About The Webinar

U.S. Customs and Border Protection is proposing to expand the use of the part 102 non-preferential rules of origin for merchandise imported from Canada or Mexico.  This webinar will provide a refresher of the rules of origin along with examples of how origin determinations for products from Canada and Mexico could change for section 301 trade remedies, admissibility, quota, and government procurement.

Key Topics

  • distinguishing between preferential rules of origin as well as the part 102 versus substantial transformation non-preferential rules of origin
  • the intent and purpose behind the part 102 rules
  • the recent impact of the substantial transformation test on origin determinations
  • benefits and challenges in expanding the use of the part 102 non-preferential rules of origin
  • distinctions between rules of origin in customs regulations versus administrative rulings
  • examples of how country of origin determinations are made and can change under the part 102 rules  


Lenny P. Feldman

Managing Partner, Operating Committee

LENNY FELDMAN is a Managing Partner, Operating Committee with Sandler, Travis & Rosenberg, P.A., resident in the Miami office. He previously co-chaired the twenty-member Customs and Border Protection’s Commercial Customs Operations Advisory Committee, providing strategic recommendations directly to CBP, Homeland Security and Treasury executives on issues such as forced labor, intellectual property rights, e-commerce policy, trade partnership programs, enforcement and facilitation mechanisms, and regulatory reform. He currently serves as General Counsel and Customs Counsel to the National Customs Brokers & Forwarders Association of America (NCBFAA).


Mark Tallo

Partner, Advisory Committee

MARK TALLO is a Partner, Advisory Committee with Sandler, Travis & Rosenberg, P.A., resident in the Washington, D.C., office. His practice areas include customs, import and export compliance matters with a focus on advising clients regarding duty savings opportunities through the First Sale Rule as well as bilateral and regional free trade agreements and U.S. preference programs, including the Generalized System of Preferences (GSP). Mr. Tallo is also focused on the assessment and qualification of goods under the United States-Mexico-Canada Agreement or USMCA, with expertise in the automotive sector. In this regard, Mr. Tallo helps global automotive producers and suppliers navigate the complex USMCA rules of origin. 



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