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Amendments to the Export Administration Regulations may seem so dry and pedantic to non-specialists. The bureaucratic jargon, references to dry-as-dust sub-subsections, and wooden prose can mask legal changes with important consequences. I’ll leave it to you, Gentle Readers, to consider whether the Bureau of Industry and Security’s three new and proposed rules restricting trade with [...]

Around the same time the Food and Drug Administration was loosening import requirements for such Personal Protection Equipment as masks and respirators, the Federal Emergency Management Agency imposed export controls on many of the same items. FEMA’s Temporary Final Rule limits exports of N95 filtering facepiece respirators, other filtering facepiece respirators, elastomeric, air-purifying respirators and appropriate particulate [...]

Maybe you already have one. Or ten. Perhaps you command them with a steady voice – “Alexa?” “Hey, Google!” – or you could be old school and just reach out and actually turn something on or off by hand. Whichever is your style, smart plugs and bulbs have invaded our homes, and they won’t be going away.   iHome SmartPlugs plug into an [...]

Is Trade Compliance the Lone Ranger?  There are companies, surely not yours, where various departments are viewed as spokes around the hub of the trade compliance department. Each department operates as if trade compliance is accomplished “out there somewhere” rather than taking an active part in making sure the company meets its import and/or export [...]

Step One: Know Your HTS Subheading Every product subject to a proposed or ongoing Section 301 tariff action is identified by an 8-digit or 10-digit HTS Subheading. This search engine allows you to search by an 8-digit HTS Subheading to obtain information about a proposed or ongoing Section 301 tariff action. If you do not [...]

Women in trade | S1: Episode 8 We discovered a new podcast featuring women who work in international trade.  The podcast is only a few episodes into its first season but they have hit the ground running with a lineup of amazing and influential ladies in trade compliance.   The podcast, Women In Trade, is [...]

The Coronavirus pandemic has affected pretty much every aspect of life in the United States. We can now add trade policy to the list. As part of the Federal government’s efforts to address the spread and treatment of COVID-19, the Trade Representative’s office is considering exclusion of medical care products from the Section 301 tariffs on imports from [...]

Where Is Brexit? What Is Brexit?  Over time, the UK has given us many interesting tales – from Camelot to Hogwarts. But there hasn’t been a more mystical story from the UK in decades as the tale of Brexit. If you have left aside the Harry/Meghan saga to keep up with the Brexit (British exit) story, then you must know that [...]

Just when I thought I was running out of blog topics, along comes the Federal Circuit to stir the pot for country of origin determinations under the Federal Acquisition Regulation. In Acetris Health, LLC v. United States, the appellate court clarified the circumstances under which an article qualifies as a “U.S.-made end product” qualified for purchase [...]

Part 3 of 3: “CBP Wants YOU! Increased AD/CVD Scrutiny Abounds”   AD/CVD Consequences: Real Live American Disasters  Inflated AD/CVD and high tariffs have real world consequences. One of the hardest-hit industries by high tariffs and AD/CVD besides the steel and aluminum industries is the hardwood industry and those companies who depend upon an inexpensive supply of raw wood and [...]