TradeLane

Most of us have heard of the terms “sanctions” and “embargoes.” They are often used interchangeably, but they are quite different.

Trade sanctions target specific types of transactions, as in a prohibition to sell arms to a specific business, country, government, or regime. An embargo represents a complete prohibition of all trade activities between countries.

This placeholder has been on the CBP website for a while now:

Do you trade in derivative aluminum and steel products? Do your imports include stranded wire, nails, tacks, and bumper stampings? If so, you have been paying Section 232 duties in the amount of 10% (aluminum) or 25% (steel) for the last few years, and need to pay attention to what is happening at the Court of International Trade regarding former President Trump’s Proclamation 9980.

Importers seeking refunds of section 301 duties for exclusions that were issued after the subject entries have liquidated and after the protest period has expired may have difficulties in duty recovery through any existing post-entry mechanism. One importer has even filed a suit at the Court of International Trade to compel CBP to reliquidate such entries so that they can benefit from the exclusions, but the result of that case is unknown at this time.

The passage of the Trade Facilitation and Trade Enforcement Act of 2015 (signed in February 2016) seems to have prompted a renewed effort by CBP to enforce regulations regarding the importation of “Merchandise Produced By Convict, Forced, or Indentured Labor.”  We have seen many instances over the last few weeks where importers have received CF28s asking about steps the importer has taken to ensure that their supply chains are free of child, forced, or convict labor.  Some of the demands are exceedingly broad: