Import & Customs
The firm represents importers, foreign manufacturers, and their counsel in all aspects of U.S. customs law. That work covers matters before U.S. Customs and Border Protection (CBP), as well as the U.S. Food and Drug Administration (FDA), the U.S. Fish and Wildlife Service (FWS), the U.S. Environmental Protection Agency (EPA), the Consumer Product Safety Commission (CPSC), and the other agencies that regulate goods at the border. In the current tariff environment, much of that work concerns the cost, recovery, and allocation of duties, and the structures through which goods enter the United States.
Categories of representation include but are not limited to:
- Customs Valuation, including First Sale for Export, Related-Party Transactions, and Assists
- Tariff Classification and Binding Ruling Requests
- Country of Origin and Marking, including Substantial Transformation Analyses
- Free Trade Agreements and Preferential Programs, including USMCA
- Section 232, Section 301, and Section 338 Duty Exposure and Mitigation
- Recovery of IEEPA Duties, including Protests and Refund Reconciliation
- Allocation of Tariff Refunds and Surcharges among Importers, Suppliers, and Customers
- Importer of Record Structuring for Foreign-Owned Companies, including Executive Order 14411 Compliance
- Agricultural and Other Actual-Use Provisions (HTSUS 9817)
- Temporary Importation under Bond and Other Special Entry Programs
- Foreign-Trade Zone Designation, Activation, and Operations
- Prior Disclosures, Protests, and Petitions
- Requests for Information (CF-28), Notices of Action (CF-29), Liquidated Damages Claims, Penalty Notices, and Seizures
- Forced Labor Enforcement, including Withhold Release Order Detentions
- Antidumping and Countervailing Duties (AD/CVD)
- Customs-Trade Partnership Against Terrorism (C-TPAT), including C-TPAT Trade Compliance (formerly ISA)
- Customs Due Diligence in Mergers and Acquisitions
- Import Compliance Programs, Manuals, Audits, and Training