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USTR Solicits Public Comment (for possible exclusions) on Proposed List of $16 Billion of Chinese Goods To Be Subject to 25% Import Tariffs….TSI Global Consulting Can Argue for Exclusions.

The Office of the U.S. Trade Representative (USTR)  published in today’s Federal Register a notice for industry comments on $16 billion dollars of proposed section 301 tariffs to be imposed on Chinese products. The list of products slated to be subject to the tariffs (284 tariff lines baring exemptions) are noted in Annex C of the attached Federal Register announcement. An implementation date will be announced in the near future. Annex B of the attached notice denotes $34 billion dollars of Chinese goods that will be subject to 25% import tariffs effective July 6, 2018. These items have already been subject to public comment. If your company imports or purchases […]

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It’s Tariff Time…..Round and Round We Go

President Donald Trump and his Office of the U.S. Trade Representative (USTR) announced today (June 15, 2018) the imposition of 25% ad valorum tariffs on $34 Billion dollars, 818 tariff lines of imports from China. The tariffs become effective July 6, 2018. The list of items broken down by H.S. Code subject to this new round of tariffs can be found HERE. In the coming days USTR will be publishing a process for applying for company specific exclusions. If your company is impacted by these new tariffs and you would like to apply for an exclusion please contact TSI Global Consulting, LLC. An additional $16 Billion dollars, 284 tariff lines […]

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BIS Adds 33 Companies to the Unverified List

The Bureau of Industry and Security (BIS) announced today that 33 companies have been added to the Unverified List (UVL) [see Supplement 6 to Part 744 of the EAR]. The new additions include twelve companies in Russia, eleven in China, five in the United Arab Emirates, two in Canada and one each in Estonia, Pakistan, and Finland. As noted in previous blog postings, BIS adds persons to the UVL when they are unable to verify the bona fides of an entity through a pre-licensing or end use check. BIS often uses commercial officers in US embassies and Consulates as well as other US government officials to visit foreign entities that […]

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FEDEX Gets Hit by BIS for Shipments to Parties on the Entity List

Yes, even FEDEX can and does get hammered for Export Control violations. On April 24th, 2018 BIS reached a settlement for 53 violations of Part 764.2 of the EAR, namely facilitating unlicensed exports to parties listed on the entity list. The exports in question took place between July 1, 2011 and January 19, 2012 and involved shipments to Aerotechnic France SAS (“Aerotechnic”) and the Pakistan Institute for Nuclear Science and Technology (“PINSTECH”) both of whom were listed on the entity list when the exports occurred. The charging letter and accompanying settlement indicated FEDEX had used screening software that was not set for fuzzy logic and required full and exact names […]

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U.S. China Trade War…..More Details

As noted in our blog post of yesterday on April 9, 2018 the Chinese Ministry of Trade responded to the imposition of new US tariffs on steel and aluminum imposed by imposing new tariffs on 128 products of U.S. origin. According to the official announcement by the Chinese Ministry, effective April 2, 2018 new ad valorem tariffs of 15% were implemented on a wide range of U.S. origin fruits, nuts and steel products. New 25% duties were imposed on U.S. pork products and aluminum scrap metals. An unofficial English translation of the official Ministry of Commerce (MOFCOM) list of new Chinese tariffs already in force is noted below. Note that […]

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A Trade War on the Horizon?

In recent weeks several TSI Global Consulting clients operating in sectors ranging from strategic alloys to aerospace parts have expressed concern over the new protectionist trade policies of the Trump Administration. While the shift away from free trade towards a more domestic “America First” trade policy agenda should come as no surprise to those who have followed Trump’s rhetoric on trade prior to and following the election, recent policy actions do indicate a ratcheting up of commercial risk as rhetoric turns to action. To date, the only new United States tariffs that have been fully implemented as part of this current friction are the steel (additional 25% ad valorem) and […]

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Did you Know that US Customs and Border Patrol Publishes Importing Into the United States: A Guide for Commercial Importers?

On a fairly regular basis I receive an inquiry on my desk here at TSI Global Consulting from an importer that is seeking information on import requirements for specific products. Did you know that U.S. Customs provides a valuable source called Importing into the United States: A Guide for Commercial Importers? The guide provides a thorough technical overview of US requirements and required declarations for importing a wide range of products into the United States. For example, did you know: The following products are subject to the Federal Food, Drug, and Cosmetic Act, Chapter V, Subchapter C—Electronic Product Radiation (formerly called the Radiation Control Health and Safety Act of 1968): […]

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Doing Business in Cuba Just Got Even Harder

On June 16th, 2017 the Trump Administration issued a memorandum on Strengthening The Policy of the United States Towards Cuba. Today the administration followed up on that policy shift with simultaneous Final Rules issued by the Departments of State, Treasury and Commerce, Bureau of Industry and Security. During the Obama era, there had been significant movement towards liberalizing and opening limited trade relations as well as travel opportunities with the island nation. Today’s regulatory changes represent a partial rollback of that liberalization effort and will enhance the commercial risk of entering legal trade relationships in Cuba. While the details of today’s regulatory changes are too wide in scope to fully […]

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New to Exporting? Free Online Training from ExportU

At TSI Global Consulting we regularly receive phone inquiries from individuals and firms that need entry level “new-to-export” assistance. There are of course numerous organizations that can assist. The US Department of Commerce, International Trade Administration offers a wealth of free and low cost services and the Bureau of Industry and Security has an online Export Training Room with valuable webinars that can be used for self-training. You can also contact your local office of the Small Business Administration for free or low cost export counseling. An additional resource that recently came to our attention is ExportU. Developed by the Small Business Development Center, International Trade Center at the University […]

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Beware of the Qatar Boycott: Stay Clear of Potential EAR Part 760 Boycott Violations

On June 5 2017, the  United Arab Emirates, Saudi Arabia and Bahrain effectively cut ties with the Gulf state of Qatar based on an allegation that Qatar has been supporting terrorist organizations and the Iranian regime. Among other sanctions, these three countries have adopted a boycott of trade through Qatari ports, a travel ban imposed on Qatari citizens, and a ban on Qatari aircraft from landing rights in the three countries. Under a highly byzantine and archaic section of the US Export Administration Regulations (i.e. Part 760.2 of the EAR) no U.S. person may refuse to do business with or in a boycotted country when such boycott is not recognized as legitimate […]

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