Thompson & Associates, PLLC

01/19/2024

Activity under the EAPA has been picking up lately, so it would be timely to address the statute and administrative procedures under it and describe some of the enforcement concerns for US importers and their foreign suppliers.

Simply stated, antidumping duties are imposed by the US Commerce Department when imported merchandise has been determined to be sold at less than fair value. This usually occurs when the price in the United States is lower than the price in the home market. Countervailing duties are imposed on merchandise which has received subsidies from a foreign government.

It’s common for combined antidumping and countervailing duties to be triple digit. This level of additional tariff generally causes transactions to become uneconomical. At the same time, US industry often raises its prices and restricts supply after it receives tariff protection.

Watch as George Thompson, international trade attorney, details how antidumping and countervailing evasion cases are brought to the attention of CBP, the actions CBP takes, and penalties that can be imposed...

https://gwthompsonlaw.com/the-enforce-and-protect-act-what-you-should-know-about-antidumping-and-countervailing-duties/

12/21/2023

In anticipation of the Uyghur Forced Labor Prevention Act, a number of federal agencies issued a joint Xinjiang Supply Chain Business Advisory in July 2021. An Addendum to that advisory was released in September 2023.

The Addendum identifies a wide range of additional products and industries believed to use forced labour or child labor. Much of the information it presents was developed by non-government organizations and other private parties.

Watch as George Thompson, international trade attorney, discusses the Addendum, the products named, and the implications for importers and manufacturers...

CLICK BELOW TO WATCH VIDEO:

https://gwthompsonlaw.com/uflpas-expanding-reach/

A recent addendum to the Xinjiang Supply Chain Business advisory has far-reaching implications for a number of products.

09/04/2023

Companies that export from the U.S. but do not import are ineligible for the primary CTPAT program. To support export growth and competitiveness of U.S. businesses in the global market, CBP developed the Exporter Program, a module of the CTPAT program.

Watch as George Thompson, international trade attorney, discusses the requirements for program certification and how exporters can benefit when shipping to countries participating in Mutual Recognition Arrangements...

https://gwthompsonlaw.com/ctpat-module-for-exporters/

08/18/2023

Determining when a product can be labeled or advertised as Made in America is an ongoing compliance challenge.

One seeming gray area arises when a product which undergoes production activities in the U.S. is no longer an article of foreign origin falling under CBP's oversight. If it undergoes a substantial transformation in the United States, it is no longer considered to have foreign origin under CBP’s rules. This does not mean, however, that it can now be labeled as Made in America. Instead, the Federal Trade Commission's very different standard will apply for that determination.

George Thompson, international trade attorney, discusses FTC requirements for “Made in USA” labeling... CLICK BELOW TO READ MORE:

George Thompson, international trade attorney, discusses FTC requirements for “Made in USA” labeling.

05/17/2023

Companies that export from the U.S. but do not import are ineligible for the primary CTPAT program. To support export growth and competitiveness of U.S. businesses in the global market, CBP developed the Exporter Program, a module of the CTPAT program.

Watch as George Thompson, international trade attorney, discusses the requirements for program certification and how exporters can benefit when shipping to countries participating in Mutual Recognition Arrangements... CLICK BELOW TO READ MORE:

International Trade Attorney discusses the four elements of the new enforcement policy and their implications for exporters and reexporters.

05/09/2023

The Customs Trade Partnership Against Terrorism (CTPAT) program, which now includes provisions regarding enforcement of the Uyghur Forced Labor Prevention Act, has been expanded to include the Trade Compliance Program (TCP).

Watch as George Thompson, international trade attorney, discusses the requirement for and benefits of participation in the TCP... CLICK BELOW TO WATCH VIDEO

International Trade Attorney discusses the four elements of the new enforcement policy and their implications for exporters and reexporters.

01/05/2023

It’s just a little over a year ago that the Uyghur Forced Labor Prevention Act became law. From all appearances, Customs and Border Protection has been diligent in enforcing its prohibitions and those of 19 U.S.C. § 1307. According to the agency...

It’s just a little over a year ago that the Uyghur Forced Labor Prevention Act became law. From all appearances, Customs and Border Protection has been diligent in enforcing its prohibitions and those of 19 U.S.C. § 1307. According to the agency, “In November 2022, CBP identified 444 entries va...

12/13/2022

Master the Rules of Origin:

A rule of origin is a standard for determining where a product is from that may be used for a number of different regulatory purposes such as eligibility for tariff preference under various bilateral and multilateral trade agreements.

Proper application of a rule of origin is an essential skill in international trade, one that will prevent merchandise from being denied entry or being subject to duties rather than receiving preferential treatment.

Join me on January 31st, 2023 for a live and interactive webinar to learn how to precisely determine the country of origin. The webinar topics include important information on:

• Reasons for Rules of Origin
• Substantial Transformation
• Free Trade Agreements and the Tariff Shift Standard
• Federal Trade Commission “Made in USA” Requirements

More info here:
https://www.globaltrainingcenter.com/country-of-origin/

Register here:
https://www.globaltrainingcenter.com/event/country-of-origin-webinar-4/

Global Training Center

10/06/2022

The Bureau of Industry and Security recently published expanded export control sanctions on Russia and others.

Industry sector controls on Russia have been extended to Belarus, and the military end use/end user controls have been expanded to include surreptitious suppliers to parties covered by the MEU license requirement.

The BIS rule now expands the military end user controls to Belarusian, Burmese, Cambodian, Chinese, Russian, and Venezuelan military end users located anywhere in the world, not just in those countries themselves. The military-intelligence end user controls for those countries are similarly expanded.

The expanded controls include a number of chemicals identified as potentially useful for chemical and biological weapon development. Other newly-designated articles include equipment useful for advanced manufacturing.

Watch as George Thompson, International Trade Attorney, details these changes and the implications for exporters and reexporters... CLICK BELOW TO SEE VIDEO:

International Trade Attorney discusses the four elements of the new enforcement policy and their implications for exporters and reexporters.

09/28/2022

The Bureau of Industry and Security has adopted a new administrative enforcement approach for resolving export control violations. BIS anticipates it will result in imposition of substantially higher monetary penalties for egregious cases, while also providing for non-monetary resolutions of less serious ones.

The new policy will make effective compliance programs even more essential for both U.S. and foreign companies.

Watch as George W. Thompson, International Trade Attorney, discusses the four elements of the new enforcement policy and their implications for exporters and reexporters...

International Trade Attorney discusses the four elements of the new enforcement policy and their implications for exporters and reexporters.

08/10/2022

A couple of years ago, we first awarded The Dummies as a prize to commemorate “the most embarrassing export control penalty of the year.” Even though it’s only July, I think we may already have a “winner” for 2022... CLICK BELOW TO READ MORE:

A couple of years ago, we first awarded The Dummies as a prize to commemorate “the most embarrassing export control penalty of the year.” Even though it’s only July, I think we may already have a “winner” for 2022. Unlicensed Controlled Technology Exports . . . As explained by the Bureau o...