Government Procurement

On August 15, 2019, USTR issued a pre-publication version of the Federal Register in which the formal announcement regarding China 301 Tariffs List 4A/B will be made. In that notice, USTR clarified the September 1, 2019 effective date refers to the date of entry or withdrawal for consumption for the goods on List 4A/Annex A.

Originally published by the Journal of Commerce in August 2019

Much has been said recently in the general press about the latest round of tariffs and what did or did not prompt President Trump to decide that August 1st was the right time to impose an additional 10% on the goods from China on the

While the Federal Register notice containing all the relevant details has yet to be published, today, the U.S. Trade Representative published an announcement confirming that certain unidentified products were removed from List 4 for health, safety, national security and similar reasons, and those remaining would be rolled out on two different lists with two different

Originally published by the Journal of Commerce in July 2019

Much to the surprise of many American companies, my cost is going to go through the roof with a 25% tariff and price my products out of the market is not enough of a justification for an exclusion request to be granted. It was not

In the June 20, 2019 pre-publication edition of the Federal Register, the U.S. Trade Representative announced the long awaited process for seeking exclusions for goods on List 3, the one which recently went from 10% to 25%.  While the exclusion process itself generally mirrors the process applied to those goods on Lists 1 and 2,

In March, there was a good deal of consternation in the general press trying to understand news that President Trump had overruled the actions of the Office of Foreign Assets Control (“OFAC”) to impose additional sanctions on North Korea. Beside the oddity of a President overruling actions by a part of the Executive branch after

Originally published by the Journal of Commerce in March 2019

On the trade with China front this week, the news is Huawei Technologies Co, of China sued the U.S. government regarding provisions in the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (“NDAA”).  The timing of the lawsuit is drawing interest as

Originally published by the Journal of Commerce in February 2019

Of all the questions asked of trade attorneys, this is likely the most frequent one.  The answer is both a study in current events, but also much more complex.  Let’s start at the obvious beginning point. Customs and Border Protection (“CBP”) receives advance information about

The Consolidated Appropriations Act of 2019 was signed into law on Friday, February 15, 2019, so the potential for another shutdown was averted, but there was a hidden gem buried in a related document. This new law contains a specific appropriation for the U.S. Trade Representative’s office which reads: “For necessary expenses of the Office

Over the weekend, President Trump announced a deal with China. The result is the 10% tariff imposed on goods on List 3 of Chinese made goods will remain in place for an additional 90 days rather than increase to 25% on January 1, 2019. The challenge is there was no joint communique issued by the