JAS USA COMPLIANCE

News & Insights from JAS Worldwide Compliance

JAS Forwarding (USA), Inc.

6165 Barfield Road
Atlanta GA, 30328
United States
Tel: +1 (770)688-1206
Fax: +1 (770)688-1229

COMPLIANCE SOLUTIONS

JAS USA Compliance Insights

Announcements

JAS USA Compliance Insights on the Impact of COVID-19

DERIVATIVE LIST

On February 11, 2025, the President issued a proclamation regarding the importation of steel and aluminum articles, increasing tariff rates to 25% from all countries. As part of that proclamation, it was announced that there would be expanded 25% tariffs to include key downstream products (derivatives) for both steel and aluminum. The Annex containing those products has been drafted and is expected to be officially published in the Federal Register on February 18, 2025.

Key Points:

• There are 167 new codes for steel downstream products (derivatives) subject to the 25% tariff referenced in this proclamation (covering 4 different chapters of the HTSUS).

• There are 123 new codes for aluminum downstream products (derivatives) subject to the 25% tariff referenced in this proclamation (covering 11 different chapters of the HTSUS).

To read the draft Federal Register, and access our Excel listing of HTS affected, click the links below:

Federal Register Draft Steel DerivativesFederal Register Draft Aluminum DerivativesDerivatives Excel Sheet
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In the spotlight Jacquelyn

For February, we are highlighting Jacquelyn Bakker, our CHB Manager in the JAS Chicago office.  Jacqulyn started her career in the industry in 2012 in an accounting role before moving into the brokerage side in 2014.  In her words, that’s when she “found my niche.”  Jacquelyn joined JAS in 2018.  After being named as the Brokerage Supervisor, Jacquelyn decided to take on the “daunting task” of obtaining her broker’s license.  After 3 months of studying, Jacquelyn was able to pass on the first try!  Jacquelyn manages a team of 6 entry writers in our Chicago branch and CHB manager.  Jacquelyn is detail oriented and attentive to the needs of her clients internally and externally!

Jacquelyn has a 19-year old daughter, loving fiance and 2 dogs at home.  She enjoys family time BBQing in the summer, taking the dogs for longs walks, playing Pokemon Go with family and seeing movies in the theater.

Jacquelyn is yet another great example that People Make the Difference!

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Forced Labor feb 2025

CBP is leading global efforts in combating forced labor by imposing import bans on goods produced with forced labor.  This has inspired international action, including the European Union’s adoption of similar measures and the inclusion of forced labor prohibitions in the USMCA.  CBP’s actions have also driven labor reforms, notably in Malaysia, which launched a National Action Plan on Forced Labor and ratified an international protocol to combat forced labor.  These advancements demonstrate CBP’s significant influence in shaping global supply chain accountability and driving positive change.

Read more about it by checking out the link below:

Breaking Unseen Chains- U.S. Customs and Border Protection
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nprm

CBP announced on January 16, 2025 an NPRM (Notice of Proposed Rulemaking) related to “illicit low-value shipments.”  Section 321 (a)(2) of the Tariff Act of 1930 allows for duty and tax exemptions on low-value shipments entering the U.S., such as gifts, personal goods, and other merchandise valued at $800 or less.  The exemption, first introduced in 1938, aimed to reduce the burden of collecting duties on minimal-value imports.  However, the surge in e-commerce and the increase in low-value shipments has made it difficult for CBP to effectively manage and target high-risk shipments, such as illicit drugs.  To address this, CBP is proposing enhanced data requirements for low-value shipments to improve enforcement and targeting.

Read more by checking out the link below:

Federal Register Notice-NPRM
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Drawback

Are you leaving money on the table?  If your company imports goods that are later exported, you could be eligible for significant refunds on customs duties, taxes and fees through the Duty Drawback Program.

 

Join our free webinar to learn how to navigate the complexities of duty drawback and maximize your savings opportunities!

 

The webinar will be on March 6, 2025 at 2pm Eastern.  To register, click the link below.

Click Here to RegisterWebinar Flyer
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Tariffs CA,MX,CN

On February 1, 2025, under the International Emergency Economic Powers Act (IEEPA), the administration is implementing 10% additional tariff on imports from China.  

 

Originally, Canada and Mexico were to have 25% tariffs imposed, however after late meetings between the President of Mexico and the Canadian Prime Minister, news outlets are reporting there will be a 30 day pause on these potential tariffs.

 

More details include that goods admitted to FTZs must be admitted under privileged foreign status, no duty drawback will be allowed, and there will be no section 321, or de minimis shipments allowed for products of China.

 

Additional details will be shared as soon as available.  As this is a fast-changing situation, all details are subject to change.

Check out our Client Advisory:

CLIENT ADVISORY FEBRUARY 3, 2025
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Spotlight Jan 2025

For January, we are highlighting Ivel Martinez, our Air & Ocean Manager/FTZ Administrator in the JAS Miami office. Ivel joined JAS in November 2021 and has been instrumental in helping manage the MIA Foreign Trade Zone operations. She is very meticulous in keeping records and validating inventory control.

Ivel's parents owned one of the first CFS warehouses in Miami. Ivel has been in the industry for many years and remembers typing 7512's on a huge brown typewriter.

Ivel has been happily married for 28 years and her family is extremely important to her. She has 2 sons, and 3 puppies. Ivel loves getting together with family and enjoying good food.

Ivel is yet another great example that People Make the Difference!

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AES HTS update

Census has published the Harmonized Tariff Codes that are not valid for AES filing for 2025. The US Census department issues a list of HTS codes each year that are not valid for use when filing an AES. Those numbers for January 1, 2025 are listed in the link below.

HTS Codes Not Valid for AES Filing
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301 update

New Section 301 China Tariffs went into effect on January 1, 2025 for five subheadings. These increases are the result of the Four Year Review and will affect imports from China of certain tungsten products, wafers and polysilicon.

The rates on tungsten products will increase to 25 percent, while the rates for wafers and polysilicon will increase to 50 percent. Affected subheadings are 2804.61.00, 3818.00.00, 8101.94.00, 8101.99.10, and 8101.99.80.

Click below to check out more details.

Federal Register Notice
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Continuing Ed

If you are a Licensed Customs Broker, you should have received an email from CBP continuing education group with the subject line "Continuing Education for Customs Brokers Requirement Information," around November 22, 2024. CBP received around 200 rejected email messages and are trying to contact these recipients. If you are a current LCB and did not receive the email and you have checked your spam folder, you should follow the link below for more information.

Read more by clicking below.

Continuing Education InformationCBP Email Copy
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MEX Update

The President of Mexico has announced a tariff increase on textiles and apparel. Tariffs will increase from 20-25% up to 35% on various apparel and made-up articles.

Click below to get the full story!

Mexico Announcement
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Fake Guitars

CBP officers in LA/Long Beach worked with other agencies and were able to seize over 3,000 counterfeit Gibson guitars. Had these guitars been genuine Gibson guitars, they would have been valued at over $18 million.

To read the full details, click below.

CBP Media Release
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December Spotlight

For December, we are highlighting Jeffrey Bispham on the West Coast!  Jeff has been in the industry for 26 years and remembers using a typewriter to prepare 7512's.  He has always worked in the import/customs brokerage side of logistics.  Jeff was adopted as part of the JAS Family when JAS acquired Tigers back in 2021 where Jeff had long tenure.

In October 2023, the JAS Forwarding (USA) Tacoma Foreign Trade Zone became an active FTZ in the JAS USA Network.  Jeff became the FTZ administrator of that site and has been instrumental in building the compliance for our FTZ site on the West Coast.

Jeff enjoys all sports, although he would tell all that he has become more of a spectator than a player as the years have passed.  Jeff enjoys being outdoors.  But most of all, he enjoys spending time with his family.  That time can often occur at the beach, or a Seattle sporting event (Mariners, Seahawks and Kraken).

Jeff is yet another great example that People Make the Difference!

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Import Training

In November, JAS USA Corporate Compliance team members teamed up with JAS Atlanta Branch team members to facilitate client compliance training. From left to right, Calvin Oh (Corporate Compliance), Scott Cassell (Corporate Compliance), Carlo Rebuffi (Manager of Live Animals Division-ATL), Laurie Arnold (VP Corporate Compliance), and Rishma Patel (CHB Manager-ATL). The team was able to facilitate learning on the topic of import compliance.

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OFAC Penalty

OFAC (Office of Foreign Assets Control), part of the Department of Treasury, has imposed a $1.1 Million penalty on a US individual. The panlty was issued for 75 violations of OFAC Iran sanctions.

To read the full details check out the link below:

OFAC Enforcement Release
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BIS Guidance

BIS has published its newest edition of "Don't Let This Happen to You!" The newest version includes new enforcement cases. New topics include the first Disruptive Technology Strike Force case, criminal cases, an assassination plot and much more.

Check out the full document at the link below:

Read the Full Document
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DHS Updates to UFLPA
December 3, 2024
UFLPA additions

The Department of Homeland Security (DHS) has added 29 new entities to the UFLPA Entity list. There are now more than 100 PRC-Based companies on the list. The companies on the list face significant challenge to enter goods into the United States because of alleged forced labor practices.

To read more details, check out the link to the Federal Register.

Federal Register Notice
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25% Tariffs

The President-elect has indicated that tariffs are coming to Canadian and Mexican goods in January. In a recent post on Truth Social, he has indicated that an executive order on January 20 will impose 25% on goods from Canada and Mexico with an additional 10% on goods from China. This action is to combat illegal immigration and illicit drugs.

Read More
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Tracey Suggs

This November, we are honored to feature Tracey Suggs, Import Specialist at JAS Forwarding USA Inc., for his tireless advocacy for individuals with Down Syndrome. While October marks Down Syndrome Awareness Month, Tracey and his family advocate every day for the empowerment and inclusion of individuals who face intellectual and developmental challenges. Inspired by his daughter, Treana, who has Down Syndrome, Tracey is driven to ensure that every individual can live their fullest life. Treana's zest for life and inspiring spirit is a testament to the impact of love, perseverance, and understanding that Tracey strives to bring to his work and community. Tracey’s unwavering commitment to making a difference embodies our values at JAS, reminding us all of the importance of inclusivity and advocacy in both our professional and personal lives.

Tracey has been with JAS for 3 years and has been in the industry for over 20 years. Tracey has a passion for sports, fitness, art, community advocacy (special needs/disadvantaged youth), and spending time with family.

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ICPA

JAS Forwarding VP Compliance, Laurie Arnold joined forces with JAS Forwarding Global Development Director Jennifer Koon, and Regional Sales Director Lindsay Gambee to attend the International Compliance Professionals Association (ICPA) Fall Conference (Western Cowboy Theme) in Grapevine, Texas from October 20-23.  

They were able to meet with numerous members of the trade community and discuss current events and network.

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BIS Penalty for $500,000
November 5, 2024
BIS Penalty

On November 1, 2024, BIS imposed a civil penalty of $500,000 against a semiconductor wafer manufacturing company. The U.S. subsidiary shipped approximately $17.1 million of semiconductor wafers company listed on the BIS Entity List, without the required licese/authorization.

The company voluntarily disclosed the conduct and cooperated which resulted in significant reduction in the penalty.

To read more, check out the final order below.

BIS Final Order 11-1-2024
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Exclusion Requests

The U.S. Trade Representative has announced the opening of a process to request Section 301 exclusions. The requests will be limited to certain machinery within chapters 84 and 85 of the HTSUS.

The docket opened on October 15, 2025, and the deadline for submitting requests is March 31, 2025.

To read more details, check out the link below to the press release.

Section 301 Exclusion Process
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Aluminum Extrusion

On October 30, 2024, the U.S. International Trade Commission (USITC) determined "...that a U.S. Industry is not materially injured or threatened with material injury by reason of imports of aluminum extrusions from China, Columbia, Ecuador, India, Indonesia, Itay, Malaysia, Mexico, South Korea, Taiwan, Thailand, Turkey, United Arab Emirates, and Vietnam that the U.S. Department of Commerce (Commerce) has determined are sold in the United States at less than fair value, and subsidized by the Governments of China, Indonesia, Mexico, and Turkey."

The overall result is that "...Commerce will not issue antidumping duty orders on imports of this product from..." the countries listed.

It is important to note that older AD/CVD orders on aluminum extrusions remain in effect (2011).

To read the full press release, click the button below.

USITC Press Release Aluminum Extrusions
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Learning

U.S. Customs has posted in the Federal Register the long-awaited information on the continuing education requirement credit hours for the current triennial period. The notice published in the Federal Register on November 1, 2024, CBP has announced that "...customs brokers license holders may begin completing qualified continuing broker education courses on January 1, 2025 (compliance date) and, accordingly, 20 credits as the prorated number of required credit hours for the triennial period beginning on February 1, 2024, and ending on January 31, 2027."

Additionally, the notice "...announces the criteria that U.S. Customs and Border Protection (CBP) used to select qualified accreditors, the list of CBP-selected qualified accreditors, and the period of award for these accreditors."

Full Federal Register Notice
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Decorative

September was a busy month for JAS Forwarding (USA) Inc. Compliance team members.

Laurie Arnold and Leah Ellis attended the NCBFAA (National Customs Brokers and Forwarders Association of America) GAC (Government Affairs Conference). During the conference, Laurie and Leah "walked the hill" and met with numerous congress members to discuss industry issues.

Scott Cassell spent time with clients in Newark, NJ along with J. Nathan May, Regional Sales Director to facilitate training on the HTS GRI (Harmonized Tariff Schedule General Rules of Interpretation) and Incoterms 2020.

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Decorative

September was a busy month for JAS Forwarding (USA) Inc. Compliance team members.

Laurie Arnold and Leah Ellis attended the NCBFAA (National Customs Brokers and Forwarders Association of America) GAC (Government Affairs Conference). During the conference, Laurie and Leah "walked the hill" and met with numerous congress members to discuss industry issues.

Scott Cassell spent time with clients in Newark, NJ along with J. Nathan May, Regional Sales Director to facilitate training on the HTS GRI (Harmonized Tariff Schedule General Rules of Interpretation) and Incoterms 2020.

Decorative

Our October spotlight of the month is Rishma Patel from our Atlanta branch, where Rishma has been with JAS since 1997. Rishma has been in the industry for 32 years. She is the CHB Manager and Licensed Customs Broker responsible for the JAS Atlanta/College Park location.

Rishma's favorite sports are cricket, volleyball, tennis and badminton. In her spare time, she enjoys painting, drawing and food carving.

Rishma's dedication is yet another example that People Make the Difference!

Decorative

The USTR (US Trade Representative) announced that they are proposing to increase Section 301 tariff rates on five subheadings of the HTSUS covering certain products of tungsten, wafers, and polysilicon.

The public docket was opened to allow for comments. All comments should be submitted by October 22, 2024.

To read more, check out the link below:

Decorative

Consumer Product Safety Commission (CPSC) is working to modernize the options for filing certificate data. "CPSC is actively developing the eFiling program and finalizing rulemaking." This creates a new opportunity to streamline the filing of General Certificates of Conformity (GCC).

Read more by checking out the link below:

Decorative

A new Federal Register notice has been issued on September 26, 2024, proposing a ban on Chinese and/or Russian "Vehicle Connectivity Systems (VCS)." According to the notice, BIS/Commerce "...is soliciting comment on this proposed rule, which builds on the advance notice proposed rulemaking (ANPRM) issued by BIS on March 1, 2024." Comments to the proposed rule must be received on or before October 28, 2024.

To read more details check out the Federal Register Notice

Joe-September 2024

Our September spotlight of the month is Mr. Joseph Schmidt from our New York branch, where he has been with JAS since 1998. Joe has been in the business for 46 years and has been a Licensed Customs Broker since 1983. He is the Broker Manager and Licensed Customs Broker responsible for the JAS New York location.

Joe loves sports, and is a huge fan of the NY Mets, Giants and Knicks. He also loves Elvis Presley. His ringtone on his phone is the song "Follow That Dream" from the 1962 Elvis movie of the same name.

His long tenure shows not only his dedication to JAS, but also shows JAS' commitment to retain dedicated professionals because People Make the Difference!

JAS Compliance

The JAS Forwarding (USA) Inc. Corporate Compliance Team met in August at our Corporate Headquarters.

The JAS Corporate Compliance Team gets together regularly to discuss current trade compliance topics such as AD/CVD (recent aluminum case), and section 301 matters.  Additionally, the Compliance Team is always strategizing on how to better serve our client's compliance needs.

The team was able to have an evening of team building throwing axes!

MOCRA

The Modernization of Cosmetics Regulation Act (MoCRA) has recently gone into effect. The MoCRA is the most significant expansion of FDA's authority to regulate cosmetics since the Federal Food, Drug and Cosmetic (FD&C) Act was passed in 1938.

Manufacturers and processors must register their facilities with FDA and renew every two years. Examples of items subject to MoCRA include but are not limited to baby products, bath preparations, various makeups, hair products, and even oral products such as mouthwash.

There are free tools available to determine whether FDA's new MoCRA regulations apply. Check out the link below to utilize this free tool!

Importer Penalized

An importer of uniforms and footwear has been penalized $1.3 Million for a fraudulent scheme involving fake invoices that deliberately and materially understated the value of their imports. These goods were being imported from China, Pakistan and Bangladesh. The defendants, including the CEO were also accused of providing invoices misrepresenting the fabric content which resulted in reduced duty amounts.

To read more details, check out the full US District court order.

Indira in the Spotlight

Indira Coomar from our JAS Forwarding (USA) Inc. Norfolk branch has been with JAS for 14 years in September.  She likes to run each morning.  During her runs, she takes some very beautiful photos of the sunrise over the beach and shares them with an inspirational quote to start many days. One of her recent quotes was “the secret to getting ahead is getting started!”  We appreciate Indira’s motivation, and this attitude perfectly reflects that People Make the Difference.

JAS on the Move

July 2024, JAS Forwarding (USA) Inc.’s Laurie Arnold (VP Compliance) and Scott Cassell (Corporate Compliance Project Manager) facilitated a client seminar covering Foreign Trade Zone, Forced Labor and Duty Drawback.  The event was hosted by our JAS Forwarding (USA)Inc. Charlotte Branch!

CBP Snap Shot

CBP publishes monthly trade statistics that provide a snapshot of the volume of shipments being processed.  In May2024, CBP processed more than 2.9 million entry summaries.  This includes numerous modes of transport from all over the world.  

CBP’s monthly trade stats show duties paid, seizures, WRO data and much more.

To read the full article, check out the link below.

MPF Increase

CBP has announced an increase of the Merchandise Processing Fee (MPF) within the Consolidated Omnibus Budget Reconciliation Act (COBRA). The fee increase will be effective on October 1, 2024.

The new minimum will increase from $31.67 to $32.71. The new maximum will increase from $614.35 to 634.62. The ad valorem rate of 0.3464% remains unchanged.

For more details check out the link below.

Additional 301 Tariffs Delayed

The USTR (US Trade Representative) has indicated that the increase originally expected on the 301 tariffs on August 1, 2024 will not go into effect as expected.  

The USTR has received 1100 comments from the public and continues to review those comments.  Modifications for 2024will likely take effect approximately two weeks after the final determination is made public.

Check out our client advisory and the links to the USTR and Federal Register Notice dated May 28, 2024.

 

To read more, check out the full register notice linked below.

Forced Labor Focus

The recent June 12, 2024, Federal Register notice added three entities to the UFLPA Entity List showing increasing focus on three additional commodities. The entities which were added are suspected of working with the Xinjiang Uyghur Autonomous Region to recruit, transport, transfer, harbor or receive forced labor or Uyghurs, Kazakhs, Kyrgyz, or members of other persecuted groups out of the Xinjiang Uyghur Autonomous Region.

The areas of increased focus include shoe and shoe materials, frozen seafood, vegetables, quick frozen convenience food and other aquatic food, and electrolytic aluminum, graphite carbon, and prebaked anodes.

To read more, check out the full register notice linked below.

Fines with disclosure

On June 24, 2024, the Assistant Secretary of Commerce, Matthew S. Axelrod signed a settlement agreement with an exporter for violations of EAR. The violations occurred because of forty-two different shipments over the course of 4 years which were classified under ECCNs 1C353. These instances were subject to export licenses, but no licenses were obtained prior to exportation.

The exporter has a compliance team and upon recognition of the issue, submitted a voluntary self-disclosure. To read more details, check out the link below.

BIS imposed a civil penalty of $44,750 for violations of the antiboycott provisions of the Export Administration Regulations (EAR)

On June 3, 2024, the BIS imposed a civil penalty of $44,750 for violations of the antiboycott provisions of the Export Administration Regulations (EAR).  In the press release, Assistant Secretary for Export Enforcement, Matthew S. Axelrod said “Our antiboycott rules against furnishing prohibited information and failing to report boycott-related requests apply with the same force even when another U.S. company is the one making the information requests.”  He goes on to say “U.S. companies are reminded to be vigilant in examining all transaction documents, regardless of the source, to ensure terms and conditions comply with our antiboycott rules.”

JAS Forwarding (USA) Inc. Compliance team members (pictured right to left) Laurie Arnold (NCBFAA Secretary) and Leah Ellis (NCBFAA Legislative Committee Chair)

JAS Forwarding (USA) Inc. Compliance team members Laurie Arnold (NCBFAA Secretary) and Leah Ellis (NCBFAA Legislative Committee Chair) attended the quarterly NCBFAA board meetings in DC discussing Ecommerce, PGA’s, transportation, and customs issues.

4th of July Fireworks

One of the most exciting things to do for the 4th of July holiday is to see fireworks with family and friends! Did you know that 88% of fireworks in the United States are imported? It is considered a very specialized product with lots of regulations. CBP seizes tons of firework shipments annually that never make it past the US port of entry. So before getting into the business of importing fireworks consulting with a customs broker like JAS is important! Happy Independence Day!!

The last 30 days have brought many updates to Section 301 duties, exclusions and more

The last 30 days have brought many updates to Section 301 duties, exclusions and more.  The action all started on May 14, 2024, when the USTR announced that further action would be taken against China’s unfair technology transfer policies and practices.  It was announced that key products would be subject to new rates over the next two years.  

May 22, 2024, there was a follow up to the May 14 announcement which further defined that 382 HTSUS subheadings and 5 statistical reporting numbers of the HTSUS are the specific products that will have the increases in 2024, 2025 and 2026.  This notice also noted that an exclusion process is being established for machinery used in domestic manufacturing and under certain subheadings under chapters 84 and 85 of the HTSUS.  Finally, this notice proposes 19 temporary exclusions for solar manufacturing equipment.

Finally, on May 24, 2024, the USTR published details about the disposition of the existing Section 301 exclusions 9903.88.67 and 9903.88.68 which have been scheduled to expire on May 31, 2024.  In summary, all exclusions under 9903.88.67 and 9903.88.68 have been extended to July 14, 2024.  On July 15, 2024, a new exclusion will be effective.  The new exclusion, under 9903.88.69 will cover 87 of the original 352 exclusions under 9903.88.67.  

For more details, check out our 3 Client advisories released during May linked below.

CBP publishes numerous Informed Compliance Publications

CBP publishes numerous Informed Compliance Publications. These documents can be extremely useful in answering detailed questions about the application of CBP rules/laws on a wide range of topics. Some of the topics covered include Valuation, classification of sets, classification of specific product types, drawback, reasonable care, recordkeeping, rules of origin and the list goes on. These documents are publicly available and can be viewed online or downloaded. To check them out, follow the link below!

U.S. Commerce Department’s Bureau of Industry and Security (BIS)

The U.S. Commerce Department’s Bureau of Industry and Security (BIS) has updated the process for excluding certain steel and aluminum imports from tariffs, effective July 1, 2024. This revision removes twelve General Approved Exclusions (GAEs), aiming to strengthen domestic steel and aluminum production and reduce reliance on foreign manufacturing.  The changes follow public feedback and are intended to ensure fairness and transparency in the exclusions process while upholding national security interests.  BIS has been overseeing this process since tariffs were imposed in 2018, and these adjustments reflect ongoing efforts to refine controls and support U.S. industrial base.

FDA issued guidance for Industry regarding the registration and listing of Cosmetic Product Facilities and Products

In December, 2023, FDA issued guidance for Industry regarding the registration and listing of Cosmetic Product Facilities and Products.  The publication lists product categories and provides a Q&A section with answers to specific cosmetic product questions.  The deadline is July 1, 2024.  For more info and links, check out our most recent client advisory linked below:

Insect Repellent is regulated by EPA and FDA

Insect Repellent is regulated by EPA and FDA for importations and classified in chapter 3808 of the HTS book.  It can be imported as a cream, spray and other methods such as bracelets.  Some repellents can be applied directly to the skin and other methods can be applied directly to the clothing.  

Here are a few ways to reduce your exposure to mosquitoes this summer:

  • Eliminate standing water in containers that could breed mosquitoes.
  • Wear long sleeve clothes and socks to avoid exposing the skin.
  • Replace outdoor lights with yellow bug lights which tend to attract fewer mosquitoes.
  • Follow necessary instructions and labels closely on insect repellents.

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