Author: Paul Fudacz

A Beginners Guide to Exporting – Resources for Growth

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 form of commerce.  One may note that there are tariffs on imports, but no tariffs on exports – our government doesn’t want to hinder a good thing. As a trade

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Section 232 Exclusions

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

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.

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steel import monitoring and analysis

Recent Changes to Steel Import Monitoring and Analysis System

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 …

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

By: Paul Fudacz, Partner, Braumiller Law Group On March 24, 2020, U.S. Customs and Border Protection published Cargo Systems Messaging Service # 42133823 “Entry Summary Guidance for Pipe Spools from Multiple Countries of Origin” (the Message).  The Message provided: Pipe spools are prefabricated components of a piping system consisting of various types of pipes, flanges,

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Section 301 Considerations When Importing from a NAFTA Country

By: Paul Fudacz, Senior Associate Attorney With the advent of the Section 301 tariffs, an issue that has been raised frequently is how to accurately determine the country of origin for Section 301 tariff purposes for goods imported from a NAFTA country.  The NAFTA sets forth rules for determining the “country of origin” of products

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

By: Paul Fudacz, Senior Associate Attorney, Braumiller Law Group, PLLC Many importers are aware that the United States, Canada, and Mexico have negotiated a replacement treaty for the North American Free Trade Agreement (NAFTA).  The new agreement is called the United States-Mexico-Canada Agreement (USMCA) and was announced by President Trump on October 1, 2018.  

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Trade Law President Trump

President Announces Updated Steps to Address China’s Trade Practices to Protect U.S. Technology and Intellectual Property

By Paul Fudacz, Senior Attorney BLG On May 29, 2018 President Trump updated the steps his administration initially announced in March related to trade actions designed to protect domestic technology and intellectual property from certain discriminatory and burdensome trade practices by China.  The Chinese trade practices targeted relate to technology transfer, intellectual property, and innovation. 

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NAFTA

Update on NAFTA Negotiations —April 2, 2018

By Paul Fudacz, Senior Attorney As negotiators from Canada, Mexico and the United States prepare for the eighth round of NAFTA discussions, there is increasing pressure to reach a deal on a revised framework due to several impending deadlines, prompting U.S. Trade Representative Robert Lighthizer to press the NAFTA partners to conclude negotiations on a

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NAFTA Country of Origin Marking Rules – an Overview

  By Paul Fudacz, Senior Attorney, Braumiller Law Group Most trade professionals are quite familiar with the long-standing country of origin marking rules applicable to foreign produced goods imported and sold into the U.S., but many are not quite so familiar with the country of origin rules applicable to goods traded between the three NAFTA

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International Trade Commission Initiates Safeguard Investigation on Solar Panels

On June 1, 2017, the United States International Commission (Commission) initiated a safeguard investigation under section 201 / 202 of the Trade Act of 1974 (‘‘the Act’’) to determine whether crystalline silicon photovoltaic (‘‘CSPV’’) cells (whether or not partially or fully assembled into other products) are being imported into the United States in such increased

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Overview of President Trump’s Section 232 Investigation of Foreign Steel

In April, the Trump administration initiated an investigation under Section 232 of the Trade Expansion Act of 1962. Section 262 is titled “Safeguarding national security”, and the Act requires the Department of Commerce (Commerce), in coordination with the Department of Defense (DOD), to conduct an investigation to determine the “effects on national security of imports

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Obtaining a Formal Ruling from CBP – Understanding the Basics

Most trade compliance professionals are aware of CBP’s ruling program, but many are not sure when it is appropriate to seek a customs ruling, exactly how to go about obtaining a customs ruling, and what types of issues are covered under the ruling program. A general principle under customs laws and regulations is that an

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Update on CBP’s Trusted Trader Program

By: Paul Fudacz, Senior Attorney In June 2014, the Bureau of Customs and Border Protection (CBP) announced the Trusted Trader Pilot Program, described as a holistic cargo and conveyance security and compliance program designed to unify the supply chain security aspects of the Customs-Trade Partnership against Terrorism (C-TPAT) program, and the internal controls of the

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Update on Use and Compliance with the “Made in USA” Standard

By: Paul Fudacz, Senior Attorney Both the Federal Trade Commission (FTC) and the U.S. Customs and Border Protection (CBP) have regulatory authority related to the use of country-of-origin claims. While CBP regulates marking requirements related to foreign-origin markings on imported products (e.g., “Made in China”), the FTC regulates claims of U.S. origin such as “Made

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