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2024

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

2024: A Year in Review

As we wrap up this extraordinary year, we want to take a moment to thank you for your trust, collaboration, and support. This year was marked by significant milestones and meaningful accomplishments, including saving our clients MILLIONS of dollars.

We look forward to working with you in 2025! 

Top 2024 Success Stories

Assisted Numerous Importers in Filing Prior Disclosures

  • Diaz Trade Law submitted numerous prior disclosures to CBP on behalf clients. CBP considered the admission of the false statements made at the time of entry as violations of Title 19, United States Code, Section 1592. However, Diaz Trade Law’s claim for prior disclosure treatment was successful and no further penalty was assessed by CBP.

 Binding Ruling Requests

  • An importer of sports equipment retained Diaz Trade Law to submit a binding ruling request to CBP. We drafted a persuasive binding ruling request and CBP agreed with our classification and issued a binding ruling reflecting the proposed HTS classification.
  • Diaz Trade Law requested a binding ruling on behalf of our client on a valuation-related inquiry. CBP agreed with our assessment and provided a binding ruling agreeing that transaction value was an acceptable formula and any adjustments to that value can be made via reconciliation.

 CPSC, EPA, and FDA Detention Assistance

  • The U.S. Consumer Product Safety Commission (CPSC) detained our client’s imported goods. CPSC found the goods to be violative and recommended Diaz Trade Law reviewed the case and received authorization from CBP to recondition the goods. CPSC released the goods saving our client from an unnecessary and costly seizure.
  • The […]
By |2024-12-27T12:20:29-05:00December 27, 2024|news|0 Comments
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Customs and Trade News Weekly Snapshot

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

Customs and Border Protection (CBP) 

  • CBP released the November 2024 monthly update. Highlights: 
    • Identified estimated duties of nearly $6.97 billion to be collected 
    • Stopped 669 shipments for further examination based on the suspected use of forced labor 
    • Seized 1,532 shipments that contained counterfeit goods 
  • CBP issued a ruling stating that food that was denied entry but can be reconditioned to meet FDA requirements isn’t prohibited merchandise, so it isn’t eligible for a refund if it’s exported or destroyed. 
  • CBP officers in Louisville seized four shipments containing 962 pieces of counterfeit designer watches, bracelets, necklaces, and earrings.  
  • CBP published updated draft Cargo Release CATAIR, draft Global Business Identifier Enrollment Create-Update, GBI Enrollment GO Status Notification, and GBI Condition Codes documents to its website. 

Bureau of Industry and Security (BIS) 

  • BIS imposed a $180,000 mitigated penalty against Indium Corporation for 11 exports of electronics manufacturing components to […]
By |2024-12-28T12:05:02-05:00December 26, 2024|Snapshot|0 Comments
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Clock Ticking: Potential Government Shutdown on the Horizon

Government funding will lapse at midnight on Friday, December 20 absent Congressional action. With a number of contentious issues still at play including the debt limit, disaster aid funding, and pay raises for lawmakers, a shutdown is looking more and more likely.

Below is a breakdown of how key agencies will be impacted by a lapse in funding.

U.S. Customs and Border Protection

According to the Department of Homeland Security’s contingency plan, cargo inspection functions at ports of entry will remain active during a shutdown. However, certain activities such as training and auditing are not required to be carried out during this time. In addition, back-office support positions are not likely to be deemed essential and will be furloughed. Refunds, audits, ruling requests, etc. would be delayed until the shutdown ends.

There remains uncertainty around which specific offices will be deemed essential. For example, Forced Labor Communications may be furloughed, resulting in delays in reviewing Enforce and Protect Act (EAPA) and Uyghur Forced Labor Prevention Act (UFLPA) allegations.

U.S. Department of Commerce

According to the Department of Commerce’s contingency plan, some International Trade Administration (ITA) activities such as trade policy negotiations will be considered necessary for national security and will operate during a shutdown.

However, many other activities are not likely to be deemed essential. For example, in the last shutdown in 2019, the ITA and the Bureau of Industry and Security operated with a significantly reduced staff and budget. All antidumping and countervailing duty (AD/CVD) investigations and administrative proceedings will stop.

U.S. Department of Treasury

Under the Department of Treasury’s 

By |2024-12-20T17:15:35-05:00December 20, 2024|news|0 Comments
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Customs and Trade News Weekly Snapshot

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

Customs and Border Protection (CBP) 

  • CBP authorized the release of most types of merchandise on or after Dec. 17 through Dec. 31 under Immediate Delivery procedures. 
  • Reminder: On January 11, 2025, CBP will deploy the second release of the Section 321 – Does Not Exceed $800 in Aggregated Shipments enhancement to the Automated Commercial Environment (ACE). This enhancement will provide a warning in ACE when a de minimis shipment may exceed the $800 per person/per day threshold. 
  • CBP seized $81.5 million in unapproved electronic nicotine delivery systems. 

Consumer Product Safety Commission (CPSC) 

  • CPSC approved a Final Rule to implement electronic filing (eFiling) of Certificate information for regulated, imported consumer products and to revise requirements for Certificates of Compliance. 

U.S. Food and Drug Administration (FDA) 

  • The FDA announced new EU requirements for importing honey and other apiculture products, effective November 29, 2024. The EU regulation requires that all establishments importing apiculture products into the EU (including honey, beeswax, royal jelly, propolis, and pollen) must register in the EU’s Trade Control and Expert System (TRACES). 

U.S. Department […]

By |2024-12-20T15:00:13-05:00December 20, 2024|Snapshot|0 Comments
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CPSC Approves Final Rule to Implement eFiling for Certificates of Compliance

The CPSC voted unanimously in favor of a Final Rule to implement electronic filing (eFiling) of Certificate information for regulated, imported consumer products.

The new eFiling program will apply to all imported consumer products subject to a mandatory safety standard, including de minimis shipments. Requirements impacting most imported consumer products and those produced domestically will take effect in July 2026.

Background – CPSC’s eFiling Proposal

Since 2008, importers have been required to maintain Certificates of Compliance stating that the product they are importing meets all applicable safety standards. However, these certificates did not need to be filed at the time of import.

In June 2022, CPSC announced a Beta Pilot test with CBP for eFiling of certificate data for regulated consumer products. In 2023, the CPSC and CBP began the test with 38 importer participants. In December 2023, the agencies published a notice expanding the Beta Pilot test to include up to 2,000 additional importer participants and to extend the test for up to three years. In announcing the expansion of the test, the CPSC also proposed a new rule that would require that importers of regulated consumer products eFile Certificates of Compliance at the time of import.

On November 22, 2024, the CPSC’s General Counsel circulated a staff briefing memorandum recommending approval and publication of a final rule implementing the eFiling proposal.

eFiling Requirements

The eFiling rule will impose new requirements for how importers manage product certificate data, not which products require a certificate. Any consumer product that is subject to a CPSC […]

By |2025-07-02T14:13:01-04:00December 19, 2024|U.S. Consumer Product Safety Commission (CPSC)|0 Comments
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