When clients are faced with unreasonable agency decisions, the unfair or inequitable application of law or policy, and litigation is either unavailable or an ineffective remedy, we have the ability to seek legislative or executive solutions. The Firm’s extensive knowledge of administrative and legislative processes often enables it to secure alternative forms of relief when conventional means may not suffice. In this regard, we have successfully enlisted Congressional assistance to obtain results on behalf of constituents, or to persuade policy makers at the appropriate administrative agencies to revise objectives or carve out appropriate exceptions, where these are warranted.
Examples of such actions might include:
- Administrative Rulemaking – We routinely draft and file comments on various rules proposed by US Customs and Border Protection, the Department of Commerce, the International Trade Commission, the Consumer Product Safety Commission, and other agencies responsible for regulating foreign trade.
- Drafting and urging adoption of amendments to the Harmonized Tariff Schedule, such as changes to existing tariff language or entirely new tariff provisions (e.g. 484(F) Committee proceedings), and other International Trade Commission proceedings.
- Drafting Miscellaneous Tariff Legislation – We have sought the temporary reduction or suspension of duties on a wide variety of US imports, as well as reliquidation of specific entries after expiration of the normal protest period.
- Coordinating and supporting lobbying efforts in connection with legislation affecting the regulation of international trade.
- Representing associations and individual companies in Section 201 “escape clause” proceedings before the International Trade Commission and the US Trade Representative.
- Appearing before the US Trade Representative in Section 301 actions, both to open foreign markets for our clients and to defend our clients against allegations of unfair activity.