Print PDF

Quick Navigation

Actions Businesses Can Take in the U.S.

Impacts on U.S. Trade Agency Operations

Worldwide Import Flexibilities and Export Restrictions

Macro Impacts on Trade

Contact

Nicole Bivens Collinson
President, International Trade & Government Relations
nbc@strtrade.com
202.730.4956

ST&R Trade Report

Subscribe to receive news & updates on COVID-19 trade actions directly in your inbox

Other COVID-19 Sites

GovPredict Coronavirus Resource Center
City/County responses to COVID-19

State Department COVID-19 Page
Country-specific travel advisories, entry/exit requirements & quarantine information

United Nations UNCTAD Train for Trade Network
COVID-19 related changes to ports worldwide

University of St. Gallen's Global Trade Alert
Information on state interventions likely to affect foreign commerce

United Nations Conference on Trade and Development
Effects of the pandemic on manufacturing, trade, foreign direct investment and economic growth. 

U.S. Chamber of Commerce's Global Dashboard on COVID-19 Government Policies 
Info on worldwide regulatory changes due to COVID-19.

Retail Industry Leaders Association COVID-19 Resources
Resources & info for retailers.

COVID-19: Trade Impacts Resource Page

Updated May 19, 2020

Subscribe to receive news & updates on COVID-19 trade actions directly in your inbox

This page features information on the effects the COVID-19 pandemic is having on international trade. It includes updates to trade operations and import / export restrictions worldwide, as well as broader information on how the pandemic may affect trade generally.

It also includes actions that a company can take at this time. If you'd like to discuss what is relevant and actionable for your company with an ST&R professional, please contact us.


Actions Businesses Can Take in the U.S.

90-Day Duty Deferral

NEW 4/20: Traders Get Immediate 90-Day Duty, Tax, and Fee Postponement - Adjustments to April Periodic Monthly Statement Due by April 20 at 11:59 PM EDT. 

Companies are still pushing for legislation that would suspend additional tariffs, for all entries, for a longer period. Those interested in participating in this initiative should contact trade consultant Nicole Bivens Collinson at (202) 730-4956.

Uniform Essential Company Definition

Trade groups are asking President Trump as well as state governments and city mayors for more uniform determinations of which companies and industries are considered essential and will be able to continue operating as a growing number of jurisdictions issue orders shutting down non-essential activities in response to the COVID-19 pandemic. 

Sandler, Travis & Rosenberg is actively working to assist companies affected by such orders. For more information or assistance, please contact trade consultant Nicole Bivens Collinson at (202) 730-4956.

Section 301 Medical Product Exemptions

The Office of the U.S. Trade Representative is accepting comments through at least June 25 on the possible removal of the Section 301 25% tariff on medical products from China, including those that may have previously been rejected for an exclusion. Each comment must (a) identify the product as precisely as possible, including its ten-digit HTSUS subheading and its functionality and physical characteristics, and (b) explain precisely how it relates to the COVID-19 response (e.g., the product may be directly used to treat the virus, limit the outbreak, or produce other needed medical care products).

For more information or assistance in filing a comment, please contact trade consultant Nicole Bivens Collinson at (202) 730-4956 or trade attorney Kristen Smith at (202) 730-4965.

Assistance Importing PPE and Related Products

Companies are increasingly importing PPE, medical and related products in response to the COVID-19 pandemic. Concurrently, federal trade regulatory agencies are announcing changes to their operations.  This is further complicated by some countries, such as China, imposing export requirements, testing, certification, etc.

ST&R can provide assistance navigating these changes. For more information, please contact trade attorney Lenny Feldman at (305) 894-1011. For specific information on dealing with China's new restrictions, please contact Harry Zhang.

Assistance Exporting PPE and Related Products

Effective April 7, 2020, the Department of Homeland Security has issued a temporary rule that prohibits exports of personal protective equipment being used to treat COVID-19 without explicit approval by the Federal Emergency Management Agency.

For questions and support relating to PPE exports, please reach out to ST&R’s export controls and sanctions leader, Kristine Pirnia, at kpirnia@strtrade.com. The full list of prohibited exports can be found under the FEMA heading below.

Using Reconciliation and Transfer Price Adjustments to Lower Duties

Companies may be able to use a sophisticated transfer pricing strategy to achieve significant duty savings and conserve cash. Transfer pricing represents the price one division of a company charges another for its goods and services. Retroactive transfer pricing adjustments are generally considered part of the customs value of previously imported goods and may need to be reported to U.S. Customs and Border Protection.

Utilizing CBP’s reconciliation program and ensuring that their related-party prices meet CBP’s requirements not only permit companies to take advantage of any retroactive transfer price adjustments by reducing previously declared dutiable values, thereby lowering duty liability, but they also help provide much needed liquidity. If you feel your company can benefit from such savings, please contact customs attorneys Charles Crowley, Mark Segrist, or Lou Shoichet to learn more.

Navigating Retail Customer Order Cancellations

Due  to COVID-19 economic difficulties, many vendors who act as importers are facing significant order cancellations from retail customers. Consequently, these importers must navigate corresponding upstream commercial agreements with their foreign vendors including consideration of their ongoing imports and delivery options.  ST&R can assist importers and strategically collaborate to identify cost and sales savings strategies.

Please contact Beth Ring for more information on how Sandler, Travis & Rosenberg PA can identify creative solutions to these immediate issues.

Impacts on U.S. Trade Agency Operations

Below is an listing of announcements from federal trade regulatory agencies regarding changes to their operations in response to the COVID-19 pandemic. 

Please note that the list below is an attempt to provide information on trade-related measures. It is not exhaustive, and we recommend that you refer to the agency website for official information. Feel free to contact us with issues, additions or questions.

Census

Customs and Border Protection

Visit CBP's Coronavirus (COVID-19) Updates and Announcements webpage. Visit their web portal for answers to COVID-19 related import questions.

Department of Homeland Security

Visit the DHS Coronavirus (COVID-19) webpage.

Directorate of Defense Trade Controls - State Department

Export-Import Bank

Federal Emergency Management Agency

There is an exception for shipments made by or on behalf of U.S. manufacturers with continuous export agreements with customers in other countries since at least January 1, 2020, so long as at least 80% of the manufacturer's domestic production of covered materials, on a per-item basis, was distributed in the U.S. in the preceding 12 months.
Federal Register Document #2020-07659

Federal Maritime Commission

Food and Drug Administration

Visit the FDA webpage on information for filing PPE and medical devices during COVID-19.

International Trade Administration 

International Trade Commission

Office of Foreign Assets Control

U.S. Department of Agriculture

U.S. Trade Representative


Worldwide Import Flexibilities and Export Restrictions

Information on changes to imports & exports by country is below. For the World Customs Organization's COVID-19 updates, click here. For a WTO list of trade and trade-related measures, click here

Please note that the country actions listed below are an attempt to provide information on trade-related measures. They are not exhaustive, and we recommend that you refer to the original notices for official information. Feel free to contact us with issues, additions or questions.

ARGENTINA

Import Flexibilities

Export Restrictions


AUSTRALIA

Import Flexibilities

Export Restrictions


BRAZIL

Import Flexibilities

Export Restrictions


CANADA

Import Flexibilities

  • Less Stringent Requirements for Drug and Medical Device Imports. An interim order dated March 30, 2020, allows the minister of health to permit the exceptional importation and sale of drugs (including hard surface disinfectants and hand sanitizers), medical devices, and foods for special dietary purposes that do not fully comply with Canadian requirements but are manufactured according to comparable standards. In certain limited cases, the interim order would also allow the exceptional sale of an unapproved medical device or food for a special dietary purpose that is manufactured in Canada when the product is needed to respond to a shortage. In addition, the interim order introduces a mandatory mechanism for the minister of health to be notified of shortages of medical devices considered to be critical during the COVID-19 pandemic and modifies certain application requirements to allow for the expedited authorization of biocide drugs, such as hard surface disinfectants and hand sanitizers.
    Interim Order Respecting Drugs, Medical Devices and Foods for a Special Dietary Purpose in Relation to COVID-19
  • Extension of Timeframes for Payment of Customs Duties and GST. The Canada Border Services Agency announced March 27 that the timeframe for all payments due to that agency has been extended to June 30. This includes customs duties; the goods and services tax (generally five percent) on regular imports, re-assessments, penalties, etc.; and charges on statements of account for March that are due April 1. Customs duty and GST payments on imports are typically due before the first day of the month following the month in which the statements of account are issued. The CBSA notes that there is no change to the accounting timeframes prescribed by the Accounting for Imported Goods and Payment of Duties Regulations. As a result, importers must continue to submit accounting declarations for imported goods released on minimum documentation within the required timeframes.
    Customs Notice 20-11

CHILE

Import Flexibilities


CHINA

Export Restrictions


COLOMBIA

Import Flexibilities

Export Restrictions


COSTA RICA

Import Flexibilities

Export Restrictions


ECUADOR

Import Flexibilities

Export Restrictions


EL SALVADOR

Import Flexibilities

Export Restrictions


EUROPEAN UNION

Find links to the official EU trade websites below.

Following are links to individual member states customs websites:

Austria Belgium Bulgaria Croatia Czech Republic Cyprus Denmark Estonia
Finland France Germany Greece Hungary Ireland Italy Latvia
Lithuania Luxembourg Malta The Netherlands Poland Portugal Romania Slovenia
Slovakia Spain Sweden Switzerland UK      

Import Flexibilities

Export Restrictions

Exports to Albania, Andorra, Bosnia & Herzegovina, Faeroe Islands, Gibraltar, Iceland, Kosovo, Liechtenstein, Montenegro, Norway, North Macedonia, San Marino, Serbia, Switzerland, and Vatican City, as well as the overseas countries and territories listed in Annex II to the Treaty, are exempt. 

Commission Implementing Regulation 2020/568
European Commission Trade Directorate press release


GUATEMALA

Import Flexibilities


INDIA

Import Flexibilities

Export Restrictions


INDONESIA

Import Flexibilities

Export Restrictions


JAPAN

Import Flexibilities


MALAYSIA

Import Flexibilities

Export Restrictions


MEXICO

Import Flexibilities


MYANMAR

Import Flexibilities

Export Restrictions


NEW ZEALAND

Import Flexibilities


PANAMA

Import Flexibilities


PARAGUAY

Import Flexibilities

Export Restrictions


PERU

Import Flexibilities


PHILIPPINES

Import Flexibilities


SINGAPORE

Import Flexibilities


SOUTH KOREA

Export Restrictions


TAIWAN

Import Flexibilities

Export Restrictions


THAILAND

Import Flexibilities

Export Restrictions


URUGUAY

Import Flexibilities


VIETNAM

Import Flexibilities

Export Restrictions



Macro Impacts on Trade

Customs & International Headlines