Author: Paul Fudacz

Antidumping Duties

Antidumping Duties – Can I Obtain a Separate Lower Rate?

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.

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

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.

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marking and labeling goods

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

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.

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Imported Goods Subject to Antidumping

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

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.

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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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