JAS USA COMPLIANCE

News & Insights from JAS Worldwide Compliance

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Message for Importers

February 4, 2018

Importers: If you can't answer these 12 questions on forced labor, you're in trouble! Did you know that import cargo that has been made with forced labor can be seized by CBP?  An estimated 40.3 million people were living in modern slavery at any moment in time in 2016. This amounts to 5.4 victims of modern slavery for every thousand people in the world. Seventy three per cent of the victims of forced labor were female, and one in four victims were children. Forced labor accounted for 24.9 million people, while 15.4 million were in forced marriage.

Basic question: Have you taken reliable measures to ensure imported goods are not produced wholly or in part with convict labor, forced labor, and/or indentured labor (including forced or indentured child labor)? Click the following link (http://diaztradelaw.com/importers-cant-answer-12-questions-forced-labor-youre-trouble/ ) to find out what you can do to ensure imported goods are not produced by forced labor.

Article written and published by Jennifer Diaz of Diaz Trade Law.

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Latest News

BIS ADDS MORE HTS TO 232

The US Department of Commerce has posted for public inspection a Federal Register Notice that will be published in the Federal Register on August 19, 2025. This notice states that “BIS (Bureau of Industry and Security) is adding 407 Harmonized Tariff Schedule of the United States codes to the list of products that will be considered as steel or aluminum derivative products.

Per the FRN, “The non-steel and non-aluminum content will remain subject to the reciprocal and other applicable tariffs.” It goes on to note “The complete list of HTSUS codes added to the Section 232 tariffs by today’s action is listed in the annexes to this notice.”

Finally, the notice indicates that “The duties set out in the annex for these additional steel and aluminum derivatives are effective for…products that are entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on August 18, 2025.

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CHINA 10% EXTENDED

The President has issued an executive order “Further Modifying Reciprocal Tariff Rates to Reflect Ongoing Discussions with the People’s Republic of China” on August 11, 2025. This executive action falls under the International Emergency Economic Powers Act (IEEPA).

The United States has been in discussions with the PRC, and the rate has been 10% while discussions on details of a China deal have been continuing. The 10% was scheduled to expire on August 12, 2025, at 12:01 am EDT.

The Executive order notes that “The United States continues to have discussions with the PRC to address the lack of trade reciprocity in our economic relationship and our resulting national and economic concerns.” It goes on to say, “Through these discussions, the PRC continues to take significant steps toward remedying non-reciprocal trade arrangements and addressing the concerns of the United States relating to economic and national security matters.”

Because of these efforts, the President has continued the suspension of the duties until November 10, 2025 at 12:01 am.

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INDIA TARIFFS

The President has issued an executive order “Addressing Threats to the United States by the Government of the Russian Federation” on August 6, 2025. This executive action falls under the International Emergency Economic Powers Act (IEEPA).

This order addresses findings that the Government of India is currently directly or indirectly importing Russian oil. As a result, articles of India imported into the United States shall be subject to an additional ad valorem rate of duty of 25%. This will take affect on August 27 and will be in addition to the 25% reciprocal tariff that takes effect for India on August 7.

Goods that were loaded onto a vessel at the port of loading and in transit on the final mode of transit prior to entry into the United States before 12:01 am EDT on August 27, and are entered for consumption, or withdrawn from warehouse for consumption before 12:01 am EDT on September 17, 2025, the tariff will not apply.

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