Paul Fudacz, Author at Braumiller Law Group

Section 232 Steel & Aluminum Derivative Products Inclusion Process Expands Scope of the National Security Purpose of Section 232 Investigations

November 30, 2025

By Paul Fudacz, Partner, Braumiller Law Group and Olivia Van Pelt, Law Clerk at Braumiller Law Group

On February 10, 2025, the President issued Presidential Proclamations Under Section 232 of the U.S. Code adjusting imports of steel and aluminum into the United States. These Proclamations provided an expanded listing of steel and aluminum derivative articles but also instructed the Secretary of Commerce (Secretary) to establish a process for including additional derivative aluminum and steel articles within the scope of the ad valorem duties.

The Art of the (UK) Deal

June 9, 2025

By Paul Fudacz, Partner, Braumiller Law Group and Olivia Van Pelt, Law Clerk at Braumiller Law Group

On May 8, 2025, the United States and United Kingdom (UK) unveiled the new trade terms of an “economic prosperity” deal. This deal comes after President Trump imposed a 10% reciprocal tariff on all products from the UK and additional tariffs on steel and aluminum, and automobiles and automobile parts. While the 10% reciprocal tariff will remain in effect, the two countries were able to agree on alternative arrangements for steel and aluminum, automobiles, and other strategic sectors.

Aluminum Extrusions from 13 Countries – Commerce Makes Affirmative Final AD and CVD Determinations

October 7, 2024

By Paul Fudacz, Partner, Braumiller Law Group
On September 27, 2024, Commerce announced its affirmative final determination in the ongoing AD / CVD aluminum extrusions investigation. On the same day Commerce also posted its Final Scope Issues and Decision Memorandum. In both, Commerce almost uniformly deferred to Petitioners in dismissing numerous comments of interested parties primarily challenging the scope of the investigation on a wide range of legal theories and practical considerations.

New Presidential Proclamations – Section 232 Duties on Certain Steel and Aluminum Products from Mexico

August 9, 2024

By Paul Fudacz, Partner, Braumiller Law Group and Senior Associate Attorney Megan Mohler

On July 10, 2024, the President issued two Presidential Proclamations related to the imposition of Section 232 duties on certain steel and aluminum products from Mexico. The first establishes a “melt and pour” requirement for imports of steel articles that are products of Mexico and will increase the section 232 duty rate for imports of steel articles and derivative steel articles that are products of Mexico that are melted and poured in a country other than Mexico, Canada, or the United States.

Aluminum Extrusions II – Scope Modifications Proposed, Dept. of Commerce Questioning Manageability

April 1, 2024

By Paul Fudacz, Partner, Braumiller Law Group

Since the last update on the AD / CVD aluminum extrusions investigation (dubbed Extrusions II) in what appears to be a response to strong opposition from trade industry groups, legislators, governments, and other interested parties, as well as dubious signals from the Department of Commerce, (Commerce) the Petitioners in the ongoing Aluminum Extrusions investigation have proposed modifications to the scope of the investigation.

New Antidumping and Countervailing Duty Investigation Initiated Covering Aluminum Extrusions from 15 Countries

November 8, 2023

By Paul Fudacz, Partner, Braumiller Law Group

On October 4, 2023, A coalition of 14 U.S. aluminum extrusion producers and labor unions filed petitions before the Department of Commerce, International Trade Administration (Commerce) and the International Trade Commission (ITC) seeking to impose antidumping (AD) and countervailing duties (CVD) on aluminum extrusions produced in 15 countries and exported to the U.S.

Update: Quartz Surface Products from China – New Certification Requirements for Shipments from Malaysia

December 8, 2022

By Paul Fudacz, Partner, Braumiller Law Group

On October 21, 2022, the Department of Commerce, International Trade Administration (The DOC) published its Final Scope Ruling on Malaysian Processed Quartz Slab. The DOC determined that imports of quartz slab manufactured in the People’s Republic of China (China) and processed in Malaysia are covered by the scope of the antidumping duty (AD) and countervailing duty (CVD).

Antidumping Duties – Can I Obtain a Separate Lower Rate?

October 2, 2022

By: Paul Fudacz, Partner, Braumiller Law Group
In Antidumping (AD) investigations, the U.S. Department of Commerce (DOC) typically selects only a limited number of exporting entities for review, with these exporters referred to as “individual” or “named” respondents. Selection of these respondents is based on U.S. Customs and Border Protection Data, and in most cases due to limited DOC resources, will consist of only a few of the largest exporters. If the selected respondents cooperate fully with the government investigation, and can demonstrate fair export pricing, they can obtain an individual AD rate that is generally favorable, or possibly de minimis, resulting in a zero rate.

Is Your Company in Compliance with US Immigration Form I-129 EAR / ITAR Certification Requirements?

August 9, 2022

By: Paul Fudacz, Partner, Braumiller Law Group

Most companies that employ non-U.S. persons in the United States are familiar with visa requirements, including completing U.S. Citizenship and Immigration Services Form I-129 – Petition for a Nonimmigrant Worker. However, many are less familiar with the affirmative due diligence and certification requirements contained in Part 6 of the I-129.

Cautions When Marking and Labeling Goods for Export from the United States

April 10, 2022

By: Paul Fudacz, Partner, Braumiller Law Group

Many importers are familiar with marking and labeling requirements for products imported into, and sold in the U.S. These include mandatory requirements such as U.S. Customs country of origin marking and labeling requirements, Federal Communications Commission labeling for certain electronic equipment, specific labeling for certain consumer products under the Federal Trade Commission and Consumer products Safety Commission, as well as a host of other mandatory marking and labeling requirements of other regulatory agencies for specified products.

I Just Found Out My Imported Goods are Subject to Antidumping – What Should I do?

February 6, 2022

By: Paul Fudacz, Partner, Braumiller Law Group

Currently there are close to 400 active antidumping cases involving nearly 40 countries. The cases cover a wide range of products including steel commodity products and steel articles (number one category), chemical products, other metal commodities and articles, plastics and rubber products, food products, paperboard and manufactured articles. Key countries subject to ADD are China (number one country by far), Korea, Indonesia, Taiwan, Thailand, Turkey, and Vietnam.

Federal Trade Commission Puts Teeth into False ‘Made in USA’ Claims Enforcement

December 6, 2021

By: Paul Fudacz, Partner, Braumiller Law Group

The U.S Federal Trade Commission (FTC) recently codified product labelling rules related to unqualified “Made in USA” (MUSA) claims under 16 CFR Part 323

A Beginners Guide to Exporting – Resources for Growth

June 7, 2021

By: Paul Fudacz, Partner, Braumiller Law Group It is well known going back to the founding of our country that exporting is the most beneficial

Department of Commerce Announces General Approved Exclusions (GAEs) for Steel Articles Under the 232 Exclusions Process

February 1, 2021

By Paul Fudacz, Partner, Braumiller Law Group

The Grinch came early in 2020 with the introduction by the U.S. Department of Commerce of new steel licensing requirements that instruct importers to indicate the “country of melt and pour” on standard steel licenses imported after October 13, 2020, and also the introduction on December 14 of new certification requirements related to the Section 232 exclusion process.

Recent Changes to Steel Import Monitoring and Analysis System

October 8, 2020

By: Paul Fudacz, Partner, Braumiller Law Group

On September 11, 2020, the U.S. Department of Commerce International Trade Administration published a final rule modifying its regulations pertaining to the Steel Import Monitoring and Analysis (SIMA) System. These changes include requiring steel import license applicants to identify the country where the steel used in the manufacture …

Paul Fudacz

Paul Fudacz

Section 232 Steel & Aluminum Derivative Products Inclusion Process Expands Scope of the National Security Purpose of Section 232 Investigations

The Art of the (UK) Deal

Aluminum Extrusions from 13 Countries – Commerce Makes Affirmative Final AD and CVD Determinations

New Presidential Proclamations – Section 232 Duties on Certain Steel and Aluminum Products from Mexico

Aluminum Extrusions II – Scope Modifications Proposed, Dept. of Commerce Questioning Manageability

New Antidumping and Countervailing Duty Investigation Initiated Covering Aluminum Extrusions from 15 Countries

Update: Quartz Surface Products from China – New Certification Requirements for Shipments from Malaysia

Antidumping Duties – Can I Obtain a Separate Lower Rate?

Is Your Company in Compliance with US Immigration Form I-129 EAR / ITAR Certification Requirements?

Cautions When Marking and Labeling Goods for Export from the United States

I Just Found Out My Imported Goods are Subject to Antidumping – What Should I do?

Federal Trade Commission Puts Teeth into False ‘Made in USA’ Claims Enforcement

A Beginners Guide to Exporting – Resources for Growth

Recent Changes to Steel Import Monitoring and Analysis System

Recent CBP Entry Summary Guidance for Pipe Spools from Multiple Countries of Origin – Shapes of Things to Come?

Department of Homeland Security Announces Actions to Combat E-Commerce Counterfeiting

Section 301 Considerations When Importing from a NAFTA Country

New NAFTA? – What NAFTA Practitioners Can Expect Under the United States-Mexico-Canada Agreement (USMCA)

Are My Goods of Chinese Origin? Update on Country of Origin Rules in view of the Section 301 Tariffs

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