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

Import Ban Lifted on Gloves
October 1, 2021

Earlier this year, in late March, CBP issued a finding that certain disposable gloves, were mined, produced, or manufactured in Malaysia by Top Glove Corporation Bhd with the use of convict, forced, or indentured labor, and were being, or were likely to be, imported into the United States.  Pursuant to 19 U.S.C. 1307 and CFR 12.42 (g), it is hereby determined that the articles described below are no longer being mined, produced, or manufactured wholly or in part with the use of convict, forced, or indentured labor by Top Glove in Malaysia.  

The change is the result of the cooperation of Top Glove Corporate to address issues initially cited.

Read more about this, see the Federal Register Notice published September 10, 2021
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Continuing Education Update
October 1, 2021

The Federal Register dated September 10, 2021, proposed to amend the U.S. Customs and Border Protection (CBP) regulations to require continuing education for individual customs broker license holders (individual brokers) and to create a framework for administering this requirement. By requiring individual brokers to remain knowledgeable about recent developments in customs and related laws as well as international trade and supply chains, CBP's proposed framework would enhance professionalism and competency within the customs broker community. CBP has determined that the proposed framework would contribute to increase trade compliance and better protection of the revenue of the United States.

Comments on this change are being accepted on or before November 9, 2021.

Read more about this proposed change, see the Federal Register Notice published September 20, 2021
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Manhattan U.S. Attorney Announces Criminal and Civil Charges Against CEO of Apparel Company for Customs Fraud
October 1, 2021

The Manhattan U.S. attorney has announced criminal and civil charges against the CEO of an apparel company.  It is alleged that the CEO has engaged in Customs Fraud.  The CEO is suspected of misrepresenting value of imported goods in an attempt to avoid paying lawfully owed customs duties.

Read more details from the U.S. Attorney's Notice
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Modification to Antidumping Duty and Countervailing Duty Regulations
October 1, 2021

On September 20, 2021, the Department of Commerce (Commerce) published new regulations and modifications to existing regulations related to its administration and enforcement of the antidumping duty (AD) and countervailing duty (CV) laws. These regulations apply to various aspects of AD/CVD proceedings, including the deadlines for industry comments pertaining to AD/CVD petitions, new shipper reviews, scope inquiries and rulings, circumvention inquiries and determinations, covered merchandise referrals from U.S. Customs and Border Protection (CBP), certification requirements to establish whether merchandise is subject to an AD/CVD order, and importer reimbursement certifications filed with CBP.

To read more, check out the CSMS message 49456863
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User Fee Changes Effective October 1, 2021
September 1, 2021

Pursuant to the General Notice (86 FR 40864) published July 29, 2021, various changes to user fees within the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) will take effect on October 1, 2021.  Merchandise Processing Fees are increasing, and other fees will reflect changes as well.

Read the Client Advisory
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New Requirements for Importing US and Foreign Goods Returned
September 1, 2021

There are new requirements for importing US and Foreign Goods Returned under HTSUS Chapter 98 (9801.00.10). Previous changes and history are found in the CSMS message linked below and summarized here. On April 25, 2016, a change to HTSUS Chapter 98 for U.S. goods returned went into effect. Specifically, section 904(b) of the Trade Facilitation and Trade Enforcement Act of 2015 (TFTEA), “Modification of Provisions Relating to Returned Property,” amended HTSUS Subheading 9801.00.10.

The expansion of Subheading 9801.00.10 includes all products exported from and returned to the United States, regardless of country of origin. For U.S. origin products, there is no time limit on filing a claim. For foreign origin products, there is a 3-year time limit. The changes to 9801.00.10 apply to U.S. or foreign articles returned to the United States and entered, or withdrawn from warehouse, for consumption on or after April 25, 2016.

Read More Here
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Five-Year Suspension of UK/EU Duties in Section 301 Action
August 31, 2021

On June 15 and June 17, 2021, the United States reached understandings on cooperative frameworks with, respectively, the European Union (EU) and the United Kingdom (UK) regarding the World Trade Organization (WTO) disputes involving large civil aircraft (LCA).

Read the Federal Register
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Compliance Meeting Held at JAS Atlanta HQ
August 31, 2021
From left to right, front row- Mary Arno, Corporate Compliance Specialist; Margaret Christian, Corporate Compliance Specialist; Laurie Arnold, Vice President of Compliance; Leah Ellis, Compliance Operations Manager; Sommer Sampson, TSA Security Program Manager; back row- Jacob Foster, Corporate Compliance Specialist; Casey Hughes, Corporate Compliance Specialist; Scott Cassell, Compliance Project Manager

From August 25 through August 27, 2021, the JAS Forwarding USA Inc. Corporate Compliance team met at the Atlanta Corporate headquarters.  The team was able to discuss various industry current events and develop a strategic plan for the coming months.  The group was excited to get together and reconnect!

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Xinjiang Supply Chain Business Advisory
August 2, 2021

The U.S. Department of State, the U.S. Department of Commerce, and other government agencies has issued an updated Xinjiang Supply Chain Business Advisory to highlight the heightened risks for businesses.  The advisory warns U.S companies that do business with and have investment links to Xinjiang may be at risk of violating the U.S. law. Due to the entities complicit in forced labor and other human rights abuses there and throughout China. Given the severity and extent of these abuses, businesses and individuals that do not exit supply chains, ventures, and/or investments connected to Xinjiang could run a high risk.

Read the updated advisory highlights
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New LACEY Act Requirements Effective October 1, 2021
August 2, 2021

Beginning October 1, 2021, the Animal and Plant Health Inspection Service (APHIS) will start enforcing Lacey Act import declaration requirements on 27 new tariff lines. This marks the sixth phase of Lacey Act declaration enforcement, which was delayed from October 2020 due to the COVID-19 pandemic.

Some of the new products include essential oils; trunks, cases and suitcases; oriented strand board and wooden containers and pallets; musical instruments; and monopods, bipods, tripods, and more.

See the full list of HTS codes impacted
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Preliminary Injunction in Section 301 Lawsuit
August 2, 2021

The Court of International Trade has granted a preliminary injunction which stopped the liquidation of unliquidated entries subject to litigation over List 3 and List 4A Section 301 China tariff litigation. The suspension of liquidation only applies to importers who are plaintiffs in the action.

Read the granted preliminary injunction
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New Chinese Law Could Impact U.S. Efforts on Forced Labor
August 2, 2021

China has implemented a new law imposing consequences on individuals and organizations that directly or indirectly participate in implementing foreign sanctions against Chinese citizens or organizations. This law could impact the ability of Chinese vendors to comply with U.S. requests to avoid entities named on U.S. Customs and Border Protection’s withhold release orders related to forced labor.

Read the details of the new law
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EU and US Take Decisive Steps to End Aircraft Dispute
July 2, 2021

European Commission Executive Vice-President Valdis Dombrovskis and US Trade Representative Katherine Tai reached an understanding relating to large civil aircraft, transforming almost 17 years of disputes into a forward-looking, collaborative platform to address bilateral issues as well as global challenges.

Both sides will now seek to overcome long-standing differences to avoid future litigation and preserve a level playing field between our aircraft manufacturers and will also work to prevent new differences from arising.

Read the full article
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Forced Labor on Silica-Based Products
July 2, 2021

According to a release order published by the White House, CBP announced that they will be detaining silica-based products made by Hoshine Silicon Industry Co., Ltd. and its subsidiaries.  CBP indicated that there is an indication that the company used forced labor in manufacturing these products. The polysilicon produced in the Xinjiang region of China is a core material in solar panels made in Asia.

Read the White House publication
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Are You Sure Your Product is Classified as EAR99?
July 2, 2021

The Bureau of Industry and Security imposed a $350,000 civil penalty against a U.S. company for violating the Export Administration Regulations. $300,000 of the penalty will be suspended for two years and then waived if the company does not commit any further violations in this time frame.  In a statement from BIS, the company exported laser systems which are controlled as national security and anti-terrorism; however, the company erroneously listed the ECCN # as EAR99 in the electronic export information filing (EEI).  The company also directed the freight forwarder to file the electronic export information as the ultimate destination of Hong Kong even though the goods were destined for China.

Read the settlement report
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Department of Commerce Recognizes the United Arab Emirates Termination of Participation in the Arab League Boycott of Israel
July 2, 2021

The Bureau of Industry and Security (BIS) at the Department of Commerce has amended its antiboycott provisions set forth in the Export Administration Regulations (EAR) to reflect the August 16, 2020 issuance by the United Arab Emirates (UAE) of Federal Decree-Law No. 4 of 2020, which formally ended the UAE’s participation in the Arab League Boycott of Israel. BIS’s action follows similar actions by the Departments of State and the Treasury.

Read the full article
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President Biden Nominates CBP Commissioner
May 6, 2021

President Biden announced on April 12th his intent to nominate Chris Magnus, who has served as police chief of Tucson, Ariz., since January 2016, as commissioner of U.S. Customs and Border Protection.

According to a White House press release, Magnus rose through the ranks of the Lansing, Mich., police department and has also served as police chief in the cities of Fargo, N.D., and Richmond, Calif. “In each of these cities,” the press release said, “Magnus developed a reputation as a progressive police leader who focused on relationship-building between the police and community, implementing evidence-based best practices, promoting reform, and insisting on police accountability.” The White House also cited Magnus’ “extensive experience in addressing immigration issues” during his time in Tucson near the U.S.-Mexico border.

Read the White House press release
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Withhold Release Orders & Findings of Forced Labor
May 6, 2021

Enforcement of the prohibition of importation of goods mined, produced, or manufactured by forced labor is on the rise. CBP has published a webpage that contains withhold release orders issued by the Commissioner and findings published in the Federal Register. CBP does not generally publicize specific detentions, re-exportations, exclusions, or seizures of the subject merchandise that may have resulted from the withhold release orders or findings.

Click here to see the list of withhold release orders published
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USTR Announces Next Steps of Section 301 Digital Services Taxes Investigations
May 6, 2021

The United States Trade Representative (USTR) announced the next steps in its Section 301 investigations of Digital Service Taxes (DSTs) adopted or under consideration by ten U.S. trading partners.   In January, USTR found that the DSTs adopted by Austria, India, Italy, Spain, Turkey, and the United Kingdom were subject to action under Section 301 because they discriminated against U.S. digital companies, were inconsistent with principles of international taxation, and burdened U.S. companies.  USTR is proceeding with the public notice and comment process on possible trade actions to preserve procedural options before the conclusion of the statutory one-year period for completing the investigations.

Read the full announcement from USTR
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CBP Issues Forced Labor Finding on Top Glove Corporation Bhd.
April 1, 2021

U.S. Customs and Border Protection (CBP) announced on March 29th that it has directed personnel at all U.S. ports of entry to begin seizing disposable gloves produced in Malaysia by Top Glove Corporation Bhd. (Top Glove).  The CBP Office of Trade published a forced labor finding against disposable gloves produced in Malaysia by Top Glove in the Customs Bulletin and in the Federal Register.  The finding communicates that CBP has sufficient information to believe that Top Glove uses forced labor in the production of disposable gloves. Merchandise covered by the forced labor finding is subject to seizure upon arrival at a U.S. port of entry.

Read the federal register notice
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Tariffs Lifted on EU Products on Airbus List
April 1, 2021

The U.S. Trade Representative has modified the actions being taken in the investigation of civil aircraft dispute on European products.  The 15% tariffs on civil aircraft and 25% tariffs on approx. 150 tariff lines of products including liquor, Italian food and beverages, lenses, Greek yogurt, Spanish pork, and more were lifted at 12:01 a.m. March 11, and will remain suspended until midnight July 10.

Read the federal register notice
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Exclusions Extended for COVID-19 Products
April 1, 2021

Exclusions from the Section 301 additional tariffs on imports from China for 99 medical care products needed to address the COVID-19 pandemic are being extended through Sept. 30, 2021. These exclusions were scheduled to expire March 31; however, the Office of the U.S. Trade Representative has determined that these items are needed to combat the pandemic.

See a product list or to read the full publication
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USTR Announces Next Steps of Section 301 Digital Services Taxes Investigations
April 1, 2021

The United States Trade Representative (USTR) announced the next steps in its Section 301 investigations of Digital Service Taxes (DSTs) adopted or under consideration by ten U.S. trading partners.  In January, USTR found that the DSTs adopted by Austria, India, Italy, Spain, Turkey, and the United Kingdom were subject to action under Section 301 because they discriminated against U.S. digital companies, were inconsistent with principles of international taxation, and burdened U.S. companies.  USTR is proceeding with the public notice and comment process on possible trade actions to preserve procedural options before the conclusion of the statutory one-year time period for completing the investigations.

Get more information on the proposed action
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Softwood Lumber Import Assessment Increase
March 3, 2021

Effective April 1, the Department of Agriculture’s Marketing Service will increase the assessment rate from $0.35 to $0.41 per thousand board feet (MBF) on imported softwood lumber.  The order is administered by the Softwood Lumber Board with oversight by the U.S. Department of Agriculture (USDA). This rule will also add the conversion factor for square meters to board feet and makes one conforming change.

Read the Federal Register Notice
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New U.S. Sanctions on Myanmar (Burma)
March 3, 2021

On February 11, 2021, the Biden Administration authorized new sanctions and export-control restrictions on Myanmar (also called Burma) in response to the Myanmar military’s recent coup against the country’s elected civilian government.

Read the Official PublicationJAS Forwarding Worldwide, now requires that all shipments to/from Burma/Myanmar to have a risk assessment form completed. The risk assessment form can be retrieved by clicking HERE.
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According to a release order published by the White House, CBP announced that they will be detaining silica-based products made by Hoshine Silicon Industry Co., Ltd. and its subsidiaries.  CBP indicated that there is an indication that the company used forced labor in manufacturing these products. The polysilicon produced in the Xinjiang region of China is a core material in solar panels made in Asia.

Is your product being investigated for possible antidumping or countervailing duties?  Do you know how to find if it is before a formalized case has published?  The International Trade Commission (USITC) publishes public notices regarding investigations, solicitations, public comments, and questionnaires.  Click HERE to go to the USITC webpage for public notices.

FDA regulates sunscreens to ensure they meet safety and effectiveness standards. To improve the quality, safety, and effectiveness of sunscreens, FDA issued requirements and it must pass certain tests before they are sold.  Also, how you use the product, and other protective measures you take, make a difference in how well you can protect yourself and your family from sunburn, skin cancer, early skin aging and other risks of overexposure to the sun.

Here are some key sun safety tips:

  • Limit time in the sun, especially between the hours of 10 a.m. and 2 p.m., when the sun’s rays are most intense.
  • Wear clothing to cover skin exposed to the sun, such as long-sleeved shirts, pants, sunglasses, and broad-brimmed hats.
  • Use broad spectrum sunscreens with SPF values of 15 or higher regularly and as directed.
  • Reapply sunscreen at least every two hours, and more often if you are sweating or jumping in and out of the water.

Enjoy your summer and have fun in the sun!

Re-Export Under the EAR

Date:  July 28, 2021

Location:  VIRTUAL

The Bureau of Industry and Security (BIS) will offer a virtual seminar entitled Reexports under the EAR.  The seminar will explain how to determine if items made outside the United States are subject to the Export Administration Regulations (EAR) by using the Foreign Direct Product (FDP) rules, including the new Entity List related FDP, and the De minimis rules.  They will also discuss how to apply for a reexport license, common license exceptions used to reexport, and compliance tips.

Register Here

2021 Virtual Update Conference on Export Controls & Policy

Date: September 2, 2021

Location:  VIRTUAL

The Bureau of Industry and Security (BIS) is preparing for its annual Update Conference on Export Controls. This major outreach activity draws business and government representatives from around the world to learn and exchange ideas about export control issues. It is one of the Department’s most notable international trade events.

Register Here

U.S. Customs and Border Protection announced its seizure of a shipment of nitrile disposable gloves from Malaysia suspected of being made with forced labor. This announcement confirms that a recent seizure authorization is broader than the original withholds release order and that CBP is in fact acting under that authorization.

Senate Finance Committee Chair, Ron Wyden, announced legislation to update and reauthorize three expired trade programs: Generalized System of Preferences (GSP), the Miscellaneous Tariff Bill (MTB) and the American Manufacturing Competitiveness Act (AMCA). The Trade Preferences and American Manufacturing Competitiveness Act of 2021 will extend duty-free access to the U.S. market for certain developing countries under GSP until 2027, with important updates to eligibility rules that ensure trade policy rewards advances in human rights, women’s economic empowerment, labor, environment, rule of law and digital trade, among others.

Fabrics for Specialized Uses

Date: June 21, 2021

Location:  VIRTUAL

This webinar hosted by Customs & Border Protection will cover information as it relates to importing fabrics of specialized uses.

SIA 2021 Virtual Summer Back to Basics Conference

Date:  July 12-16, 2021

Location:  VIRTUAL

This five-session conference will provide attendees with the important first step to exporting articles on the United States Munitions List (USML) and the Commerce Control List (CCL) and the associated defense services and technology. This webinar is deal for newcomers (less than 5 years of experience) to exporting under the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR). Attendees will become familiar with the various types of licenses, agreements, exemptions and exceptions and the requirements and conditions associated with each.

Laurie Arnold and Leah Ellis of Corporate Compliance at JAS Forwarding attended the NCBFAA annual conference and provided their committee reports at the annual meeting.  The NCBFAA conference is an annual event that brings together more than 600 international trade representatives from across the United States to discuss trade affairs.

The new version of the publication “Don’t Let This Happen to You” is now available!  This publication is an introduction to the consequences of violating U.S. Export Control laws.  It includes actual investigations, export control and antiboycott violations published by the Bureau of Industry Security.  

To read the access the latest version, CLICK HERE.

Ahhh, the smell of ripe strawberries lingers in the air as one of the most wonderful times of the year has arrived…. SUMMER!  

Consider strawberry picking as a family friendly outdoor activity this year!  Most of us are accustomed to strawberries from the grocery that were shipped in from faraway places and picked perhaps a bit early to ensure smooth travels.   Local strawberries are a totally different experience.  You are selecting each one yourself at the peak of perfection.  They are ripe and red totally through and filled with flavor beyond comparison.

Here are 5 tips to make your strawberry picking experience the best!

  1. Pick on a weekday when strawberry availability is at its peak. Strawberries ripen over time and supplies are best mid-week.
  2. Arrive right when the farm opens on weekends.
  3. Local Berries are Fragile. Eat your strawberries or freeze them within 24 hours of picking.  
  4. Dress for Picking!  You are visiting a working farm so close-toed shoes, sun hat and sunscreen are in order.  
  5. Please pay for your Strawberries before eating them. It is hugely tempting to eat strawberries while picking, but strawberries are sold by the pound at most farms so you will need to weigh and pay before you enjoy.

Enjoy!! Cheers to the summer!

President Biden announced on April 12th his intent to nominate Chris Magnus, who has served as police chief of Tucson, Ariz., since January 2016, as commissioner of U.S. Customs and Border Protection.

According to a White House press release, Magnus rose through the ranks of the Lansing, Mich., police department and has also served as police chief in the cities of Fargo, N.D., and Richmond, Calif. “In each of these cities,” the press release said, “Magnus developed a reputation as a progressive police leader who focused on relationship-building between the police and community, implementing evidence-based best practices, promoting reform, and insisting on police accountability.” The White House also cited Magnus’ “extensive experience in addressing immigration issues” during his time in Tucson near the U.S.-Mexico border.

Enforcement of the prohibition of importation of goods mined, produced, or manufactured by forced labor is on the rise. CBP has published a webpage that contains withhold release orders issued by the Commissioner and findings published in the Federal Register. CBP does not generally publicize specific detentions, re-exportations, exclusions, or seizures of the subject merchandise that may have resulted from the withhold release orders or findings.

On April 29, 2021, Kevin J. Kurland, Acting Assistant Secretary for Export Enforcement, Bureau of Industry and Security (BIS) of the U.S. Department of Commerce, announced an administrative settlement of $3,290,000 with SAP SE (SAP), a multinational software company based in Walldorf, Germany. SAP also agreed to complete three audits of its export compliance program over a three-year period. SAP voluntarily self-disclosed potential violations of the Export Administration Regulations (EAR) to BIS and cooperated with the investigation conducted by the Boston Field Office of BIS’s Office of Export Enforcement.

The United States Trade Representative (USTR) announced the next steps in its Section 301 investigations of Digital Service Taxes (DSTs) adopted or under consideration by ten U.S. trading partners.   In January, USTR found that the DSTs adopted by Austria, India, Italy, Spain, Turkey, and the United Kingdom were subject to action under Section 301 because they discriminated against U.S. digital companies, were inconsistent with principles of international taxation, and burdened U.S. companies.  USTR is proceeding with the public notice and comment process on possible trade actions to preserve procedural options before the conclusion of the statutory one-year period for completing the investigations.

Did you know that Harbor Maintenance Fees (HMF) are exempt on an Entry Summary line (when MOT 10 vessel non-containerized, 11 vessel containerized, or 12 barge) when the article is classified under some HTS chapter 98 provisions?  Chapter 9808 has been added to that list. The HTS chapter 98 provisions that exempt the HMF are now 9804, 9805, 9806, 9807, 9808, and 9809.

Did you know that the Memorial Day Holiday used to be known as Decoration Day?  The holiday was celebrated by “decorating” the graves of fallen soldiers with flowers, flags, and more, hence the name “Decoration Day.” Over time, it became known as Memorial Day.  

We honor the men and women who died while serving in the U.S. Military, particularly those who died in battle or because of wounds sustained in battle.

SIA 2021 Spring Virtual Advanced Conference

Date:  May 17-19, 2021

Location:  VIRTUAL

This is a three-day VIRTUAL advanced level forum focusing on the processes and procedures relating to export controls and compliance.  Agenda topics will address a variety of advanced issues of concern to the international trade community in a more intimate setting with attendees from industry, government, and other international trade specialists.


Complying with U.S. Export Controls

Date: June 8-11, 2021

Location:  VIRTUAL

The two-day program is led by BIS's professional counseling staff and provides an in-depth examination of the Export Administration Regulations (EAR). The program will cover the information exporters need to know to comply with U.S. export control requirements on commercial goods.

U.S. Customs and Border Protection (CBP) announced on March 29th that it has directed personnel at all U.S. ports of entry to begin seizing disposable gloves produced in Malaysia by Top Glove Corporation Bhd. (Top Glove).  The CBP Office of Trade published a forced labor finding against disposable gloves produced in Malaysia by Top Glove in the Customs Bulletin and in the Federal Register.  The finding communicates that CBP has sufficient information to believe that Top Glove uses forced labor in the production of disposable gloves. Merchandise covered by the forced labor finding is subject to seizure upon arrival at a U.S. port of entry.

The U.S. Trade Representative has modified the actions being taken in the investigation of civil aircraft dispute on European products.  The 15% tariffs on civil aircraft and 25% tariffs on approx. 150 tariff lines of products including liquor, Italian food and beverages, lenses, Greek yogurt, Spanish pork, and more were lifted at 12:01 a.m. March 11, and will remain suspended until midnight July 10.

Exclusions from the Section 301 additional tariffs on imports from China for 99 medical care products needed to address the COVID-19 pandemic are being extended through Sept. 30, 2021. These exclusions were scheduled to expire March 31; however, the Office of the U.S. Trade Representative has determined that these items are needed to combat the pandemic.

On December 23, 2020, the U.S. Department of Commerce (Commerce) published a final rule in the Federal Register adopting the Aluminum Import Monitoring and Analysis (AIM) system regulations and establishing an AIM website. The AIM website consists of an online aluminum import license application platform and public AIM monitor. Commerce published a notice of a delay in January with an effective date of March 29, 2021.  This has been delayed again and is now effective June 28, 2021.  This delay means that licenses will not be required for covered aluminum product imports until June 28, 2021. Further information and a revised effective date will be provided in the Federal Register notice.

The United States Trade Representative (USTR) announced the next steps in its Section 301 investigations of Digital Service Taxes (DSTs) adopted or under consideration by ten U.S. trading partners.  In January, USTR found that the DSTs adopted by Austria, India, Italy, Spain, Turkey, and the United Kingdom were subject to action under Section 301 because they discriminated against U.S. digital companies, were inconsistent with principles of international taxation, and burdened U.S. companies.  USTR is proceeding with the public notice and comment process on possible trade actions to preserve procedural options before the conclusion of the statutory one-year time period for completing the investigations.

On March 1, 2021, the U.S. Court of International Trade (CIT) issued a decision with important ramifications for any company that uses “first sale” to reduce customs duty liability for goods imported into the United States.  All companies relying on first sale should review their first sale programs to evaluate the impact of this ruling and take adequate precautions.

Roll up your sleeves and get your garden ready for Summer on April 14, as it is National Gardening Day. Gardening is a fun and relaxing hobby enjoyed by many, and this is the perfect day for those who have been wanting to take up gardening to finally gather their tools and seeds and get their hands dirty. National Gardening Day happens at the height of Spring, so it is the perfect day to start growing your flowers, vegetables, herbs, and fruits, so they are ready to be enjoyed in the Summer. Even if you don't have a garden, you can still exercise your green fingers on houseplants, and bring the outside in.  Happy Spring!!

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