TradeLane

As our Vice President Michael Bellezza spoke about on June 26^th, the pace of change in trade compliance regulations and requirements has never been swifter than in the past five years.

The United States market is not unique in grappling with these regulatory challenges. However, the formality with which US Customs & Border Protection, the US Bureau of Industry and Security, and other relevant government agencies enforce regulations, combined with the market size and trade volumes most US-based customers must manage, make this a jurisdiction where strategy and forethought are especially key to ensure trade compliance departments meet their goals.

US Customs and Border Protection (CBP) issued ruling H290535 on September 29^th, 2022, which specifies that CBP interprets suppliers providing HTS Classifications to US Importers of Record as “transacting customs business” and requiring a customs brokerage license.

On May 3^rd, the United States Trade Representative (USTR) issued a notice requesting comments from US domestic industry regarding the extension of Section 301 duties originally imposed in July and August 2018. The request for comments is directed at US domestic industries that have benefited from the Section 301 action, which imposes additional duties on products that are country of origin China.

**Update: CBP has notified the trade that HTS 9903.88.67 will be activated in ACE on April 12^th. Entries filed between April 12^th, 2022, and December 31^st, 2022, may claim the exclusion at time of importation using this HTS. Importers who paid Section 301 duty on entered merchandise that is now subject to an exclusion between October 12^th, 2021 and April 11^th, 2022 may recover previously paid duty via a Post Summary Correction (PSC). Tradewin may help with exclusion determinations and helping you build a post entry strategy.**

On March 24^th, 2022, the United States Trade Representative (USTR) issued an announcement reinstating certain product exclusions previously granted and expired for items subject to 301 duties. There are 352 product types that have been reinstated as part of this list, covering a broad range of commodities.

Importers, exporters, and producers trading within North America have been rapidly preparing for the July 1^st implementation of the US Mexico Canada Agreement (USMCA).