First Sale—CBP Strictly Enforcing Requirements

First Sale—CBP Strictly Enforcing Requirements

U.S. Customs and Border Protection (CBP) is strictly enforcing the interpretation of first sale requirements. First sale is a lawful way for importers purchasing goods in a multi-tiered transaction to reduce the amount of import duty they pay by declaring the price charged between the manufacturer and the middleman rather than the price charged between…

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New Chinese Postal Code Entry Requirement Scheduled

New Chinese Postal Code Entry Requirement Scheduled

The updated U.S. Customs and Border Protection (CBP) Automated Commercial Environment (ACE) deployment schedule outlined an upcoming requirement to include a postal code for entries of China-origin goods. New Chinese manufacturer IDs are now scheduled for deployment on March 18, 2023. The UFLPA Region Alert will add three new data elements that will be performed…

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New ITAR Guidelines Issued by the DDTC

New ITAR Guidelines Issued by the DDTC

The State Department’s Directorate of Defense Trade Controls (DDTC) has released its long-awaited updated compliance program guidelines which are intended to outline and detail “key el­ements” of an effective compliance program, the agency said. The guidelines include the following: Management Commitment DDTC Registration, Jurisdiction and Classification, Authorizations, and Other ITAR Activities Recordkeeping Reporting and Addressing…

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UPDATE: 81 Section 301 Exclusions for COVID-19 Goods Extended

UPDATE: 81 Section 301 Exclusions for COVID-19 Goods Extended

UPDATE: 2/7/2023—USTR is extending the 81 medical product exclusions until May 15, according to a Federal Register publication notice. The Office of the U.S. Trade Representative (USTR) is extending exclusions of 81 medical-care products from Section 301 China tariffs until February 28, 2023. USTR felt this determination was warranted to continue combatting the needs from…

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Pakistan Due Diligence Guidance Updated 2022

Pakistan Due Diligence Guidance Updated 2022

Pakistan’s due diligence guidance has now been updated by the Bureau of Industry and Security (BIS). This guidance is meant to assist those dealing with exports to Pakistan, due to the nuclear and missile programs in the country that are subject to end-use and end-user restrictions pursuant to Part 744 of the Export Administration Regulations…

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Disregarding Government Export Regulations Could Mean Indictment

Disregarding Government Export Regulations Could Mean Indictment

The Department of Justice (DOJ) recently unsealed a federal indictment against three U.S. citizens and Quadrant Magnetics LLC. The defendants allegedly sent technical data drawings related to U.S. military projects to China and then supplied the Department of Defense (DOD) with prohibited Chinese-origin Items. The three U.S. citizens are being accused of exporting defense-related technical…

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