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A new guidance document from the Bureau of Industry and Security designed to counter schemes to ship controlled items to nuclear- or missile-related activities in Pakistan highlights the due diligence measures that should be taken for all exports of goods subject to the Export Administration Regulations, particularly those destined for higher-risk destinations.
Importers should take this opportunity to review these requirements, ensure they have an FSVP in place for each food they import, and conduct mock FSVP inspections to prepare for possible FDA inspections.
Importers should be aware that while the COO claims made by their vendors may be correct under the source country’s rules, they may be incorrect under U.S. rules. With an ever-increasing tariff burden at stake, as well as potential penalties for getting it wrong, it is important for importers to understand the applicable rules and verify COO claims made by their suppliers.
Requests for exclusions from the additional tariff imposed on some $200 billion worth of imports from China (List 3 goods) may be submitted through Sept. 30. Any exclusions granted will be retroactive to Sept. 24, 2018, and remain in effect for one year from the date of publication of the exclusion determination in the Federal Register.
The Office of the U.S. Trade Representative is seeking input by Oct. 31 for its annual national trade estimate report on significant barriers to U.S. exports of goods and services and U.S. foreign direct investment.
Importers and others have until Sept. 20 to submit comments on the proposed increase from 25 percent to 30 percent of the additional tariff being imposed on $250 billion worth of imports from China. This increase is scheduled to take effect Oct. 1.
The Trump administration has indicated that another tariff increase on imports from China will be imposed with no flexibility for goods already in transit to the U.S.
Over the last month the Office of the U.S. Trade Representative has denied hundreds more requests for exclusions from the Section 301 additional tariffs on imports from China. USTR is continuing to review outstanding exclusion requests for List 1 and List 2 goods, imports of which are collectively worth about $50 billion, and has set a Sept. 30 deadline for requests for List 3 goods, which are worth about $200 billion.
President Trump announced Aug. 23 that he will further increase existing and pending tariffs on imports from China in response to Beijing’s move to raise its own tariffs on more than 5,000 additional goods from the U.S. The president also threatened to force U.S. companies to relocate operations out of China if bilateral trade relations worsen.
China has announced plans to increase tariffs on more than 5,000 additional goods imported from the U.S. if President Trump goes ahead with a 10 percent tariff hike on $300 billion worth of products from China. Press sources note that this move will result in nearly all Chinese imports from the U.S. being subject to higher tariffs.
Watches and jewelry remained the most seized commodity by value, wearing apparel continued to be the most seized item by number, and China and Hong Kong continued to account for more than three-quarters of the number of IPR seizures.
The ITC states that these changes principally (1) require petitions and comments to include certain additional information, (2) clarify and provide additional instructions with respect to information to be included in petitions and comments, and (3) revise the requirement regarding when petitions may be withdrawn.
The Trump administration is allowing limited exports to Huawei Technologies Co. Ltd. and its affiliates for another 90 days but has expanded export restrictions on Huawei to an additional 46 affiliates.
The additional 10 percent tariff set to be imposed on hundreds of billions of dollars’ worth of products imported from China (List 4A goods) will be triggered by the date of entry. As a result, there will be no reprieve for such goods that are currently on the water but unable to reach the U.S. before Sept. 1.
The following additional details concerning the Section 301 additional 10 percent tariff that will be imposed on List 4 goods imported from China have been made available by the Office of the U.S. Trade Representative.
The State Department is imposing, effective Sept. 16, certain sanctions on a Chinese entity and an executive of that entity for knowingly engaging on or after Nov. 5, 2018, in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum products from Iran.
USTR has issued a notice stating that the additional 10 percent tariff on List 4 imports from China will not be imposed on certain products. Additionally, the tariff will be delayed until Dec. 15 for products on List 4B.
U.S. Customs and Border Protection has announced that no earlier than Sept. 28 it will begin a test to allow Section 321 low-valued shipments, including those subject to partner government agency data requirements, to be entered via a new informal entry type 86 in the Automated Commercial Environment. This test is separate from one slated to begin Aug. 22 under which additional data elements for Section 321 goods will be transmitted in advance of their arrival.
Recently updated guidelines from U.S. Customs and Border Protection will make it more expensive to secure a return of goods seized for violations of U.S. export laws or regulations. However, export compliance programs and other factors can help lower that cost.
U.S. Customs and Border Protection sources state that CBP’s next customs broker license examination has been moved from Oct. 23 to Oct. 17. CBP states that registration for the exam will open in mid-August.