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June 2025

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

Breaking the Chains: Forced Labor in Mexico’s Supply Chains

Forced labor is a severe violation of human rights and a persistent global issue affecting millions of individuals. According to the ILO, 27.6 million men, women, and children are in forced labor globally.[1] Over $236 billion USD is generated in illegal profits using forced labor every year.[2]

Both Mexico and the United States have robust legal frameworks to eradicate the use of forced labor and have made great strides in detection and enforcement. However, the secretive nature of the forced labor industry, changing bad actor tactics, and the intensive resourcing required presents challenges to both countries.

Forced Labor in Mexico

While Mexico has made great strides in identifying and preventing forced labor, it is still a problem that impacts hundreds of thousands of citizens. Certain risk factors[3] may make certain individuals more vulnerable to forced labor than others, including:

  • Poverty
  • Unstable immigration status
  • Language barriers
  • Lack of social support systems
  • Physical or developmental disabilities

An estimated 850,000 people are still living in modern slavery today in Mexico.[4] The Department of Labor has identified a list of goods it has reason to believe are produced using child labor and forced labor in Mexico including[5]:

  • Beans
  • Cattle
  • Chile peppers
  • Coffee
  • Cucumbers
  • Eggplants
  • Garments
  • Leather goods/accessories
  • Melons
  • Onions
  • Poppies
  • Pornography
  • Sugarcane
  • Tobacco
  • Tomatoes

Investigations have also uncovered severe forms of child labor including using children in the production and trafficking of drugs and in dangerous agricultural work.[6]

Mexico Efforts to Eliminate Forced Labor in Mexico

Over the […]

By |2025-06-25T16:24:22-04:00June 25, 2025|Countries, Forced Labor, Mexico|0 Comments
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AD/CVD News: New Case Filed Against Oleoresin Paprika from India

A new antidumping and countervailing duty action has been filed against Oleoresin Paprika imported from India. The allegation is that imports from India are unfairly subsidized and 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 coloring additive oleoresin paprika.  

 The products subject to the investigations are currently classified in the Harmonized Tariff Schedule of the United States (HTSUS) under subheadings 3203.00.8000 and 3301.90.1010. Subject merchandise may also enter under HTSUS subheadings 1301.90.9190, 1302.19.9140, and 3205.00.0500. 

By |2025-06-25T14:18:53-04:00June 25, 2025|AD/CVD, news, U.S. Department of Commerce (DOC)|0 Comments
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Five Tips for SMEs Looking to Scale Wellness Brands in the US

DTL President Jennifer Diaz was featured in Santander Navigator! Read below or on Santander here.

Pre-planning and investing in regulatory compliance measures are key to success

The US is the most lucrative wellness market in the world – and for some small and medium-sized enterprises (SMEs) that produce supplements, the potential for growth and a bigger bottom line is difficult to ignore. 

And who would blame them? The US wellness sector is valued at US$2tn and is poised to continue growing, recording an average annual growth rate of 8.3% between 2019 and 2023, according to research by the Global Wellness Institute. 

In contrast, China’s market, ranked the second-largest in the world, trails at a more modest US$870bn, followed by Germany at $310bn.

However, rushing in without being fully compliant could result in products being blacklisted or seized at the border, says Jennifer Diaz, an attorney and founding partner at Miami-based Diaz Trade Law, which specializes in customs and US Food and Drug Administration (FDA) laws and compliance.

Here, Diaz offers her top five tips for new brands to stay compliant and off the FDA’s blacklist.

1. Know the regulators

One of the first steps for SMEs planning to import supplements into the US is to register with the FDA, as they are considered a food product, Diaz says.

Companies also need to designate […]

By |2025-06-17T08:01:40-04:00June 17, 2025|Best Practices, Import Alert, International Business, International Trade, Labeling, Pre-compliance|0 Comments
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DOJ Targets Trade Fraud: Importers Now on Notice as Criminal Division Ramps Up Enforcement

On May 12, 2025, Matthew Galeotti, the Head of the U.S. Department of Justice’s Criminal Division, sent a memo to all criminal division personnel highlighting the focus areas of the division for white-collar crime.

The memo included a list of “high-impact areas” that the division will prioritize investigating and prosecuting. Trade and customs fraud, including tariff evasion, was second on the list.

The DOJ also revised its Corporate Whistleblower Awards Pilot Program and added “trade, tariff, and customs fraud by corporations” to the priority list.

Galeotti noted that unchecked fraud in U.S. markets robs hardworking Americans, harms the public, and that efficient enforcement promotes American economic and national security interests.

This memo signals a significant shift in the priorities of the DOJ’s criminal division. Historically, trade violations were not a top criminal priority and were instead handled by CBP and the DOJ’s Civil Division. Relatively few trade law violation cases have risen to the level of criminal prosecution.

What Importers Should Do

Now more than ever it is critical for importers to examine their import compliance programs and ensure that adequate procedures are in place to correctly enter goods into the United States.

Invest in Compliance

CBP expects importers to use “reasonable care” in reporting HTS, value, country of origin, free trade agreement preference, etc. This is a subjective standard; however, CBP […]

By |2025-06-13T13:24:14-04:00June 13, 2025|U.S. Department of Justice (DOJ)|0 Comments
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Outdated Trade Regulations – CBP Open to Feedback

Whether you’re a seasoned importer or just entering the trade world, keeping up with thousands of pages of regulations can be a challenge. 

A stated priority of the current administration is deregulation. On January 31, 2025, President Trump signed an Executive Order titled “Unleashing Prosperity Through Deregulation.” The Order requires that whenever an agency promulgates a new rule, regulation, or guidance, it must identify at least 10 existing rules, regulations, or guidance documents to be repealed.

At last month’s Trade and Cargo Security Summit, CBP said they and their partner agencies are seeking feedback on what regulations are obsolete or simply don’t reflect the reality of the current trade environment.

Here’s a sampling of some potential obscure and obsolete regulations that CBP may consider revisiting (what are your additions to this list?):

Allowing Non-Resident Importers to Act as an Importer of Record in the U.S.

Although there are many entities that legitimately use the exception found in 19 CFR 141.18, which permits non-resident corporations to make entry of goods into the U.S. (as an importer of record), companies can also do so with malicious intent. The non-resident entity solely needs a U.S. agent for service of process and a customs bond. This particular exception is one that a bad actor can use surreptitiously. For example, a non-resident importer can create a shell […]

By |2025-06-13T10:52:50-04:00June 13, 2025|U.S. Customs and Border Protection (CBP)|0 Comments
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