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August 2025

Call 305-456-3830 or email info@diaztradelaw.com.

Census Bureau Releases Final Rule Clarifying Filing Requirements for In-Transit Shipments 

On August 14, 2025, The Census Bureau issued a final rule to clarify its regulations governing in-transit shipments from foreign countries through the United States that are subsequently exported to a foreign destination. The rule takes effect September 15, 2025. 

Background

The Census Bureau is responsible for collecting, compiling, and publishing import and export trade statistics for the United States. As part of this responsibility, the Census collects Electronic Export Information (EEI) in concert with the export control and enforcement functions of U.S. Customs and Border Protection (CBP) of the Department of Homeland Security (DHS), the Bureau of Industry and Security (BIS), and the Directorate of Defense Trade Controls (DDTC).

Public Law 107-228 directed the Census to publish regulations requiring exporters to file Shippers’ Export Declarations. As a result, the bureau experienced an increase in the number of inquiries regarding in-transit movements. Accordingly, in October of 2024 the Census solicited comments on a proposed rule to clarify its regulations governing in-transit shipments. The bureau received 11 letters and emails commenting on the proposed rule.

Key Changes

In addition to making definitional, grammatical and style changes, the rule: (i) clarifies who is the USPPI; (ii) makes changes to mandatory filing requirements; (iii) makes changes to voluntary self-disclosures.  

Who is the USPPI

The U.S. Principal Party in Interest (USPPI) is the person or legal entity in the United States that receives the primary benefit, […]

By |2025-08-15T09:26:51-04:00August 15, 2025|Brokers, EEI, Enforcement, Export, International Trade, Pre-compliance, U.S. Census Bureau|0 Comments
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New AD/CVD Case Filed: High Purity Dissolving Pulp from Brazil and Norway

A new antidumping and countervailing duty action has been filed on high purity dissolving pulp from Brazil and Norway. The allegation is that imports from Brazil and Norway are unfairly subsidized and are being dumped.  

Full list of exporters here. 

Full list of importers here.   

Background on AD/CVD Investigations  

Antidumping duty (“AD”) and countervailing duty (“CVD”) investigations are brought jointly by the U.S. International Trade Commission (“USITC”) and the U.S. Department of Commerce (“Commerce”). AD investigations are triggered when a domestic industry alleges that it has been injured by competing imports of particular goods from specific countries being sold at less than a fair value. Meanwhile, CVD investigations are triggered when a domestic industry alleges that it has been injured by competing imports that are being unfairly subsidized by their governments. The domestic industry initiating the investigation is known as the petitioner while the foreign industry participating in the investigation is known as the respondent. 

Scope of the Investigation 

The merchandise covered by these investigations is high purity dissolving pulp.  

The products subject to the investigations are currently classified in the Harmonized Tariff Schedule of the United States (HTSUS) under subheadings 4702.00.0020 and 4702.00.0040.  

Full scope here.

Next Steps 

The Commerce Department will determine whether to initiate the investigations within 20 days. The USITC will reach a preliminary determination of material injury or threat of material […]

By |2025-08-13T13:09:00-04:00August 13, 2025|AD/CVD, U.S. Department of Commerce (DOC)|0 Comments
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Breaking Trade News: Reciprocal Tariffs Take Effect, Additional Tariffs on India, FDA Food Traceability Extension

Here is a recap of the latest customs and international trade news:    

Administration
  • The Administration’s reciprocal tariffs took effect on August 7. Goods from more than 60 countries now face additional tariffs between 10% and 41%.
  • On August 6, President Trump signed an Executive Order imposing an additional 25% tariff on imports from India to take effect Aug. 27. This applies on top of the 25% reciprocal tariff.
  • President Trump told reporters that the U.S. will be imposing a tariff of “approximately 100%” on chips and semiconductors.
Customs and Border Protection (CBP)
  • CBP published additional guidance on reciprocal tariffs. The guidance covers additional information on what goods are exempt, reiterates which goods are subject to reciprocal tariffs, the reporting sequence for HTSUS numbers, and how CBP will process goods determined to be transshipped.  
  • CBP released a Harmonized System Update on August 5 that contained 404 Automated Broker Interface records and 135 Harmonized Tariff Schedule records. 
  • CBP published guidance on how brokers and importers should apply the new 40% duties on goods imported from Brazil.
  • CBP, in partnership with the FDA, seized 54,843 […]
By |2025-08-08T10:41:50-04:00August 8, 2025|news, Snapshot|0 Comments
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ICYMI: Technology Company Pleads Guilty to Export Control Violations, Agrees to $140M Fine

The U.S. Attorney’s Office for the Northern District of California and the Counterintelligence and Export Control Section (CES) of the Department of Justice’s (DoJ) National Security Division announced that Cadence Design Systems, Inc. of San Jose, California, agreed to plead guilty to resolve criminal violations of export controls. 

As part of the plea agreement, Cadence will pay criminal penalties of nearly $118 million. 

In addition to the charges, the Department of Commerce’s Bureau of Industry and Security (BIS) also announced the resolution of a civil enforcement action against the company in which Cadence agreed to pay over $95 million in civil penalties. 

The DoJ and BIS have coordinated the resolution of the parallel investigation, and each agreed to a partial credit against their fine for payments made to satisfy the other agency’s fine. Under the coordinated agreement, Cadence will pay criminal and civil penalties of more than $140 million.

Cadence committed criminal violations of the export control laws by selling hardware, software, and semiconductor design intellectual property to the National University of Defense Technology (NUDT) in China. NUDT was added to the Department of Commerce’s Entity List in February 2015. The university was involved in the development of supercomputers with applications for military and nuclear explosive simulations. 

Cadence and its Chinese subsidiary engaged in a conspiracy to commit export control violations by exporting this technology to NUDT without obtaining the requisite licenses from […]

By |2025-08-07T11:02:32-04:00August 7, 2025|EAR, Enforcement, Export, International Trade, Technology, U.S. Bureau of Industry and Security (BIS), U.S. Department of Justice (DOJ)|0 Comments
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Jennifer Diaz Featured in Inside U.S. Trade

We are pleased to announce that DTL President Jennifer Diaz was recently featured in Inside U.S. Trade!

In the article, “New Transshipment Limits Could Bring Confusion, Enforcement Hurdles,” reporter Brett Fortnam walks through how the Administration’s new approach to combatting transshipment includes goods with significant content from third countries in addition to traditional transshipment. He quoted Jennifer on how this approach is likely to cause confusion up and down the supply chain.

Below are a few snippets from the piece. Read the full article on InsideTrade.com here.

“Diaz said a new approach to transshipment will sow confusion up and down the supply chain. Changing what confers a product’s country of origin ‘adds another pillar of complexity’ to already complicated rules of origin, Diaz said.”

“If I were CBP, I would have a hard time understanding what kind of documentation and proof will be necessary,” Diaz said of the new policy. “Are we going to have the ability to audit raw material for every item? We all need a framework to start with. Now we’re all subject to audit risk, penalties and criminality. We need a good framework to ensure that everyone has the ability to comply.”

Diaz Trade Law is tracking the latest updates to U.S. trade policy.

Learn more:

By |2025-08-05T13:34:46-04:00August 5, 2025|Import, news, Supply Chain|0 Comments
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