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COMMERCE DEPARTMENT INITIATES CIRCUMVENTION INVESTIGATION ON SOLAR CELLS AND MODULES EXPORTED FROM MALAYSIA, THAILAND, VIETNAM, AND CAMBODIA CONTAINING PARTS AND COMPONENTS PRODUCED IN CHINA

On March 28, 2022, the Department of Commerce (“DOC”) initiated a country-wide circumvention investigation on Crystalline Silicon Photovoltaic Cells, Whether or Not Assembled Into Modules, from the People’s Republic of China (“CSPV”), which are further processed in Malaysia, Thailand, Vietnam, and/or Cambodia prior to exportation to the United States.  The investigation was requested in a […]

USTR REINSTATES 352 EXPIRED CHINA 301 EXCLUSIONS

On March 23, 2022, the Office of the United States Trade Representative (USTR) announced its determination to reinstate 352 expired China 301 exclusions.  The reinstated exclusions will apply to merchandise imported between October 12, 2021 and December 31, 2022. This action follows the solicitation of public comments in connection with the USTR’s evaluation of 549 […]

UNITED STATES IMPOSES EXPORT RESTRICTIONS AGAINST RUSSIA

In response to Russia’s invasion of Ukraine, the United States has imposed significant restrictions on exports to Russia.  Effective February 24, 2022, goods covered by Categories 3-9 of the Commerce Control List (CCL) are subject to license requirements and licensing is under a “policy to deny.”  The involved CCL categories cover:  Electronics; Computers; Telecommunications; Information […]

BIS SEEKS PUBLIC COMMENTS ON THE SECTION 232 EXCLUSIONS PROCESS

In a February 10, 2022 Federal Register notice, the Bureau of Industry and Security (“BIS”) announced that it is seeking public comments regarding the Section 232 exclusion process currently in place with respect to the additional duties assessed on certain steel and aluminum products. In particular, BIS is seeking public comment on the responsiveness of […]

U.S. ANNOUNCES DEAL WITH JAPAN TO PARTIALLY ROLLBACK SECTION 232 STEEL TARIFFS

On February 7, 2022, the USTR announced a deal to partially rollback the Section 232 tariffs on steel from Japan through the use of a tariff rate quota (“TRQ”).  The TRQ will be set to allow for the importation of historically-based volumes of Japan steel products without the assessment of Section 232 tariffs.  Highlights of […]

2/2/2022 CHINA 301 LITIGATION UPDATE

On February 1, 2022, the three-judge panel at the U.S. Court of International Trade heard oral argument in the pending litigation challenging the imposition of Section 301 Lists 3 and 4A additional duties on certain goods from China The oral argument lasted for over three hours and centered on three main topics: 1) whether the […]

HEATHER LITMAN APPOINTED MEMBER OF THE 16TH TERM OF THE COMMERCIAL CUSTOMS OPERATIONS ADVISORY COMMITTEE

GDLSK is pleased to announce that Heather Litman, a partner in the firm’s Los Angeles office, has been appointed as a member of the 16th term of the Commercial Customs Operations Advisory Committee (“COAC”). The COAC advises the Secretaries of the Department of the Treasury and the Department of Homeland Security on all matters involving […]

TASK FORCE SEEKS PUBLIC COMMENTS ON METHODS TO PREVENT THE IMPORTATION OF CHINA FORCED LABOR GOODS

On December 23, 2021, the President signed into law the Uyghur Forced Labor Prevention Act (“the Act”). GDLSK’s summary can be accessed here. One provision requires that the Forced Labor Enforcement Task Force (“Task Force”) (a multi-agency body created to enforce the forced labor import prohibition) solicit public comments “on how best to ensure that goods […]

GDLSK ATTORNEYS TO SPEAK ON HOT BUTTON ISSUES ON FIRST SALE

On January 26, 2022, GDLSK Partners Arthur Bodek and Kevin Leonard will be speaking on the subject of the first sale duty-savings opportunity at an online program hosted by the U.S. Fashion Industry Association. The Customs valuation of imported merchandise continues to be one of the most important aspects of business planning for fashion companies.  […]

CHINA ISSUES A WHITE PAPER PROVIDING INSIGHT INTO THE POLICY OBJECTIVES AND ENFORCEMENT MECHANISMS OF ITS EMERGING EXPORT CONTROL REGIME

On 29 December 2021, China’s State Council released a white paper on China’s export control regime, laying out China’s policy objectives as it expands and modernizes its dual-use export control regime. In this paper, the Chinese State Council has articulated its intention to promulgate and administer a “fair, reasonable, and non-discriminating export control system.”  Also of […]