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New Forced Labor Presumption Creates New Challenges for Global Supply Chains

The Uyghur Forced Labor Prevention Act ("UFLPA" or the "Act") imposes new obligations on companies producing or sourcing goods from the Xinjiang Uyghur Autonomous Region of the People's Republic of China ("Xinjiang"). The key...more

CBP Announces Known Importer Letters Related to Uyghur Forced Labor Prevention Act

On December 23, 2021, President Biden signed the Uyghur Forced Labor Prevention Act ("UFLPA" or the "Act") into law. The Act creates a rebuttable presumption that "any goods, wares, articles, and merchandise mined, produced,...more

Court of International Trade Remands Section 301 Tariffs to U.S. Trade Representative

Court orders agency to provide better explanation for List 3 and List 4A by June 30, 2022. On April 1, 2022, a three-judge panel of the U.S. Court of International Trade issued an opinion in a test case for more than...more

2022 & Beyond: Continued Challenges in the Automotive Supply Chain

While our inboxes are flooded on a daily basis with news about how the pandemic has created supply chain and commodities issues, global organizations must think about more than just near-term issues. Although the pandemic...more

USTR Accepting Comments on Reinstating Certain Exclusions to Section 301 Tariffs

The Office of the United States Trade Representative ("USTR") is seeking comments on the possible reinstatement of Section 301 tariff exclusions on 549 Chinese-origin products. The Office of the United States Trade...more

Recent Executive Actions Represent Latest Evolution of U.S.-China Relations

President Biden's Executive Orders on China underscore the need for experienced counsel in U.S.-China transactions as the two countries' relations continue to impact the regulatory landscape. On June 9, 2021, President Biden...more

Biden Administration Announces New Trade Restrictions Affecting Solar and Electronics Industries

These targeted restrictions present a pressing need for U.S. solar and electronics companies to evaluate their supply chain for critical inputs and monitor subsequent U.S. Customs Border Patrol ("CBP") forced labor...more

U.S. Treasury Sanctions Senior Hong Kong Officials Under Authority of Executive Order on Hong Kong Normalization

The Situation: On August 7, 2020, the U.S. Department of the Treasury ("Treasury Department") took the first action under the authority of "The President's Executive Order on Hong Kong Normalization" ("HK Normalization EO")...more

The Hong Kong Autonomy Act Signed Into Law

The Situation: On July 14, 2020, President Trump signed into law the Hong Kong Autonomy Act (the "HKAA"), the U.S. government's response to China's new National Security Law for Hong Kong. The Result: The HKAA could...more

USTR Unveils Process to Exclude Select Products from China Tariffs

Interested parties may apply until June 25, 2020, regardless of whether the product is already subject to a separate exclusion request that is pending or has previously been denied. As part of the U.S. government's ongoing...more

U.S. Imposes Tariffs on Derivative Steel and Aluminum Imports

The Situation: The Trump administration announced new tariffs on imports of certain derivative, or "downstream," steel and aluminum articles with exemptions for certain countries. These tariffs are in addition to the existing...more

U.S. Proposes Up to 100% Additional Duties Due to French Digital Tax

The Situation: The Office of the United States Trade Representative ("USTR") determined that France's digital services tax ("DST") unreasonably burdens or restricts U.S. commerce, particularly U.S. technology...more

U.S.-China Trade Uncertainty: Section 301 Tariff State of Play

The Situation: Recent reports indicate that the United States and China may soon reach an initial, limited trade deal that could involve the United States phasing out some existing tariffs on Chinese-origin goods while...more

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