Owners or operators of companies that produce and distribute medical devices intended for commercial distribution in the U.S., including products that are imported for export only, must register annually with the FDA. Foreign and domestic medical device facilities that do not renew their registrations with the FDA by December 31, 2021, could be restricted from…
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According to a recent message sent out by U.S. Customs and Border Protection (CBP), “CBP will deny requests filed under 19 U.S.C. § 1504(b)(2) for an extension of time for liquidation of entries based solely on the pending Court of International Trade (CIT) litigation challenging the lawfulness of the Section 301 duties on Chinese goods…
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When importing—or exporting—goods under a lease agreement, it is important to understand that the items are not considered sold and that transaction value will not apply. Instead, importers must use one of the other methods of valuation, applied in sequential order, as part of their Reasonable Care. U.S. Customs and Border Protection’s (CBP) Informed Compliance…
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The three judges at the U.S. Court of International Trade, who are presiding over the Section 301 litigation, have scheduled for an oral argument to be held in New York City, on February 1. They also plan to broadcast the proceedings using a dedicated YouTube channel, which has yet to be identified. This news demonstrations…
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The Office of the U.S. Trade Representative (USTR) has announced an extension of 81 Section 301 tariff exclusions—which include certain medical-care products needed to address the COVID-19 pandemic—until May 31, 2022. USTR has also stated that the notice, “extends the 99 exclusions scheduled to expire on November 14, 2021, through November 30, 2021. Those exclusions…
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The U.S. will issue tariff rate quotas (TRQs) on imported steel and aluminum products, starting January 1, 2022. These quotas will allow limited amounts of EU steel and aluminum products to be entered into the U.S. free of Section 232 tariffs—which adds a 25 percent tariff on steel and 10 percent on aluminum imports. Steel…
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The Office of the U.S. Trade Representative (USTR) is seeking comments on whether it should reinstate hundreds of Section 301 product exclusions that expired either late last year or early this year. The commenting period begins October 12, and parties can submit comments until December 1. USTR will evaluate the possible reinstatement of certain exclusions…
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Due to Department Homeland Security (DHS) and U.S. Customs and Border Protection (CBP) security policy changes, effective October 3, all Automated Commercial Environment (ACE) Secure Data Portal account passwords will require a minimum of 15-characters. This new requirement will be enforced as of Oct 3, when the customs broker’s or freight forwarder’s current 12-character password…
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In a recent CSMS message, U.S. Customs and Border Protection (CBP) has issued updated guidance on importer’s—and broker’s—responsibilities for U.S. and foreign goods returning under HTS 9801.00.10 from their previous CSMS message in 2017. Under HTS 9801.00.10, goods are allowed to be entered duty-free, if the importer has the required documentation to prove that the…
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The State Department’s Directorate of Defense Trade Controls (DDTC) is cracking down on certain compliance requirements and violations involving software and technical data. The DDTC is enforcing a consent agreement requirement which “forces companies to review and verify the jurisdiction and classification status of all hardware and software relating to their International Traffic in Arms…
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