42/#respond Mon, 31 Oct 2022 12:45:35 +0000 https://diaztradelaw.com/?p=6563 Below is a recap for this week’s Custom’s Bulletin.

  • Period of Admission and Extensions of Stay for Representatives of Foreign Information Media Seeking to Enter the United States
    • This rule amends Department of Homeland Security (DHS) regulations to better facilitate the U.S. Government’s ability to achieve greater reciprocity between the United States and the People’s Republic of China (PRC) relative to the treatment of representatives of foreign information media of the respective countries seeking entry into the other country.
    • For entry into the United States, such foreign nationals would seek to be admitted in I nonimmigrant status as bona fide representatives of foreign information media. Currently, foreign nationals who present a passport issued by the PRC, with the exception of Hong Kong Special Administrative Region (SAR) or Macau SAR passport holders, may be admitted in or otherwise granted I nonimmigrant status until the activities or assignments consistent with the I classification are completed, not to exceed 90 days.
    • This rule amends the DHS regulations to remove the set period of stay of up to 90 days and to allow the Secretary of Homeland Security (Secretary) to determine the maximum period of stay, no longer than one year, for PRC I visa holders, taking into account certain factors.
    • This rule also announces the Secretary has determined the maximum period of stay for which a noncitizen who presents a passport issued by the PRC (other than a Hong Kong SAR passport or a Macau SAR passport) may be admitted in or otherwise granted I nonimmigrant status is one year
    • This rule was effective on October 13, 2022.
  • Arrival Restrictions Applicable to Flights Carrying Persons Who Have Recently Traveled From or Were Otherwise Present Within Uganda
    • This document announces the decision of the Secretary of the Department of Homeland Security (DHS) to direct all flights to the United States carrying persons who have recently traveled from, or were otherwise present within, Uganda to arrive at one of the United States airports where the United States government is focusing public health resources to implement enhanced public health measures.
    • For purposes of this document, a person has recently traveled from Uganda if that person departed from, or was otherwise present within, Uganda within 21 days of the date of the person’s entry or attempted entry into the United States.
    • Also, for purposes of this document, crew and flights carrying only cargo (i.e., no passengers or non-crew), are excluded from the measures herein.
    • The arrival restrictions apply to flights departing after 11:59 p.m. Eastern Daylight Time on October 10, 2022. Arrival restrictions continue until cancelled or modified by the Secretary of DHS and notice of such cancellation or modification is published in the Federal Register.
  • Proposes Revocation of Two Ruling Letters and Proposed Revocation of Treatment Relating to the Tariff Classification of Pan Masala Betel Nut Food Product
    • In NY 830068 and DD H890859, CBP classified the pan masala betel nut food product in heading 2106, HTSUS, specifically in subheading 2106.90.6099, HTSUS Annotated (HTSUSA) (currently subheading 2106.90.99, HTSUS, under the 2022 HTSUS), which provides for “Food preparations not elsewhere specified or include Other: Other: Other: Other.”
    • CBP has reviewed both NY 830068 and DD H890859 and has determined the ruling letters to be in error.
    • It is now CBP’s position that pan masala betel nut food product is properly classified, in heading 2008, HTSUS, specifically in subheading 2008.19.9090, HTSUSA, which provides for “Fruit, nuts and other edible parts of plants, otherwise prepared or preserved, whether or not containing added sugar or other sweetening matter or spirit, not elsewhere specified or included: Other, including mixtures: Other, including mixtures: Other: Other.”
  • Nucor Corporation v. United States
    • Plaintiff Nucor Corporation (“Nucor”) challenges the U.S. Department of Commerce’s (“Commerce” or “the agency”) final results in the 2018 administrative review of the countervailing duty (“CVD”) order on certain carbon and alloy steel cut-to-length plate (“CTL plate”) from the Republic of Korea (“Korea”).
    • Nucor challenges Commerce’s determination not to initiate an investigation into the alleged provision of off-peak electricity for less than adequate remuneration (sometimes referred to as “LTAR”) and Commerce’s determination that mandatory respondent POSCO and its affiliate POSCO Plantec (“Plantec”) do not meet the requirements necessary to find a cross-owned input supplier relationship.
    • The Court ordered the following:
      • 1. That Commerce’s Final Results are sustained in part and remanded in part.
      • 2. On remand, Commerce shall reconsider or further explain its determination not to investigate the alleged off-peak sale of electricity for less than adequate remuneration.
      • 3. On remand, Commerce shall reconsider or further explain its determination not to treat Plantec as a cross-owned input supplier in connection with the supply of scrap.
      • 4. Commerce shall file its remand redetermination on or before January 3, 2023.
      • 5. Subsequent proceedings shall be governed by US-CIT Rule 56.2(h); if, however Commerce determines to investigate whether off-peak electricity is provided for less than adequate remuneration, the Parties may instead file a joint status report addressing the timing of any necessary further administrative proceedings.
      • 6. Any comments or responsive comments must not exceed 4,000 words.
]]> https://diaztradelaw.com/customs-bulletin-weekly-vol-56-october-26-2022-no-42/feed/ 0 6563 Customs and Trade Law Weekly Snapshot https://diaztradelaw.com/customs-and-trade-law-weekly-snapshot-28/ https://diaztradelaw.com/customs-and-trade-law-weekly-snapshot-28/#respond Fri, 14 Oct 2022 12:45:20 +0000 https://diaztradelaw.com/?p=6548 Here is a recap of the latest customs and international trade law news:

 

 

 

 

Customs and Border Protection (CBP)

  • President Biden signed H.R. 8982, the Bulk Infant Formula to Retail Shelves Act on October 10, 2022. Duty-free treatment will only be provided to importers of base powder to be manufactured into infant formula authorized to be marketed in the United States or subject to an enforcement discretion letter from the Food and Drug Administration (FDA). The effective date is October 13, 2022, the third day after signature.

The Office of the United States Trade Representative

  • The Office of the United States Trade Representative announced the next steps in the statutory four-year review of the tariff actions in the Section 301 investigation of China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation following requests for continuation from representatives of domestic industries
    • USTR is seeking public comments, consistent with the statutory directive, to consider the effectiveness of the actions in achieving the objectives of the investigation, other actions that could be taken, and the effects of the actions on the United States economy, including consumers.

United States Department of Commerce (DOC)

  • Department of Commerce (DOC) announced on October 3, 2022, an opportunity to request administrative review and join annual inquiry service list for products on AD/CVD lists.  
  • DOC is issuing a final rule to implement Proclamation 10414, “Declaration of Emergency and Authorization for Temporary Extensions of Time and Duty- Free Importation of Solar Cells and Modules from Southeast Asia.” 
  • DOC is amending the Export Administration Regulations (EAR) in response to Russia’s further invasion of Ukraine on February 24, 2022.
  • DOC and the International Trade Commission (USITC) announced a petition filed on Oct. 12 which alleges paper file folders from China, India, and Vietnam are being sold at less than fair value in the U.S. market, and in India benefiting from countervailable subsidies. The alleged average dumping margins are 116.69 percent for China, 174.19 percent for India, and 214.53 percent for Vietnam.
  • DOC and the U.S. International Trade Commission (USITC) announced on October 12, that revocation of the antidumping duty  order on certain artist canvas from China would likely lead to a continuation or recurrence of dumping and material injury to an industry in the U.S. 
  • DOC determined on October 12, that POSCO and its affiliated companies, made sales of subject merchandise in the United States at less than normal value during the period of review May 1, 2020, through April 30, 2021.
    • DOC intends to disclose the
      calculations for these final results of
      review within five days of the date of
      publication of this notice in the Federal
      Register.
  • DOC and the U.S. International Trade Commission (USITC) announced on October 12, that revocation of the AD/CVD orders on certain biaxial integral geogrid products from China would likely lead to continuation or recurrence of dumping, countervailable subsidies, and material injury to an industry in the U.S.
  • DOC determines that certain steel nails from the United Arab Emirates were sold in the United States at less than normal value during the period of review May 1, 2020, through April 30, 2021.
    • DOC plans to adopt the Preliminary Results as the
      final results of their review.
  • DOC continues to determine that the 30 companies subject to this administrative review of the antidumping duty order on  magnesia carbon bricks from China are part of the China-wide entity because they did not demonstrate eligibility for separate rates.
    • The period of review is September 1, 2020, through August 31, 2021.

U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC)

  • U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned three individuals on October 6, 2022, and one entity connected to Burma’s military regime pursuant to Executive Order (E.O.) 14014. Following the February 1, 2021, coup that overthrew Burma’s democratically elected civilian government, the military has committed numerous atrocities against people in Burma, including the violent repression of political dissent, the killing of over 2,300 innocent civilians, and displacement of more than 900,000 people. 
  • OFAC on October 6, 2022, designated seven senior leaders within Iran’s government and security apparatus for the shutdown of Iran’s Internet access and the continued violence against peaceful protesters in the wake of the tragic death of 22-year-old Mahsa Amini, who was arrested for allegedly wearing a hijab improperly, and died in the custody of Iran’s Morality Police. 
  • OFAC on September 30, 2022, placed hundreds of Russian individuals and entities on the Specially Designated Nationals (SDN) List in response to Russia’s illegal annexation of Ukrainian territories.  
  • OFAC on September 29, 2022, sanctioned an international network of companies involved in the sale of hundreds of millions of dollars’ worth of Iranian petrochemicals and petroleum products to end users in South and East Asia. 
  • OFAC on October 7,2022, designated Malaysian national Teo Boon Ching, the Teo Boon Ching Wildlife Trafficking Transnational Criminal Organization (TCO), and the Malaysian company Sunrise Greenland Sdn. Bhd. for the cruel trafficking of endangered and threatened wildlife and the products of brutal poaching. 
  • OFAC on October 7, 2022, designated two individuals and three entities for activities related to the exportation of petroleum to the Democratic People’s Republic of Korea (DPRK), which directly supports the development of DPRK weapons programs and its military. 
  • OFAC and Financial Crimes Enforcement Network (FinCEN) announced settlements for over $24 million and $29 million, respectively, with Bittrex, Inc. (Bittrex), a virtual currency exchange based in Bellevue, Washington. 
  • OFAC is publishing one general license (GL) issued pursuant to the Iranian Transactions and Sanctions Regulations: GL D-2, which was previously made available on OFAC’s website.
  • OFAC is publishing one sectoral determination issued pursuant to an April 15, 2021 Executive order, as well as a category of services determination issued pursuant to an April 6, 2022 Executive order.
  • OFAC is publishing one general license (GL) issued pursuant to the Russian Harmful Foreign Activities Sanctions Regulations: GL 13B, which was previously issued on OFAC’s website.
  • OFAC is publishing nine general licenses (GLs) issued in the Venezuela Sanctions Regulations program: GLs 3, 3A, 3B, 3C, 3D, 3E, 3F, and 3G, each of which was previously issued on OFAC’s website and is now expired, as well as GL 3H, which was also previously issued on OFAC’s website.
  • OFAC is publishing eight general licenses (GLs) issued in the Venezuela Sanctions Regulations program: GLs 9, 9A, 9B, 9C, 9D, 9E, and 9F, each of which was previously issued on OFAC’s website and is now expired, as well as GL 9G, which was also previously issued on OFAC’s website.
  • OFAC published the names of one or more persons that have been placed on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List) based on OFAC’s determination that one or more applicable legal criteria were satisfied. All property and interests in property subject to U.S. jurisdiction of these persons are blocked, and U.S. persons are generally prohibited from engaging in transactions with them.

United States International Trade Commission (USITC)

  • United States International Trade Commission (USITC) hereby gives notice of the institution of investigations and commencement of preliminary phase antidumping and countervailing duty investigation Nos. 701-TA-682 and 731-TA-1592-1593 (Preliminary) pursuant to the Tariff Act of 1930 (“the Act”) to determine whether there is a reasonable indication that an industry in the United States is materially injured or threatened with material injury, or the establishment of an industry in the United States is materially retarded, by reason of imports of certain freight rail couplers and parts thereof from China and Mexico, provided for in subheadings 8607.30.10 and 7326.90.86 of the Harmonized Tariff Schedule of the United States, that are alleged to be sold in the United States at less than fair value and alleged to be subsidized by the Government of China. 

United States Department of Labor (DOL)

  • Department of Labor (DOL) has updated its list of goods produced by child or forced labor on September 28, 2022, and is now comprised of 158 goods from 77 countries.  

The White House and Congress

  • President Biden issued an executive order on September 15, 2022, elaborating upon existing statutory factors and include additional national security factors the Committee on Foreign Investment in the United States (CFIUS or “Committee”) must consider in its review process of a covered transaction. 
  • United States Senate on September 21, 2022, ratified the Kigali Amendment which will phase down global production and consumption of hydrofluorocarbons (HFCs), super-polluting chemicals in technology markets.  
  • President Biden on September 15, 2022, issued an executive order elaborating on statutory factors and additional national security factors the Committee on Foreign Investment in the United States must consider in its review process of covered transactions.

Bureau of Industry and Security (BIS)

  • The Bureau of Industry and Security (BIS) is amending the Export Administration Regulations (EAR) to implement necessary controls on advanced computing integrated circuits (ICs), computer commodities that contain such ICs, and certain semiconductor manufacturing items.
    • In addition, BIS is expanding controls on transactions involving items for supercomputer and semiconductor manufacturing end uses.
  • BIS is amending the Export Administration Regulations (EAR) by adding 31 persons to the Unverified List (UVL). The 31 persons of China are added to the UVL on the basis that BIS was unable to verify their bona fides because an end-use check could not be completed satisfactorily for reasons outside the U.S. Government’s control.

British Broadcasting Channel (BBC)

  • BBC reports that shares in major Asian computer chipmakers have fallen following the U.S. implementing a ban on American firms from selling certain chips.

Customs and Border Protection (CBP) Bulletin Weekly, Vol. 56, October 5, 2022, No. 39

  • Extension and Amendment of Import Restrictions on Archaeological and Ethological Materials from Mali
    • This document amends the U.S. Customs and Border Protection (CBP) regulations to reflect an extension and amendment of import restrictions on certain categories of archaeological and ethnological material from the Republic of Mali (Mali) to fulfill the terms of the new agreement, titled ‘‘Agreement Between the Government of the United States of America and the Government of the Republic of Mali Concerning the Imposition of Import Restrictions on Categories of Archaeological and Ethnological Material of Mali.’’
    • The Designated List, which was last described in CBP Dec. 17–12, is amended in this document to reflect additional categories of archaeological material found throughout the entirety of Mali and additional categories of ethnological material associated with religious activities, ceremonies, or rites, and enforcement of import restrictions is being extended for an additional five years by this final rule
  • Quarterly interest rates used in calculating interest on overdue accounts and refunds on Customs duties
    • This notice advises the public that the quarterly Internal Revenue Service interest rates used to calculate interest on overdue accounts (underpayments) and refunds (overpayments) of customs duties will increase from the previous quarter.
    • For the calendar quarter beginning October 1, 2022, the interest rates for overpayments will be 5 percent for corporations and 6 percent for non-corporations, and the interest rate for underpayments will be 6 percent for both corporations and non-corporations
  • Proposed revocation of two ruling letter and proposed revocation of treatment relating to the tariff classification of pan masala betel nut food product
    • In NY 830068 and DD H890859, CBP classified the pan masala betel nut food product in heading 2106, HTSUS, specifically in subheading 2106.90.6099, HTSUS Annotated (HTSUSA) (currently subheading 2106.90.99, HTSUS, under the 2022 HTSUS), which provides for “Food preparations not elsewhere specified or included: Other: Other: Other: Other.”
    • CBP has reviewed both NY 830068 and DD H890859 and has determined the ruling letters to be in error. It is now CBP’s position that pan masala betel nut food product is properly classified, in heading 2008, HTSUS, specifically in subheading 2008.19.9090, HTSUSA, which provides for “Fruit, nuts and other edible parts of plants, otherwise prepared or preserved, whether or not containing added sugar or other sweetening matter or spirit, not elsewhere specified or included: Other, including mixtures: Other, including mixtures: Other: Other.”
  • New American Keg v. United States
    • Because the Department of Commerce failed to explain why it was appropriate to inflate a Mexican labor wage rate using Brazilian data and why doing so was superior to using a Brazilian labor wage rate and to identify the evidence in the administrative record that supported granting a company a separate rate, the case had to be remanded.
  • Hyundai Steel Company v. United States
    • Because the Commerce Department reopened the record and necessary information was available, the court concluded that the Department’s decision to recalculate plaintiff’s dumping margin at 0.46% without applying facts available was supported by substantial evidence. Because the court sustained the Department’s decision to not use facts available in recalculating plaintiff’s dumping margin, consideration of the Department’s reiterated benefit determination in the remand results would have no practical significance and was mooted.
  • United States v. Zhe “John” Liu
    • Zhe “John” Liu and GL Paper Distribution, LLC (collectively, “Liu”), has moved pursuant to USCIT Rule 12(f) to strike portions of the complaint presented by the United States (“Government”), arguing that paragraphs 5–10, 14, 16, 17, 21, 22, and the majority of paragraph 3 of the complaint are “wholly unrelated to the underlying action and contain allegations that are potentially prejudicial.”
    • Motion to strike denied
  • Eteros Technologies v. United States
    • Washington State’s repeal of certain prohibitions attending marijuana-related drug paraphernalia “authorized” plaintiff such that plaintiff’s importation of component parts of an agricultural machine, which was designed to separate the leaf from the flower of cannabis or other plant material, through the Port of Blaine, Washington was exempted by the federal Controlled Substances Act, 21 U.S.C.S. § 863(f)(1), from the federal prohibition on importing drug paraphernalia.

Customs and Border Protection (CBP) Bulletin Weekly, Vol. 56, October 12, 2022, No. 40

  • Extension of import restrictions on archaeological and ecclesiastical ethnological materials from Guatemala
    • This document amends the U.S. Customs and Border Protection (CBP) regulations to reflect an extension of import restrictions on certain categories of archaeological and ecclesiastical ethnological materials from Guatemala to fulfill the terms of the new agreement, titled ‘‘Memorandum of Understanding between the Government of the United States of America and the Government of the Republic of Guatemala Concerning the Imposition of Import Restrictions on Categories Of Archaeological and Ethnological Material of Guatemala.’’
    • CBP Dec. 12–17, which contains the Designated List of archaeological and ecclesiastical ethnological material from Guatemala to which the restrictions apply, is being extended for an additional five years by this final rule.
  • Proposed modification of one ruling letter and proposed revocation of treatment relating to the tariff classification of finished wood slats and wood bottom rails with UV coatings used for window blinds
    • In NY N041645, CBP classified various wood components used for the manufacture of window blinds, including two styles of finished wood valances and wood slats that were primed and painted and three styles of finished wood slats and wood bottom rails that were either stained or painted and coated with UV coatings, in heading 4409, HTSUS, specifically in subheading 4409.29.9000, HTSUSA (“Annotated”) , which provides for “[w]ood (including strips and friezes for parquet flooring, not assembled) continuously shaped (tongued, grooved, rebated, chamfered, V-jointed, beaded, molded, rounded or the like) along any of its edges, ends or faces, whether or not planed, sanded or end-jointed: Nonconiferous: Other: Other: Other.” CBP has reviewed NY N041645 and has determined the ruling letter to be partially in error.
    • It is now CBP’s position that the finished wood slats and wood bottom rails with UV coatings used for window blinds are properly classified, in heading 4421, HTSUS, specifically in subheading 4421.99.9880, HTSUSA, which provides for “[o]ther articles of wood: Other: Other: Other: Other…Other.”
  • Proposed modification of one ruling letter and proposed revocation of treatment relating to the tariff classification of woven upholstery fabrics
    • In NY N319028, CBP classified the woven upholstery fabrics (Style N1829 (Moriarty), Style D1818 (Glossary), and Style J1819 (Fringe)) in heading 5903, HTSUS, specifically in subheading 5903.90.25, HTSUS, which provides for “Textile fabrics impregnated, coated, covered or laminated with plastics, other than those of heading 5902: Other: Of man-made fibers: Other.” CBP has reviewed NY N319028 and has determined the ruling letter to be in error.
    • It is now CBP’s position that woven upholstery fabrics are properly classified, within either heading 5407, HTSUS, or heading 5515, HTSUS, dependent on the specific subject merchandise at-issue. Specifically it is CBP’s position that the first woven upholstery fabric (Style N1829 (Moriarty)) is properly classified within in subheading 5407.53.20, HTSUS, which provides for “Woven fabrics of synthetic filament yarn, including woven fabrics obtained from materials of heading 5404: Other woven fabrics, including 85 percent or more by weight of textured polyester filaments: Of yarns of different colors: Other,” that the second woven upholstery fabric (Style D1818 (Glossary)) is classified within 5407.73.20, HTSUS, which provides for “Woven fabrics of synthetic filament yarn, including woven fabrics obtained from materials of heading 5404: Other woven fabrics, containing 85 percent or more by weight of synthetic filaments: Of yarns of different colors: Other,” and that the third woven upholstery fabric (Style J1819 (Fringe)) is classified within subheading 5515.12.00, HTSUS, which provides for “Other woven fabrics of synthetic staple fibers: Of polyester stable fibers: Mixed mainly or solely with man-made filaments.”
  • Proposed revocation of one ruling letter and proposed revocation of treatment relating to the tariff classification of a woman’s top
    • In NY N324185, CBP classified a woman’s top in heading 6211, HTSUS, specifically in subheading 6211.42.10, HTSUS, which provides for “Track suits, ski-suits and swimwear; other garments: Other garments, women’s or girls’: Of cotton: Other.” CBP has reviewed NY N324185 and has determined the ruling letter to be in error.
    • It is now CBP’s position that the woman’s top is properly classified in heading 6206, HTSUS, specifically in subheading 6206.30.30, HTSUS, which provides for “Women’s or girls’ blouses, shirts and shirt-blouses: Of cotton: Other: Other.”
  • Proposed revocation of one ruling letter and proposed revocation of treatment relating to the tariff classification of metal storage lockers and cabinets for garage use
    • In NY N310710, CBP classified the metal storage lockers and cabinets in heading 9403, HTSUS, specifically in subheading 9403.20.0081, HTSUSA (Annotated), which provides for “Other furniture and parts thereof: Other metal furniture: Other: Counters, lockers, racks, display cases, shelves, partitions and similar fixtures: Other”. CBP has reviewed ruling letter to be in error.
    • It is now CBP’s position that the metal locker cabinets are properly classified, in heading 9403, HTSUS, specifically in subheading 9403.20.0050, HTSUSA, which provides for “Other furniture and parts thereof: Other metal furniture: Household: Other: Other
  • Proposed revocation of one ruling letter and proposed revocation of treatment relating to the tariff classification of cast-iron cylinder heads and block castings
    • In NY N312073, CBP classified cast-iron cylinder heads and block castings in heading 8409, HTSUS, specifically in subheading 8409.99.91, HTSUS, which provides for “Parts suitable for use solely or principally with the engines of heading 8407 or 8408: Other: Other: Other: For vehicles of subheading 8701.20, or heading 8702, 8703 or 8704.” CBP has reviewed NY N312073 and has determined the ruling letter to be in error.
    • It is now CBP’s position that cast-iron cylinder heads and block castings are properly classified in heading 8409, HTSUS, specifically in subheading 8409.99.10, HTSUS, which provides for “Parts suitable for use solely or principally with the engines of heading 8407 or 8408: Other: Other: Cast-iron parts, not advanced beyond cleaning, and machined only for the removal of fins, gates, sprues and risers or to permit location in finishing machinery.”
  • Proposed revocation of one ruling letter, proposed modification of one ruling letter and proposed revocation of treatment relating to the country of origin of certain air purifiers
    • In NY N322681, CBP determined that the air purifiers, manufactured from parts of Chinese and Vietnamese-origin and further assembled in Vietnam into subassemblies and the finished air purifiers, were products of China. It is now CBP’s position that the country of origin of these air purifiers is Vietnam. In NY N322364, CBP determined that air purifiers, manufactured from parts of Chinese and Vietnamese-origin and further assembled in Vietnam into subassemblies and the finished air purifiers, were products of Vietnam in the first manufacturing scenario and products of China in the second manufacturing scenario.
    • It is now CBP’s position that the country of origin of the air purifiers in the second manufacturing scenario is Vietnam
  • Xi’an Metals & Mineral Import & Export Co v. United States
    • There was no error in the U.S. Court of International Trade’s determination that the CONNUM-specific rule was not subject to the notice-and-comment rulemaking provisions of the APA; hence, the U.S. Department of Commerce was entitled to clarify the regulation regarding the data used in performing margin calculations in the third administrative review because it needed data that more accurately reflected the costs associated with the production and sale of the subject merchandise;
    • The Court correctly determined that Commerce’s application of facts otherwise available (FA) was supported by substantial evidence; in deciding to apply FA, Commerce reasonably determined that appellant’s repeated failure to submit its cost information on a CONNUM-specific basis meant that necessary information reasonably reflecting the costs of production was not available.
  • Kaptan Demir Celik Endustrisi ve Ticaret v. United States
    • A Turkish producer and exporter of steel concrete reinforcing bar was not entitled to a stay pending resolution of its separate action arising from the previous administrative review of the same countervailing duty order where no common legal issue was being reviewed by the appellate court, the administrative reviews were separate actions based on the specific factual records, and thus, the proposed stay did not meaningfully advance judicial economy;
    • In light of the court‘s overarching duty to timely resolve disputes, the interests of the litigants in resolving disputes quickly, as well as the general interest of the public in expeditiously resolving matters of great economic importance, the extensive stay of proceedings requested by the producer and exporter did not meet the pressing need required for such stays.
  • HiSteel v. United States
    • Because the foreign producer of heavy walled rectangular welded carbon steel pipes and tubes did not seek any relief separate from that sought by the producer challenging its individual weighted-average dumping margin, the foreign producer could piggyback on the challenging producer’s standing and did not need to establish independent constitutional standing;
    • Because the underlying litigation consisted of a civil action commenced under § 516A of the Tariff Act of 1930, and because the foreign producer was an interested party who was a party to the proceedings, the foreign producer was to intervene as of right by operation of 28 U.S.C.S. § 2631(j)(1)(B) and Ct. Int’l Trade R. 24(a)(1).
  • AG der Dillinger Huttenwerke et. Al. v. United States
    • This consolidated action involves a challenge to the final determination in the antidumping (“AD”) investigation conducted by the U.S. Department of Commerce (“Commerce”) of certain carbon and alloy steel cut-to-length plate (“CTL plate”) from the Federal Republic of Germany
    • Since the issue, Commerce’s analysis, and the arguments of the parties are nearly identical to those presented in Dillinger France, the court concludes that a remand is equally appropriate here. Because Dillinger has failed to place information on the record demonstrating the actual cost of production of its non-prime products, Commerce may reasonably rely on facts otherwise available pursuant to § 1677e(a)(1); however, in making its selection of facts otherwise available, Commerce must explain how its reliance on information indicating the “likely selling price” of non-prime products accords with its obligation to ensure that the reported costs of production reasonably reflect the cost of producing the merchandise under consideration

 

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]]> https://diaztradelaw.com/customs-and-trade-law-weekly-snapshot-28/feed/ 0 6548 Customs and Trade Law Weekly Snapshot https://diaztradelaw.com/customs-and-trade-law-weekly-snapshot-26/ https://diaztradelaw.com/customs-and-trade-law-weekly-snapshot-26/#respond Fri, 15 Jul 2022 12:45:52 +0000 https://diaztradelaw.com/?p=6371 Here is a recap of the latest customs and international trade law news:

U.S. Department of the Treasury’s Office of Foreign Assets Control

  • On July 11, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) identified and designated an individual engaged in the trafficking of high-caliber firearms from the United States to one of Mexico’s most powerful drug organizations. Today’s action is the result of ongoing efforts by U.S. agencies and the Government of Mexico to disrupt Mexican drug trafficking organizations’ access to weapons, including those sourced in the United States. 
  • On July 7, 2022, the OFAC, issued Venezuela Related General License 40A, effective immediately, authorizing certain transactions involving the exportation or re-exportation of liquefied petroleum gas to Venezuela. The license does not authorize any payment-in-kind of petroleum or petroleum products; or any transactions or activities otherwise prohibited by the VSR, prohibited by any other part of 31 CFR chapter V, or involving any blocked persons other than PdVSA, any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest, or any Government of Venezuela person that is blocked solely pursuant to E.O. 13884.  
  • On July 7, 2022, the Secretary of the Treasury along with heads of other U.S. agencies, delivered a framework for interagency engagement with foreign counterparts to President Biden. Principals under the framework include protecting U.S. global financial stability, reinforcing U.S. leadership in the global financial system, and promoting access to safe and affordable financial services.

U.S. Customs and Border Protection 

  • On July 11, 2022, a Federal Register announced that the HTSUS General Note 3(b) is being updated to include Russia and Belarus as countries subject to column 2 duties as a result of being removed from the most favored nations and column 2 duties were increased on HTSUS subheading 9903.90.08 to 35% for numerous products listed in Annex A of the Notice. 
  • As of July 16, 2022, the U.S. Customs and Border Protection (CBP) announced the members of the 16th term of the Commercial Customs Operations Advisory Committee (COAC). Congratulations to all new members.

The Food and Drug Administration 

  • On July 13, 2022, the Food and Drug Administration (FDA) issued its first two warning letters to manufacturers for unlawfully marketing non-tobacco nicotine e-liquid products without the required authorization. FDA announced, it has issued 107 warning letters to retailers in the last two weeks for illegally selling non-tobacco nicotine products, including certain e-cigarette or e-liquid products, to underage purchasers. 
  • As of July 24, 2022, the FDA announced the UNK is no longer an acceptable UFI and importers of food(s) subject to the FSVP regulation are required to have a DUNS number. After July 24, 2022, customs brokers must transmit an importer’s DUNS number when electronically filing entry for each line of food subject to the FSVP regulation. Electronic entries containing UNK in the Entity Number field will be rejected by CBP’s electronic import system. 

The Department of Justice  

  • On July 8, 2022, the Department of Justice (DOJ) announced a federal grand jury in the District of New Jersey returned an indictment charging a resident of Florida with running a massive operation to traffic in fraudulent and counterfeit Cisco networking equipment with an estimated retail value of over $1 billion. Onur Aksoy, aka Dave Durden, 38, of Miami allegedly ran 19 companies formed in New Jersey and Florida, which imported tens of thousands fraudulent and counterfeit Cisco networking devices from China and Hong Kong.  

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]]> https://diaztradelaw.com/customs-and-trade-law-weekly-snapshot-26/feed/ 0 6371 Bloomberg: Tariff Classification Basics https://diaztradelaw.com/bloomberg-tariff-classification-basics/ https://diaztradelaw.com/bloomberg-tariff-classification-basics/#respond Wed, 26 Jan 2022 20:23:49 +0000 https://diaztradelaw.com/?p=6170 Diaz Trade Law is enthusiastic to announce Bloomberg Law published another one of our articles, “Tariff Classification Basics“! Below is the article reproduced with permission for your reading pleasure. You can read the article here (where you’ll have the ability to access all of the great hyperlinks). Please note you cannot click on the hyperlinks below.

We’d love to hear your feedback!

 

]]> https://diaztradelaw.com/bloomberg-tariff-classification-basics/feed/ 0 6170 Customs and Trade Law Weekly Snapshot https://diaztradelaw.com/customs-and-trade-law-weekly-snapshot-3/ https://diaztradelaw.com/customs-and-trade-law-weekly-snapshot-3/#respond Fri, 21 Jan 2022 20:01:36 +0000 https://diaztradelaw.com/?p=6167 Here is a recap of the latest customs and international trade law news:

BIS 

  • On January 14, 2022, the Bureau of Industry and Security (BIS) issued a notice of information collection regarding a Defense Production Act requirement for U.S. firms to furnish information to the agency regarding offset agreements exceeding $5,000,000 in value associated with sales of weapon systems or defense related items to foreign countries or foreign firms. BIS is soliciting public comments to help evaluate if the proposed information collection is necessary for the proper functions of the Commerce Department, evaluate the accuracy of their estimate of time and cost burden, evaluate ways to enhance the quality, utility, and clarity of the information to be collected, and to minimize the reporting burden.
    • Comments are due no later than March 15, 2022.

CBP 

DOT 

OFAC 

USDA 

USTR 

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]]> https://diaztradelaw.com/customs-and-trade-law-weekly-snapshot-3/feed/ 0 6167 Customs and Trade Law Weekly Snapshot https://diaztradelaw.com/customs-and-trade-law-weekly-snapshot-2/ https://diaztradelaw.com/customs-and-trade-law-weekly-snapshot-2/#respond Fri, 14 Jan 2022 13:45:19 +0000 https://diaztradelaw.com/?p=6163 Here is a recap of the latest customs and international trade law news:

Apparel

  • Nike has ended 2021 as the most valuable apparel firm globally. According to data presented by FinancePR.com, the American outfit achieved a $30.44 billion valuation in 2021, placing it at the helm of the top ten garment firms worldwide.

CBP 

U.S. Census Bureau

China

Department of Commerce 

FDA

  • The FDA is seeking early feedback on a plan to assist stakeholders, including industry, health care professionals, and patients, with a smooth transition away from the temporary emergency measures of the pandemic to the eventual resumption of normal operation.
    • Comments are due March 23, 2022
  • Elizabeth Miller, assistant commissioner for medical products and tobacco operations in FDA’s Office of Regulatory Affairs, announced at a recent FDLI enforcement conference that the FDA will resume unannounced and hybrid inspections of foreign facilities in 2022.
  • On January 1, 2022, the Food and Drug Administration (FDA) opened the Voluntary Qualified Importer Program (VQIP) for FY 2023. Participants in the fee-based program receive expedited review of animal and human foods entering the United States.
  • On January 12, 2022, the U.S. Food and Drug Administration declared they are revoking the standard of identity for French dressing, reacting to a citizen petition from the Association for Dressings and Sauces that shared information documenting that the standard is outdated. The agency is now finalizing the proposed rule issued in December 2020 based on the conclusion that revoking the standard will allow for greater innovation and flexibility of products on the market.
      • The final rule is effective February 14, 2022

HTSUS 

Port Everglades

Sanctions 

USTR

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]]> https://diaztradelaw.com/customs-and-trade-law-weekly-snapshot-2/feed/ 0 6163 2021: A Year in Review https://diaztradelaw.com/2021-a-year-in-review/ https://diaztradelaw.com/2021-a-year-in-review/#respond Thu, 30 Dec 2021 19:00:15 +0000 https://diaztradelaw.com/?p=6141 From all of us at Diaz Trade Law, we are incredibly thankful and grateful for your support this year. Despite this ongoing pandemic, Diaz Trade Law still managed to save our clients MILLIONS of dollars in 2021. It is with great joy that we finish off 2021 filled with numerous achievements and accomplishments were humbled to share with you. We look forward to assisting you in what we envision will be a better and brighter 2022!

Below we share some of our top 2021 success stories with you.

Successfully Mitigated Liquidated Damages Claims 

  • For failure to timely refile rejected entries subject to AD/CV duties:
    • After DTL’s strategic involvement CBP substantially mitigated approximately $5 MILLION in claims down to $26,365.00, successfully saving our client over $4.7 MILLION dollars
    • Our client received 36 liquidated damages notices from CBP totaling over $567,000. After Diaz Trade Law’s successful negotiation with CBP, all 36 cases were canceled by CBP, saving our client $over $567,000!!
  • CBP sent our client a liquidated damages claim in the amount of $150,000. As a result of Diaz Trade Law’s successful petition, CBP mitigated the liquidated damages claim down to $1,500!
  • CBP issued a liquidated damages claim in the amount of $50,000.00. After DTL successfully petitioned CBP, the claim was cancelled!
  • CBP issued a liquidated damages claim in the amount of $36,033.00. After DTL successfully petitioned CBP, the claim was mitigated to $360.33 (the best potential mitigation!).

CBP Detention Assistance 

  • Mere days after being retained, Diaz Trade Law successfully assisted in negotiating with CBP and numerous trademark owners proving that our clients detained goods (collectively valued over $1,000,000.00) were legitimate, receiving either consent TM holder, and/or convincing CBP to release legitimate merchandise that should not have been detained.
  • After CBP detained our client’s electronic merchandise to verify admissibility with the Department of Transportation (DOT)
    • CBP released the electronic goods after DTL proved the merchandise, LED driving lights, were eligible for an “off road” use exception and DOT providing such confirmation.
  • After CBP detained our client’s electronic merchandise to verify the validity of a trademark on the product packaging.
    • Diaz Trade Law proactively communicated with the trademark holder and CBP, who, with the authorization of the trademark holder, permitted the importer to manipulate the merchandise and import the goods saving our client from a costly and lengthy seizure case that potentially exposed our client to CBP penalties.
  • After CBP detained our client’s electronic merchandise to verify the validity of a trademark on the product packaging.
    • After Diaz Trade Law’s immediate involvement in arguing the product was “confusingly similar” and not counterfeit, DTL persuaded CBP to apply the relief afforded to “confusingly similar” seized merchandise and ultimately CBP permitted the exportation – which is relief that is rarely granted for detained products. DTL saved our client from a seizure case and potential penalties.
  • CBP detained 28 containers of our client’s cargo.
    • Diaz Trade Law successfully negotiated with CBP to permit the goods to be reexported and avoid substantial demurrage expenses.

4647 Responses 

  • CBP issued our client a CBP Form 4647 – Notice to Mark, because its electronic car accessories labels had both a country of origin marking and a “Designed in the USA” claim (in separate locations on the label).
    • After 48 hours of Diaz Trade Law’s successful escalation and negotiation with the Electronic Center of Excellence and Expertise, CBP granted a rarely used marking waiver permitting the merchandise to be imported as is, saving our client both money and time.
  • CBP issued our client a CBP Form 4647 – Notice to Mark, because over 1,000 electronic car accessory units did not bear a country of origin marking.
    • Diaz Trade Law successfully and efficiently guided our client through the marking process. Ultimately, the goods were marked and authorized for distribution within recording timing – less than 10 days from the issuance of the 4647, saving our client both money and time.
  • CBPO’s at Port Everglades detained two of our client’s shipments and issued two separate CBP Form 4647s – Notices to Mark because the imported merchandise valued at $98,744.00 did not bear a country of origin marking.
    • Diaz Trade Law successfully and efficiently guided our client through the marking process. Ultimately, the goods were marked and authorized for distribution with record timing – within 7 days from the issuance of the 4647, saving our client both money and time.
  • Diaz Trade Law successfully assisted our client in responding to CBP’s Notice to Redeliver (CBP Form 4647) and provided CBP confirmation that the intellectual property rights displayed on the goods was authorized and our client’s merchandise was released in record timing!

Successfully Assisted Numerous Importers Battle Alleged Intellectual Property Rights Violations

  • Our client’s merchandise was seized by CBP due to an alleged trademark violation.
    • After Diaz Trade Law’s successful petition, CBP issued a decision authorizing our client to relabel and export its legitimate merchandise.
  • CBP detained several shipments of our client’s cargo for both Country of Origin (COO) and Intellectual Property Rights (IPR) reasons.
    • Diaz Trade Law advocated for our client and within less than one week convinced CBP to release our client’s legitimate merchandise detained at numerous ports of entry nationwide.
  • Our client’s designer handbags were seized by CBP due to an alleged counterfeit violation.
    • After Diaz Trade Law’s successful petition, proving that the handbags were legitimate, CBP released our client’s legitimate merchandise.
  • CBP detained our client’s goods valued at $98,744.00 for an alleged IPR validation.
    • Our firm immediately communicated with the appropriate CBP CEE and submitted evidence supporting the legitimacy of the imported goods requesting their immediate release. The CBP CEE agreed with our request and recommended the local port release the shipment, saving our client from a costly and lengthy seizure case.
  • Diaz Trade Law successfully negotiated with CBP on behalf of an aftermarket car part importer to permit the exportation of goods detained for alleged IPR violations, saving the importer from a costly and lengthy seizure and potential penalty.
  • Our client imported electronic merchandise which contained a trademark-violating processing system.
    • After Diaz Trade Law’s successful intervention, Diaz Trade Law received authorization from the trademark holder to permit the violative components to be removed and destroyed, and the larger shell merchandise to be imported in its current form. CBP agreed to these terms, and issued a disposition order authorizing the manipulation and release of the goods as Diaz Trade Law had requested.

Successfully Mitigated Penalty Actions Issued by CBP to our Clients 

  • For importing noncompliant Wood Packaging Material:
    • $91,714 mitigated to 3% of penalty to $2,751.42, saving our client $88,962
    • $69,900 mitigated to 3% of penalty to $6,990, saving our client $60,000
    • $28,478 mitigated to 10% of penalty to $2,847, saving our client $25,631
    • $27,857 mitigated to 10% of penalty to $2,786, saving our client $25,071
    • $19,980.00 mitigated to 10% of penalty to $1,998, saving our client $17,982
  • For filing incorrect Electronic Export Information (EEI)
    • $14,194 mitigated down to $500 (the best possible relief)!
    • $14,194 mitigated to 10% of penalty to $1500, saving our client $12,694

CBP 28 / CBP 29 Responses / CBP Investigations and Rejections

  • Our client received a CBP 28 for a U.S. Australia Free Trade Agreement verification.
    • After Diaz Trade Law filed a successful response proving the imported goods were eligible for preferential duty-free treatment, CBP closed the 28 with a positive CBP 29 (Notice of Action).
  • Our client received a CBP 28 Request for Information from U.S. Customs to verify GSP eligibility.
    • After Diaz Trade Law submitted a substantive response proving the GSP claim was valid, CBP issued a CBP 29 determining that the merchandise qualifies for GSP and no duties are owed to CBP!
  • Our client received a Request for Information (CBP 28) from CBP.
    • Diaz Trade Law filed a 28 response which included a Prior Disclosure. The 28 was closed out, and the disclosure was accepted by CBP resulting in no 1592 penalties being issued to our client.
  • CBP physically inspected our client’s cargo at the time of entry and identified that the commercial invoice and packing slip submitted to CBP did not include one model number included in the cargo. Diaz Trade Law immediately negotiated with CBP to accept an updated invoice and packing list. CBP accepted and released the complete cargo with no further enforcement action taken, saving our client costly demerge fees and other expenses.
  • CBP rejected and refused an importation of tires because CBP alleged the importer did not have a right to make entry. After three uphill battles with CBP and DTL’s strategic recommendation to change the import transaction model, the importer was successfully able to act as IOR and its merchandise was admitted into the US.

USTR/China Tariffs

  • Diaz Trade Law assisted over 100 importers in filing complaints with the Court of International Trade challenging Section 301 tariffs imposed for imported goods under for List 3 and List 4a, requesting full refunds.
  • Diaz Trade Law filed numerous exclusions for goods subject to the Section 301 List 3 and List 4. USTR agreed and granted our client’s exclusion!
  • Numerous clients that were subject to 301 duties used Diaz Trade Law to actively monitor 301 exclusions to ensure they were notified when refunds were a possibility. Diaz Trade Law assisted with not only actively monitoring the relevant exclusions, but also interpreting the applicability, and fighting for refunds via the Protest or PSC process. CBP has accepted numerous Protests, and hundreds of thousands of dollars of refunds were sent to our clients!
  • As a result of Diaz Trade Law’s closely monitoring Section 301 China tariff exclusions, Diaz Trade Law found an applicable exclusion for our client to use and filed two Protests with CBP requesting that CBP refund the China tariffs paid. Our client’s protests were approved by CBP, resulting in a refund of $64,678.00.

Export Compliance and Enforcement Mitigation Assistance

  • Diaz Trade Law is actively assisting exporters:
    • Vetting proposed export transactions
    • Providing voluntary self-disclosures to Census and OFAC
    • Developing an effective export compliance plan
    • Developing export compliance training
    • Mitigation and corrective action
    • Presenting export report cards to clients based upon an analysis of ACE data
    • Analyze export trade data
    • With mitigation of export seizures and penalties
  • Our client needed urgent assistance to ensure it understood the requirements to properly export hazardous materials. Diaz Trade Law successfully and expeditiously secured Competent Authority Approvals for the hazardous material from the U.S. DEPARTMENT OF TRANSPORTATION Pipeline and Hazardous Materials Safety Administration (PHMSA) as well as the Competent Authority of Turkey and Finland.

OFAC/FAA/HSI 

  • Our client’s incoming wire payments of $842,918.92 from Venezuela were blocked by its U.S. bank for possible violations of U.S. sanctions laws.
    • After Diaz Trade Law filed a specific license application with the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), OFAC issued a specific license authorizing the legitimate funds to be unblocked and returned to our client.
  • Our client was being investigated by FAA as a result of a hazardous materials incident.
    • As a result of Diaz Trade Law’s successful involvement, the FAA closed the matter with an informal action!
  • Our client was being investigated by HSI for possible criminal liability.
    • After Diaz Trade Law’s intervention, HSI closed its investigation into our client.

 Protests

  • Diaz Trade Law successfully assisted our client in filing two Protests with CBP. These approvals saved our client over $600,000!!
  • After Diaz Trade Law’s successful Protest of CBP’s AD/CVD bills, our client’s protest was approved by CBP, saving our client over $200,000!!

Binding Rulings

  • Diaz Trade Law successfully requested and received binding rulings for numerous clients confirming:
    • the correct country of origin for its prospective imported merchandise.
    • the correct harmonized tariff schedule (HTSUS) for its imported merchandise.
    • both the origin of their merchandise and appropriate CBP country of origin marking
    • the applicability of a free trade agreement.

Assisted Numerous Importers in Filing Prior Disclosures and Voluntary Self-Disclosures Accepted by CBP 

  • Diaz Trade Law successfully submitted a perfected prior disclosure for underlying classification, valuation, quantity, and 301/China tariff errors. While reviewing ACE data, we identified offsets for the duties owed to CBP. Ultimately, CBP agreed with our assessment and accepted our prior disclosure and tender, resulting in a refund of over $25,000 to our client and ensuring no future penalties would be assessed for our client’s past importing errors.
  • After discovering Electronic Export Information (EEI) filing errors made by one of our clients, Diaz Trade Law assisted our client in proactively filing a Voluntary Self-Disclosure (VSD) with the U.S. Census Bureau and assisting our client in fixing all past errors. The VSD filing was accepted and resulted in the U.S. Census Bureau closing out the matter without penalties being assessed.
  • On behalf of a client, Diaz Trade Law filed a voluntary disclosure with the Office of Foreign Assets Control (OFAC), disclosing potential sanctions violations.
    • Diaz Trade Law worked proactively with OFAC and received this “No Action letter” with no penalties assessed to our client.
  • Diaz Trade Law successfully assisted our client in filing a Voluntary Self-Disclosure (VSD) with the U.S. Census Bureau for violations of the Foreign Trade Regulations.
    • Diaz Trade Law proactively worked with the Census Bureau and corrected past filing errors. The VSD was successfully closed out with no penalties assessed.
  • Diaz Trade Law successfully assisted our client in filing a Prior Disclosure. CBP accepted the prior disclosure with no 1592 penalties being assessed!

Bonded Warehouse

  • After Diaz Trade Law’s successful application, our client’s Bonded Warehouse Application was approved!
  • After its bonded warehouse was activated by CBP, our client realized it wanted to change the total square footage. Diaz Trade Law successfully assisted our client alter its customs bonded warehouse space.

Successfully Assisted Numerous Importers in Various Seizure Cases 

  • CBP seized our client’s vehicle after believing it could have been used to import illegal substances. After Diaz Trade Law’s successful petition proving our client’s innocence, CBP released the vehicle with no penalty assessed
  • $20,868.81 of our client’s currency was seized by CBP. After Diaz Trade Law’s successful petition, $19,868.81 was returned to our client!
  • $15,795 of our client’s currency was seized by CBP. After Diaz Trade Law’s successful petition, $14,795 was returned to our client!
  • $12,157.95 worth of jewelry was seized by Customs after our client failed to declare it. After Diaz Trade Law’s successful Petition, CBP released the jewelry within 22 days.

Awards

  • In 2021, Diaz Trade Law founder Jennifer Diaz was again Chambers ranked in International Trade: Customs – USA – Nationwide

Publications

Key publications written by Diaz Trade Law in 2021 were:

Customized Training Programs & Webinars

Key compliance programs taught by Diaz Trade Law in 2021 were:

Diaz Trade Law values you and appreciates your trust in us to be your Customs and International Trade Law Expert! Contact us at info@diaztradelaw.com to schedule your consultation or customized training today.

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