International Trade Attorney
The Federal Trade Commission’s rules governing assertions that a product is “Made in the U.S.” can be confusing. As we’ve discussed on various occasions, that agency has strict standards on when claims of United States origin are permissible. I won’t repeat the Made In/Assembled In and qualified and … Read More...
Given that the United States concluded that Hong Kong is no longer autonomous from China, it should come as no surprise that the former is now subject to enhanced export controls that already applied to the latter. There are two simultaneous processes at work. China is being placed under a more … Read More...
The term “carousel” brings to mind a carnival merry-go-round, with laughing children, cotton candy and calliope music. It has a much less benign connotation when used in international trade disputes, as our friends at the Trade Representative's office have just reminded us. After winning the … Read More...
The Bureau of Industry and Security adopted two final rules and proposed a third at the end of April. We've already covered the military end use/end user license requirement. With apologies for the delay, it's time to address the other two as well. License Exception CIV to Be Eliminated First, … Read More...
Amendments to the Export Administration Regulations may seem so dry and pedantic to non-specialists. The bureaucratic jargon, references to dry-as-dust sub-subsections, and wooden prose can mask legal changes with important consequences. I'll leave it to you, Gentle Readers, to consider whether the … Read More...
Around the same time the Food and Drug Administration was loosening import requirements for such Personal Protection Equipment as masks and respirators, the Federal Emergency Management Agency imposed export restrictions on many of the same items. FEMA's Temporary Final Rule limits exports of N95 … Read More...
The Food and Drug Administration imposes an extensive and time-consuming qualification process for medical devices. While that may be a virtue in normal times, to ensure that such products meet safety and quality standards, it can stand as a roadblock when increased volumes are needed on short … Read More...
The Coronavirus pandemic has affected pretty much every aspect of life in the United States. We can now add trade policy to the list. As part of the Federal government's efforts to address the spread and treatment of COVID-19, the Trade Representative's office is considering exclusion of medical … Read More...
DATE HELD: Thursday, February 15, 2018 The Foreign Corrupt Practices Act imposes criminal liability on United States companies for bribery of foreign officials. This webinar discussed the types … [Read More...]
DATE HELD: November 16, 2017 Customs Section 592 Penalties: Who, What, When, Why and How, reviewed the circumstances under which Customs and Border Protection can impose penalties against importers … [Read More...]
