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 … [Read more...]
BIS Suspends Hong Kong’s Eligibility for Certain License Exceptions
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 … [Read more...]
Airbus Tariffs Due for Overhaul
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 … [Read more...]
Additional Changes to Export Administration Regulations License Exceptions CIV and APR
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 … [Read more...]
BIS Puts the Squeeze on China, Russia and Venezuela
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...]
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