MEMO TO CLIENTS ISSUE 22-011 – September 27, 2022

FDA Food Facility Renewal Registration Begins Oct. 1 The Food and Drug Administration’s (FDA) Food Facility Registration Renewal will open on October 1, 2022.  The registration period will be open through December 31, 2022. All food facilities of an importer’s supply chains must submit a timely renewal. Failure to do so will cause products to be denied entry into the …

Special Memo – September 15, 2022

Rail Strike Averted The rail strike that was due to go into effect at midnight Friday has been averted. The Secretary of Labor made an announcement this morning that after 20 hours of negotiation an agreement was reached. The agreement must still be ratified by the rank and file of the unions, but there will be no work stoppage for …

Special Memo – September 14, 2022

 Railroad Strike Looms The US Class 1 railroads are facing a possible shutdown due a potential rail strike. The railroads have been negotiating with several rail unions and some deals have been made with 10 out of the 12 rail unions. The two that are left are the biggest of the twelve: The Brotherhood of Locomotive Engineers and Trainmen and …

MEMO TO CLIENTS ISSUE 22-010 – September 9, 2022

South Korea Expresses Concerns on Electric Vehicle Provisions of the Inflation Reduction Act South Korea has expressed its concerns about the provisions on electrical vehicles in the Inflation Reductions Act. The Trade Industry and Energy Minister have said that while South Korea supports the efforts to expand clean energy, the Act grants tax benefits to U.S. EV’s over imported EV’s …

MEMO TO CLIENTS ISSUE 22-009 – August 18, 2022

User Fee Increase Coming October 1 U. S. Customs and Border Protection (CBP) has announced an increase in user fees in a Federal Register Notice (FRN) issued on August 1, 2022. Cobra fees for 23 separate user fees will be increased. This includes Merchandise Processing Fees charged on Customs entries. For formal entries, the ad valorum rate of .3465% will …

MEMO TO CLIENTS ISSUE 22-008 – July 8, 2022

CBP Introduces New Green Trade Strategy Customs and Border Protection (CBP) launched the “Green Trade Strategy,” a framework to incentivize green trade, strengthen the agency’s environmental enforcement posture, accelerate green innovation, and improve climate resilience and resource efficiency. The agency said the strategy sets up a proactive model to combat the negative impacts of climate change on the agency’s trade …

Special Memo – June 17, 2022

UFLPA Instructions Have Been Published Today the Department of Homeland Security (DHS) released the strategy instructions of the Uyghur Forced Labor Prevention Act (UFLPA) which were expected to be released on June 21. The strategy instructions were required to be released to the trade in order to begin enforcement of the Act. A copy of the “Strategy to Prevent the …

MEMO TO CLIENTS ISSUE 22-007 – June 16, 2022

Operational Guidelines on UFPLA are not the Final Word Last Friday we sent out a memo touting U.S Customs and Border Protections Guidelines for the Uyghur Forced Labor Act (UFPLA). These are not the instructions that we have all been waiting for. These are actually operational guidelines that summarize much of what CBP has been presenting on their many webinars. …

MEMO TO CLIENTS ISSUE 22-006 – May 27, 2022

CBP Announces Trade Symposium Registration U.S. Customs and Border Protection (CBP) has announced that registration for this year’s Trade Symposium will open on June 1, at 12:00 PM EST. They will send out details on how to register that morning. We will send out a message to everyone who receives our memo as soon as we get more details. The …

MEMO TO CLIENTS ISSUE 22-005 – April 28, 2022

CBP is Issuing “Known Importer” Letters in Advance of UFLPA U.S. Customs and Border Patrol (CBP) has started to send out letters to importers who are identified as possibly having previously imported goods that may be subject to enforcement under the Uyghur Forced Labor Act (UFLPA) which will become effective on June 21, 2022. Under ULFLPA, there is a presumption …

MEMO TO CLIENTS ISSUE 22-004 – April 8, 2022

Congress Passes Legislation to Suspend Russia and Belarus from Normal Trade Relations The U.S. Congress has passed bill HR 7108 – Suspending Normal Trade Relations with Russia and Belarus Act and submitted it in to President Biden. This act will temporarily revoke the Most Favored Nation (MFN) status from both Russia and Belarus and subject them to HTSUS Column 2 …

Special Memo – March 24, 2022

USTR Reinstates 352 Exclusions to China 301 Duties On March 23, the Office of the U.S. Trade Representative (USTR) made an announcement of reinstatement of 352 of the China 301 duty exclusions that expired last year. These exclusions include 137 from List 1, 59 from List 3 and 87 form List 4a. We should be able to file entries under …

MEMO TO CLIENTS ISSUE 22-003 – March 18, 2022

FMC Holds Hearings on Enforcement The Federal Maritime Commissions (FMC) has held hearings on enforcement activities that included prioritizing enforcement efforts dealing with ocean carrier behavior in compliance, particularly with the guideline that the FMC issued in 2020.  Personnel from the Bureau of Enforcement covered how they are meeting the direction from Chairman Maffei on enforcement efforts on unreasonable demurrage …

MEMO TO CLIENTS ISSUE 22-002 – February 24, 2022

FMC Commissioner Daniel Maffei Disparages PierPass The West Coast Terminal Operator Agreement (WCMTOA) filed an amendment to the PierPass agreement that would make it a permanent program. PierPass is an incentive program to assess fees to beneficial cargo owners to encourage use of off-peak gate services to help eliminate heavy daytime traffic at the Ports of Los Angeles and Long …

MEMO TO CLIENTS ISSUE 22-001 – January 20, 2022

Bill Introduced to Tighten the Sec. 321 Process Congressman Earl Blumenauer (D-OR), the Chairman of the House ways and Means Committee, has announced new legislation to toughen requirements for release of de minimis shipments (Section 321) with value under $800.00. Representative Blumenauer wants to eliminate loophole that will make it easier for people to allow better oversight on the goods …

MEMO TO CLIENTS ISSUE 21-012 – November 22, 2021

Schumer wants to add MTB and GSP Renewal to NDAA Senate Majority Leader Chuck Schumer has written to his colleagues that it is likely that the Senate will consider the National Defense Authorization Act this week and that the China package that includes the renewal of the Miscellaneous Trade Bill (MTB) and the Generalized System of Preferences (GSP) that the …

MEMO TO CLIENTS ISSUE 21-011 – October 29, 2021

Ports of LA/LB Assessing New Fee to Help Relieve Congestion In cooperation with the Biden Administration Task Force, the Ports of Los Angeles and Long Beach have announced that they will begin to assess a new fee to carriers for containers that dwell too long on marine terminals. The ports will have two categories for the new fee. The first …

Special Memo – October 6, 2021

 USTR Will Review Extending Expired Exclusions  The Office of the U.S. Trade Representative (USTR) has announced that they will have a review for possible reinstatement of the 549 exclusions that expired on December 31, 2020.  In a USTR notice, the USTR will accept comments on its published list beginning on October 12, 2021. The comments for the need of the …

MEMO TO CLIENTS ISSUE 21-010 – October 4, 2021

USTR Extends Exclusions on Certain Covid-19 Pandemic Medical Care Products The Office of the U.S. Trade Representative (USTR) issued a notice that would extend the current exclusions for certain medical care products needed to address the covid-19 pandemic.  These exclusions were scheduled to expire on September 30, 202l. That date has been extended for 45 days to November 14. The …

MEMO TO CLIENTS ISSUE 21-009 – September 14, 2021

CIT Vacates Repository Order for China 301 Duties on Lists 3 and 4a The Court of International Trade had issued requirements for a repository list of all the unliquidated entries included in the court filings for refunds of the China 301 duties paid under List no. 3 and 4a. In a court order issued on September 8, 2021, the CIT …