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Lead Content Limit for Children's Products to be Reduced to 100 PPM

Pursuant to a Consumer Product Safety Commission (“CPSC”) vote on July 13, 2011, a Federal Register notice will soon be published announcing that children’s products will be required to meet a reduced lead limit of 100 parts per million (“ppm”) as of August 14th, 2011. This limit applies to the lead content of the substrate material in a children’s product (the lead content of paint and similar surface coatings is governed by a different standard).

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CBP Agrees to Cancel PMS Late Filing Claims

The Customs & Border Protection National Finance Center has recently issued liquidated damages claims in connection with Periodic Monthly Statements (“PMS”) where payments were made late. These claims have for the most part been issued against the importers of record who have generally sought to claim against the broker for causing the late payment.

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U.S. International Trade Commission Declines to Recommend Additional Duty-Free "Festive Article" Tariff Provisions

In a recently issued report, the U.S. International Trade Commission (“ITC”) has determined that it will not recommend to the President the adoption of additional duty-free “festive article” tariff provisions.

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Reminder on Ozone-Depleting Chemicals Tax on Imports

The Internal Revenue Service (IRS) recently increased its scrutiny of importers who are subject to the Ozone-Depleting Chemicals (ODC) excise tax. They are conducting audits, and proposing multi-million dollar assessments for compliance failures. Since 1989, an excise tax is imposed on any imported ozone-depleting chemical (“ODC”) and any imported products in which an ODC was used in the manufacturing process (“Imported Taxable Products”).

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