On August 12, CBP confirmed that the recent revocation of Hong Kong’s “special status” and updated China marking requirements would not render goods of Hong Kong origin subject to the additional Section 301 tariffs imposed on most goods of Chinese origin. CBP stated that “the change in marking requirements does not affect country of origin
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US Revokes Hong Kong’s “Special Status” – UPDATED 8/24
UPDATE: CBP has extended the compliance period for origin marking for an additional 45 days. In an effort to allow importers ample time to comply with EO requirements for goods produced in Hong Kong to be appropriately marked with the origin of “China”, CBP is extending the transition period through November 9, 2020. Accoringly, effective…
Canadian Aluminum to Again Face 10% Tariff
On August 6 the Trump Administration announced that it would reimpose the 10% aluminum tariff on imports of Canadian “non-alloy unwrought aluminum” classified under HTS subheading 7601.10. The move has not garnered widespread support from industry or the US Chamber of Commerce, who called it “a step in the wrong direction.” The Administration’s proclamation claims…
USMCA Certificates of Origin – What you need to know.
The fact that the US-Mexico-Canada Agreement (“USMCA”), which replaced NAFTA on July 1, does not require any particular form Certificate of Origin (“COO”) has left many importers and exporters confused on the proper manner of certifying goods as “originating” under USMCA. The new trade agreement dispensed with the formality of the Form 434 COO under…
Treasury’s Final FIRRMA Regulations: New Foreign Investment Restrictions in Tech, Infrastructure and Data
Starting Feb. 13, 2020, U.S. companies in tech, infrastructure and data seeking minority or controlling foreign investment will require approval from the Committee on Foreign Investment in the United States (CFIUS) before closing certain transactions.
The change stems from the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA), which was signed into law by…
Apple’s Lesson: Screening Software Alone Won’t Prevent Export Violations
Apple Inc.’s recent settlement with the Treasury Department’s Office of Foreign Assets Control (OFAC) has exposed a potentially costly wrinkle in complying with international trade regulations. While sanctions screening technologies may help a company catch and report errors, this software alone will not absolve faults and shortcomings in a company’s overall export compliance programs.
The compliance…
Certain Transactions with the Government of Venezuela are Authorized
On November 5, 2019 the Office of Foreign Assets Control (OFAC) issued two General Licenses (GLs) authorizing specific transactions involving the Government of Venezuela and categories of persons blocked by Executive Order 13884 (E.O. 13884).
E.O. 13884 was signed by President Donald Trump earlier this year on August 5, 2019. E.O 13884 was intended to…
USMCA…maybe next year?
Now that Canadian PM Justin Trudeau has dissolved Parliament and called for a general election (to be held October 21), chances of seeing the USMCA ratified by all three member states this year has become an increasingly remote possibility. However, the good news for USMCA supporters is that NAFTA’s replacement continues to enjoy support in…
New Foreign Investment Restrictions on the Horizon in Tech, Infrastructure and Data
U.S. companies in tech, infrastructure and data seeking foreign investment will require approval from the Committee on Foreign Investment in the United States (CFIUS) before closing certain transactions. Last year, President Trump signed into law the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA), which outlined the expansion of CFIUS jurisdiction to review certain…
US/China Trade War Escalates
On Friday, August 23, the Trump Administration announced an increase in Section 301 tariffs following China’s announcement of retaliatory tariffs targeting $75 billion of US goods. The announcement, which came by way of tweet, provided that Section 301 tariffs on all List 1 through 3 goods would be elevated from 25% to 30% effective October…