Author: Bruce Leeds

Continuing the Proposal for Customs Broker Continuing Education

By: Bruce Leeds, Senior of Counsel

On Oct. 28, 2020, U.S. Customs and Border Protection (CBP) published an Advance Notice of Proposed Rulemaking on continuing education for individually licensed customs brokers. After receiving comments and feedback from the trade, CBP published a Notice of Proposed Rulemaking (NPRM) on this proposal on Sept. 10, 2021.

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itar export exemptions

The ITAR Australia and UK Exemptions – Better Read the Regulations Carefully

By: Bruce Leeds, Senior Counsel to Braumiller Law Group and George Alfonso, Of Counsel to Braumiller Law Group and President of Reigncore Lobbying

On behalf of our example, we’d like to introduce you to “Joe Compliance.” Imagine Joe Compliance is going through the International Traffic in Arms Regulations (ITAR) and notices license exemptions for Australia and the UK in Part 126.16 126.17.

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Navigating the Export Controls on Semiconductors

By Bruce Leeds, Senior Counsel, Braumiller Law Group Determining what export controls apply to semiconductor devices can be a challenging task.  Most controls on semiconductor devices are found in Export Commodity Classification Number (ECCN) 3A001 of the Commerce Control List (CCL) in the Export Administration Regulations (EAR).  That ECCN has nearly 16 pages of detailed

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trade in 2021

What’s Happening with Trade in 2021

By Bruce Leeds, Senior Counsel, Braumiller Law Group

A new year, a new administration, and new trade initiatives. Well…at least 2 out of 3. Let’s take a look at some import and Customs subjects, then turn to export controls.

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export controls colleges universities

Export Controls on Campus A Learning Experience

By: Bruce H. Leeds Senior Counsel, Braumiller Law Group

Colleges and universities – Ivy covered buildings with students and faculty engaged in academic pursuits. Colleges and universities – Hotbeds of export control concerns. What?? The halls of academia have increasingly become involved with export control issues. There are several ways that universities are potentially affected …

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What is the Country of Origin?

By: Bruce H. Leeds, Senior Counsel, Braumiller Law Group Determining the country of origin of imported articles has become increasingly important in recent years.  There has long been a requirement that imported articles be marked with the name of the country of origin.  Country of origin also determines eligibility for special duties or free trade

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Are You Gonna Sign That Thing? Getting Certified Under USMCA

By: Bruce Leeds, Senior Counsel, Braumiller Law Group The US-Mexico-Canada Agreement (USMCA) replaces NAFTA and goes into effect on July 1 of this year. One of the major changes to come out of this trade agreement is elimination of the NAFTA Certificate of Origin.  Instead, the USMCA replaces the Certificate of Origin with a certification. 

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Exporting Under the USMCA. No Problem – Right?

By: Bruce Leeds, Of Counsel, Braumiller Law Group The United States-Mexico-Canada Agreement (USMCA) will replace NAFTA and likely go into effect by Jan. 1, 2021. Your company exports to Canada and Mexico.  So: So long as you can produce a Certificate of Origin everything is taken care of NAFTA and USMCA are import things, so

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Japan-US Free Trade Agreement – Not All it Appears to Be

By: Bruce Leeds, Senior Counsel, Braumiller Law Group On Jan. 1, 2020 the Japan-United States Free Trade Agreement went into effect.  The agreement provides duty-free, or reduced duty treatment, for certain Japanese imports into the U.S. and certain U.S. exports to Japan.  The implementation details were printed in the Federal Register on Dec. 30, 2019

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Sacre Bleu! Section 301 Duties on Nice French Stuff?

By: Bruce Leeds, Senior Counsel, Braumiller Law Group Section 301 duties on French merchandise?  How can that be?   Doesn’t Section 301 only apply to China? The answers are yes and no.  The US Trade Representative announced that the US was planning to impose up to 100% additional duties on a variety of French origin products

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FedEx vs. Department of Commerce: Compliance Comes in Small Packages

By: Bruce Leeds, Senior Counsel, Braumiller Law Group On June 24th of this year, FedEx filed a suit against the Department of Commerce “seeking to enjoin the US Department of Commerce from enforcing prohibitions contained in the Export Administration Regulations.” In its filing FedEx stated that it “believes that the EAR violates common carrier rights

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Which Way with Huawei?

By: Bruce Leeds, Senior Counsel, Braumiller Law Group The Bureau of Industry & Security (BIS) of the Department of Commerce announced that it was adding Huawei Technologies Co., Ltd. to the Entity List on May 16, 2019.  Not just this Huawei company in China, but also 68 non-US affiliates of Huawei located in 26 countries. 

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Special 301 Duties on Aircraft – Are They Just Winging It?

By: Bruce Leeds, Senior Counsel, Braumiller Law Group In a Federal Register Notice dated April 12, 2019, the Office of the US Trade Representative (USTR) announced the initiation of an investigation into European Union (EU) subsidies of large aircraft.  The notice also contained a list of European origin aircraft and other products targeted for potential

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Export Control Changes and Updates in 2018

By: Bruce Leeds, Senior Counsel, Braumiller Law Group, PLLC 2018 saw a number of administrative and legislative changes to U.S. export controls.  Many of them have not been implemented, and others have gone into place.  Let’s take a look: Export Control Reform Act (ECRA) of 2018 This legislation had bipartisan sponsorship, was passed by both

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U.S. Customs & Border Protection Enforcement of Trademarks

By Bruce Leeds, Senior Counsel, Braumiller Law Group If you go to the Trade tab at one of the featured items on the menu is Priority Trade Issues.  There you will find information on Intellectual Property Rights (IPR).  This primarily deals with CBP enforcement of trademarks and copyrights. U.S. copyright and trademark holders lose

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Deductive Reasoning – Deducting Expenses or Asking for Trouble?

By Bruce Leeds, Senior Counsel, Braumiller Law Group Acme Corporation receives a shipment by ocean freight from Japan. The terms of shipment on the purchase order are CIF Long Beach, California, meaning the price includes the cost of the goods plus prepaid ocean freight and insurance from Japan to Long Beach. The commercial invoice accompanying

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