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


Lenny Feldman is a Senior Member of ST&R who has counseled thousands of companies on creating “comply chains” while increasing efficiencies and lowering costs. He concentrates his practice in complex issues pertaining to import and export compliance, valuation, trade preference/country of origin, penalty mitigation, supply chain security (including CTPAT), intellectual property, and other programs involving CBP and other government agencies. He is recognized internationally as a leading strategic advisor having co-chaired and served on CBP’s Commercial Customs Operations Advisory Committee under three administrations.


Mark Tallo


MARK TALLO is a Member in the Import and Export Practice Group of Sandler, Travis & Rosenberg, P.A., resident in the Washington, D.C., office. His practice areas include customs, import and export compliance, and international anti-corruption measures such as the Foreign Corrupt Practices Act as well as advising clients on duty savings opportunities through the First Sale Rule and U.S. preference programs, including the Generalized System of Preferences and bilateral and regional free trade agreements.



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