Norman Lubeck

Norman Lubeck
Norm joined Tradewin in 2011, continuing a successful career in international logistics and trade compliance that began in 1987. He has held the position of Trade Counsel for a logistics management firm and managed the Trade Compliance departments for several multinational corporations. Norm's technical background includes Focused Assessment, C-TPAT implementation, Free Trade Agreement compliance, and expertise in a broad spectrum of international trade topics. Norm holds a B.A. from Middlebury College and a J.D. from Suffolk Law School. He is a licensed customs broker and is a member of the Massachusetts Bar.

Recent Posts

Sanctions and Embargoes: How Are They Different?

Churchillian Thoughts on European Customs Valuation

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.

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Topics: Tradewin, Sanctions, Embargoes

CTPATTCP is Coming! CTPATTCP is Coming!


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

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Topics: Tradewin, Trade Compliance

Section 232 Updates – Steel and Aluminum Derivatives


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.

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Topics: Tradewin, Sourcing, Trade Compliance

US Section 301 Duty Recovery via Liquidation Extension

301 header

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.

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Topics: Duty Drawback, Section 301

Slave and Child Labor in Global Supply Chains

Slave and Child Labor in Global Supply Chains.jpg

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:

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