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 … [Read more...]
Export Controls on Personal Protection Equipment and Exceptions
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 … [Read more...]
FDA Relaxes Requirements for Imported Personal Protection Equipment
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 … [Read more...]
New Section 301 Tariff Exclusion Process for COVID-19-Related Items
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 … [Read more...]
Federal Circuit Defines Country of Origin Requirement for Federal Procurement
Just when I thought I was running out of blog topics, along comes the Federal Circuit to stir the pot for country of origin determinations under the Federal Acquisition Regulation. In Acetris Health, LLC v. … [Read more...]
Incoterms® 2020 Now in Effect
The new decade is now upon us, and we all know what that means. First, the Census Bureau will send out questionnaires seeking such important knowledge as the number of dust bunnies hiding under the sofa. … [Read more...]
Commerce Department Proposes Intrusive Rule for Scrutinizing Information and Communications Technology and Services
As directed by Executive Order 13873, the Commerce Department has proposed a rule for Securing the Information and Communications Technology and Services Supply Chain. Comments on it are due by December 27, … [Read more...]
Opportunity to Request Duty Suspension or Reduction Under the American Manufacturing Competitiveness Act of 2016
Has it really been three years already? The International Trade Commission has issued its Second Request for Petitions for Duty Suspensions and Reductions. We discussed the process after the first such request … [Read more...]
How Is the Trade War Like a Romantic Comedy?
This trade war business is beginning to remind me of the classic film Groundhog Day, except without the comedy or happy ending. You’ll recall that’s the one where Bill Murray plays a weatherman who relives the … [Read more...]
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