TRADE ANALYSIS
ST&R has over 30 years of experience
supplying textile and apparel importers, retailers, and manufacturers with all the
trade and economic intelligence necessary to maximize opportunities, mitigate risks,
and make educated decisions associated with importing. ST&R professionals quantify
and analyze the risk of supply chain interruptions, allowing sourcing professionals
to properly investigate and vet a supplier, calculate and quantify opportunities,
then analyze and monitor the risks associated with sourcing abroad, resulting in
maximized import operations efficiencies. A broad range of complementary services
is also available through our ST&R-TAP™ service, including economic outlook and
conditions assessments, import and export statistics analysis, U.S. and foreign
market competitive analysis, and legal, administrative, and regulatory action monitoring.
ST&R-TAP also maintains a Vietnam monitoring tool that provides an analysis of the
potential for antidumping actions by the U.S. government on a product-by-product
basis and a Trade Library that contains hundreds of reports covering all topics
related to textile and apparel trade management.
IMPORT COMPLIANCE
Customs laws have a dramatic
impact on the business operations of the trade community. We assist companies in
self-assessing their compliance with Customs and other government agency requirements,
as well as represent them before U.S. Customs in Compliance Assessments, NAFTA Verifications,
and other, more focused import reviews. In addition, we work with companies to develop
internal procedures, manuals and recordkeeping guidelines to ensure conformity with
applicable laws and regulations.
TARIFF CLASSIFICATION
Rates of Duty for all imported
products and admissibility for many are established by how they are classified for
U.S. Customs purposes. We work closely with our clients to "tariff engineer"
their products so they are classified in the provisions most favorable to their
ongoing operations.
PREFERENCE PROGRAMS
Claims of duty-free or duty-reduced
entry represent a growing percentage of the merchandise imported into the United
States. Whether the claim involves the North American Free Trade Agreement, the
Generalized System of Preferences, the Caribbean Basin Initiative, or one of the
Chapter 98 provisions (including the 9802.00.80 provision) of the Tariff Schedule,
we have extensive experience in the evaluation of companies’ eligibility to use
these trade preferences, and in the assessment of their on-going compliance and
adherence to all legal and regulatory requirements.
EXPORT LICENSING AND CONTROL
Although restraints on exports have been relaxed, a wide range of products must
still be approved by the U.S. Government before they are permitted to be exported
from the United States. We assist companies in determining the level of control
applicable to their merchandise, and in assessing the need to obtain advance licensing
and/or include protective statements and controls on the movement of their goods
worldwide.
FOREIGN CORRUPT PRACTICES AND ANTI-BOYCOTTS
U.S. law places extreme restrictions on the ability of companies to provide monetary
contributions or compensation to foreign governments or to participate in boycotts
of other countries' products and/or services. We review companies' current operations,
and evaluate their interaction with suppliers, vendors, customers, and such governments,
to ensure that no violations of these laws are occurring.
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CUSTOMS VALUATION
The valuation placed on merchandise at its
time of importation represents one of the more critical issues when importing merchandise
into the United States. We evaluate companies’ relationships with suppliers, vendors
and agents so that the most beneficial dutiable value permissible under the law
is declared to Customs at the time of entry.
TRADE RELIEF
Relief under the Dumping or Countervailing
Duty Laws, or reliance on Sections 201, 301 or 337 of the Tariff Act, represent
the primary vehicles available to companies that believe their ability to distribute
their products is being hampered by unfair price competition or market distorting
practices. Whether a petitioner or a respondent, we represent companies in trade
disputes in an effort to ensure a level trading field for the distribution of goods
and services.
COUNTRY OF ORIGIN AND MARKING DETERMINATIONS
Country of origin determinations,
marking, and the applicability of quotas are three of the most significant admissibility
issues which importers must address before they import their merchandise into the
United States. We evaluate companies’ products, production processes and sourcing
patterns to ensure that all origins, markings, and quota applications are properly
determined so that appropriate planning decisions can be made and imported merchandise
is not unduly detained.
OTHER GOVERNMENT AGENCY REQUIREMENTS
Besides the Customs laws, imported
merchandise must satisfy the requirements of a host of other Federal Agencies. From
the Food & Drug Administration to the Consumer Products Safety Commission to
the Federal Trade Commission, we assist companies in maintaining compliance with
all regulatory requirements applicable to their goods.
ADMINISTRATIVE PROCEEDINGS
Often, a determination as to the rules governing
a company’s imports/exports hinges on an interpretation of federal law and/or regulation.
In those instances, through the submission of ruling requests, requests for internal
advice, protests, or responses to Requests for Information or other communication,
we advocate our clients’ positions before the affected federal agency. We also represent
the interests of our clients in any penalty or other administrative action which
may have been initiated by the Government.
COMPLIANCE REVIEWS, MANUALS, AND PROCEDURES
The best practices are demonstrated by those companies that have developed specific
procedures, manuals and on-going compliance programs for evaluating and monitoring
their import/export operations. We work with companies to create documented policies
and procedures and written guidelines concerning their import/export practices.
We also conduct internal reviews of companies' current procedures to ensure that
they are in compliance with all legal requirements.
DUTY DRAWBACK
Although often underutilized programs, duty drawback is one of the primary money-saving
techniques available to companies involved in two-way trade with the United States.
We have a sophisticated staff of attorneys and other trade professionals who are
dedicated to the provision of drawback-related services, whether conducted in conjunction
with company personnel or on an outsourced basis.
FOREIGN-TRADE ZONES, BONDED WAREHOUSES
AND TEMPORARY IMPORTATIONS
As an alternative to the refund of duties previously paid, many companies have discovered
the duty savings to be realized by either admitting their merchandise directly into
foreign-trade zones or entering merchandise into bonded warehouses, or by utilizing
temporary import procedures. Our practice in this area is extensive, from assessing
the feasibility of utilizing one of these duty deferral mechanisms to assisting
in the implementation, review and monitoring of on-going compliance with the exacting
requirements of these programs.
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