Author: Jennifer Horvath

HTS 9801.00.10

Updated Requirements to HTS 9801.00.10 – U.S. and Foreign Goods Returned

By: Jennifer Horvath, Partner

U.S. CBP recently released updated requirements for importers and brokers regarding HTS subheading 9801.00.10, U.S. and Foreign Goods Returned. Often called a “9801 Claim,” importers can generally use this special duty-free tariff provision when merchandise is exported from and returned to the United States, so long as it is not advanced in value/condition, regardless of country of origin.

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marking rules

USMCA Proposed Rule Change – Expanding Part 102 Marking Rules

By Jennifer Horvath, Partner, Braumiller Law Group

U.S. Customs and Border Protection (“CBP” or “Customs”) recently released a proposed rule (FR 86 35422) which would expand the usage of the U.S. – Canada – Mexico Agreement marking rules found in 19 C.F.R. Part 102 (herein after “Part 102”).

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Digital service tax investigation

Section 301 Digital Service Tax Investigation

By Jennifer Horvath, Partner, Braumiller Law Group

The primary focus of companies over the past few years has been on the Section 301 China tariffs. However, businesses should be aware of the ongoing Section 301 investigation into digital service taxes (DST) by certain countries.

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China Vietnam USTR Investigation

China… Vietnam…What’s Next?

By Jennifer Horvath, Partner, BLG 

Many people are aware of the Section 301 investigation into the unfair trade practices of the People’s Republic of China (PRC). However, a similar investigation has recently been initiated by the United States Trade Representative (USTR) into actions by Vietnam.

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NAFTA to USMCA – What Changed for the Automotive Sector?

By: Jennifer Horvath, Partner, Braumiller Law Group The USMCA recently went into effect on July 1, 2020, which ended the twenty-six years reign of NAFTA. A major focus of the new agreement was to update the regulations relating to the automotive sector. While a majority of the agreement is similar to NAFTA, it is critical

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CBP’s Forced Labor Initiative: Will this Affect your Supply Chain?

By: Jennifer Horvath, Partner, Braumiller Law Group The U.S. government, including Customs and Border Protection (CBP), has recently put an emphasis on preventing forced labor in global supply chains. For instance, On March 11, 2020, the House Rules Committee introduced a new bill that would create a rebuttable presumption regarding forced labor in Xinjiang, China.

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Updated VSD Policies: How Could this Affect you?

By: Jennifer Horvath, Partner, Braumiller Law Group While the United States Trade Representative is currently inundated with Section 301 exclusion requests, the Department of Justice’s (DOJ) National Security Division’s (NSD) recent update could be encouraging an influx of voluntary self-disclosures (VSDs) to the U.S. export agencies and the DOJ in the near future. NSD has

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Understanding the Ins and Outs of Wood Packing Materials

By: Jennifer Horvath, Partner, Braumiller Law Group Either your company, or someone you have spoken with lately, has likely been the recipient of a wood packing notice violation. This is because, especially in the last two years, Customs and Border Protection (CBP) has started strictly enforcing the requirements and regulations related to wood packing material

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Who Knew that Gorgeous Mirror Needs an FWS Declaration?

By: Jennifer Horvath, Senior Associate, Braumiller Law Group Understanding the specific regulations  overseen by the Fish and Wildlife Service (FWS) can often times be challenging. Businesses should be aware of how the FWS enforces the regulations, environmental wildlife protection laws, and international wildlife treaties of other agencies. For instance, violations of FWS regulations can trigger

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Chinese Retaliatory Tariffs and List 4

By: Jennifer Horvath, Senior Associate, Braumiller Law Group In light of President Trump’s decision to increase tariffs on the $200 billion list of Chinese imports, China has decided to raise tariffs on $60 billion worth of U.S. goods. These retaliatory tariffs affect approximately 5,000 products and the total duty ranges from 20-25% depending on the

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Imposition of Russian Sanctions

By: Jennifer Horvath, Senior Associate One of the more interesting developments in the trade world is the recent addition of Russian businesses and individuals to the Specially Designated Nationals List (SDN List) by the U.S., Canada, and EU. On March 15th, the U.S. Treasury Department announced that the Office of Foreign Asset Controls (OFAC) added

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China Section 301 Tariffs & Mitigation Strategies

By Jennifer Horvath, BLG Attorney Section 301, China tariffs, Lists…. There is a lot to learn about the new Section 301 tariffs being applied to imports from China. Below is a brief overview of the China tariff schedules, and key ways to mitigate the potential amount owed due to these extra duties. What is Section

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Global Trade Compliance

Section 301 Initial Tariff List Becomes Effective

By Jennifer Horvath, Senior Associate Attorney, BLG Today, June 15th, 2018, the Office of the United States Trade Representative (USTR) released the list of products which will become subject to the additional Section 301 tariff.  The tariffs were announced to become effective beginning July 6, 2018.  The government is imposing an additional 25% ad valorem

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The CAATSA

By Jennifer Horvath, Senior Associate Attorney, Braumiller Law Group On August 2, 2017, President Trump signed H.R. 3364, the Countering America’s Adversaries Through Sanctions Act (“CAATSA”) into law.  The CAATSA imposes additional sanctions on Russia, Iran and North Korea.  In creating enhanced sanctions under the CAATSA, Congress also issued additional implementation requirements and corresponding deadlines

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ACE Reconciliation to Launch in February 2018

By Jennifer Horvath, Attorney, Braumiller Law Group  On June 27, 2017, CBP postponed the implementation of the reconciliation processing capability within the Automated Commercial Environment (ACE).  The release date was originally targeted for July 8, 2017, but is now scheduled to deploy on February 24, 2018.  According to the CBP, the delay is related to continuing efforts

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The “Next Big Thing”: Update on Key Antidumping/Countervailing Duty Case for Cold Drawn Mechanical Tubing

By Jennifer Horvath, Attorney, Braumiller Law Group   On April 19, 2017, ArcelorMittal Tubular Products, Michigan Seamless Tube, PTC Alliance Corp., Webco Industries and Zekelman Industries filed petitions with the United States International Trade Commission (USITC) and the Department of Commerce (DOC).  The imposition of antidumping/countervailing duties (ADD/CVD) on imports of such tubing could have

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Ramping Up Enforcement on Anti-dumping & Countervailing Duties

In the area of international trade law, anti-dumping duties (ADD) and countervailing duties (CVD) have increasingly become a hot-button issue for the government. Collection and enforcement of ADD/CVD owed by importers is one of the core priority issues of the U.S. Customs and Border Protection (Customs or CBP). Just last year, the government enacted an

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Time Limit for Temporary Export License Increased

The Bureau of Industry and Security (BIS) of the Department of Commerce has implemented a rule aligning a temporary export license exception with the rules of the IMMEX program in Mexico. The rule was effective January 3, 2017. U.S. exporters are eligible to use the license exception Temporary Imports, Exports, Re-exports and Transfers (TMP) for

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BIS Amends Licensing Requirements for Certain CNC Machines and Valves, Pumps

By: Jennifer Horvath, Senior Associate Attorney Effective November 25, 2016, the Bureau of Industry and Security (BIS) of the Department of Commerce implemented a rule to decrease the level of licensing required for certain turning machines or combination turning/milling machines, valves and pump, among other named items. The changes in licensing requirements aim to be

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