An Overview of the IPEF Supply Chain Agreement. In a world where supply chain disruptions have become more frequent and impactful, countries are recognizing the need to enhance the resiliency and efficiency with supply chains. The Indo-Pacific Economic Framework for Prosperity (IPEF) supply chain agreement aims to address this challenge. Set to go into effect…
Activity under the EAPA has been picking up lately, so it would be timely to address the statute and administrative procedures under it and describe some of the enforcement concerns for US importers and their foreign suppliers. Simply stated, antidumping duties are imposed by the US Commerce Department when imported merchandise has been determined to…
By George W. Thompson In anticipation of the Uyghur Forced Labor Prevention Act, a number of federal agencies issued a joint Xinjiang Supply Chain Business Advisory in July 2021. An Addendum to that advisory was released in September 2023. The Addendum identifies a wide range of additional products and industries believed to use forced labour or child labor. Much…
The export controls on products destined for Russia have been expanded. These controls present an enforcement challenge for three reasons: Watch as George Thompson, international trade attorney, discusses the implications of the expanded controls and recommended actions for exporters. Thompson & Associates, PLLC provides representation in all aspects of customs laws and regulations, specializing in…
Determining when a product can be labeled or advertised as Made in America is an ongoing compliance challenge. One seeming gray area arises when a product which undergoes production activities in the U.S. is no longer an article of foreign origin falling under CBP’s oversight. If it undergoes a substantial transformation in the United States,…
The Unverified List, the Commerce Department’s listing of foreign companies subject to restrictions on all items included in the Export Administration Regulations, has received increased attention as a result of the recent addition of 33 Chinese industrial and technology companies to the list. Read how George Thompson, International Trade Attorney, explains what the Unverified List…
The Bureau of Industry and Security (BIS) has adopted a new administrative enforcement approach for resolving export control violations. BIS anticipates it will result in the imposition of substantially higher monetary penalties for egregious cases, while also providing for non-monetary resolutions of less serious ones. It was implemented to address evasions of the ever-growing restrictions…
The Uyghur Forced Labor Prevention Act (UFLPA) went into effect on June 21, 2022. The UFLPA has three key provisions: It creates a rebuttable presumption that all items produced, in whole or in part, in the Xinjiang region of China are made with forced labor. It requires Customs and Border Protection to create an Entity…
Buy American Rules Update There have been fairly significant changes to the Buy American rules under both the Federal Acquisition Regulation, or FAR, and the Defense Federal Acquisition Regulation Supplement, or DFARS. They relate to when a product qualifies as a domestic end product, and thereby is eligible for the Buy American bidding preference. In…
The Federal Trade Commission’s Made in the USA Rules A notice appeared in the May 19th Federal Register detailing a consent agreement reached with a company called Lions Not Sheep over what the Federal Trade Commission alleged were false and misleading statements regarding the origin of their products. In the following transcript, George Thompson discusses the…
Sanctions imposed on Russia by the BIS The February 24 sanctions imposed on Russia by the BIS have put in place a vastly expanded definition of the foreign-direct product rule, which will pose significant compliance challenges. In the following transcript George Thompson details which products are affected by the new rule and how it will…
The Unverified List The Commerce Department’s listing of foreign companies subject to restrictions on all items included in the Export Administration Regulations, has received increased attention as a result of the recent addition of 33 Chinese industrial and technology companies to the list. The following transcript from George Thompson‘s video, explains what the Unverified List…
