Guidance on Forced Labor Allegations

Guidance on Forced Labor Allegations

It can be daunting to submit forced labor allegations in the U.S. Customs and Border Protection (CBP) system. To ease the pressure on filers CBP has released two useful documents—a Recommended Guidelines for Submissions of Forced Labor Supporting Documents and a Forced Labor Allegation Submission Checklist. These resources will help clarify details of what information…

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BIS Announces New Russia Export Restrictions

BIS Announces New Russia Export Restrictions

The Bureau of Industry and Security (BIS) has announced new Russia-related export controls, including actions that increase its Russian and Belarusian Industry Sector Sanctions, extend its foreign direct product rule restrictions, and add 71 new entities to the Entity List. Reason for the Updates Some of the changes in the final rule—effective May 19—“better align”…

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International Transport Guidance on Lithium-ion Batteries

International Transport Guidance on Lithium-ion Batteries

Together with several industry bodies the global carrier, Cargo Incident Notification and System Networks (CINS) have compiled and published The Lithium-ion Batteries in Containers Guidelines in an effort to prevent the increasing risks that the transport of lithium-ion batteries by sea creates, providing suggestions for identifying such risks. In recent years, serious, and sometimes catastrophic…

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FDA Unique Facility Identifier Required

FDA Unique Facility Identifier Required

The policy of enforcement discretion that allowed registrants to enter “pending unique facility identifier (UFI) Option” has now been terminated by the Food and Drug Administration (FDA) on March 10, 2023. The agency resolved that there has been enough time for facilities to obtain a Data Universal Numbering System (DUNS) number since October 2020. “The…

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UPDATED: Phase VII of Lacey Act Enforcement

UPDATED: Phase VII of Lacey Act Enforcement

UPDATE: 12/15/2023—Recently the APHIS team announced that while they hoped to issue a list of the tariff schedule codes that will require Lacey Act declarations under phase VII, they are now planning to release this notice in early 2024. Erin Otto, part of the APHIS team mentioned the items covered in phase VII are wicker…

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New Reporting for Imports of Aluminum Products

New Reporting for Imports of Aluminum Products

New Aluminum Smelt and Cast import declaration reporting are scheduled to go into effect on May 10, 2023. Proclamation 10522 issued by the President states that any imports of aluminum or aluminum derivative articles from Russia—effective March 10, 2023—or where any amount of primary aluminum used in the manufacture of the aluminum articles is smelted…

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Tri‐Seal Compliance Note

Tri‐Seal Compliance Note

In the Tri-Seal Compliance Note U.S. enforcement agencies stress the aim to squash third‐party intermediaries used to evade Russia‐related sanctions and export controls. This is said to be one of the most common tactics Russia is using to help “disguise their involvement” the agencies said. The note—from the Bureau of Industry and Security (BIS), Treasury’s…

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