We advise and represent clients on matters related to import and customs law, export controls, economic sanctions, antiboycott restrictions, and free trade agreements.
On October 24, 2018, the Bureau of Industry and Security (BIS) revised the Commerce Control List (CCL) and EAR to update the Wassenaar Arrangement List of Dual-Use Goods and Technologies following changes decided upon during the December 2017 Plenary meeting. This final rule amends over fifty (50) ECCNs, License Exceptions APR, ENC, and STA, Definitions, the WA Sensitive and Very Sensitive Lists, and Regional Stability Controls.
President Trump and the Office of the United States Trade Representative (USTR) announced additional tariffs on $200 billion worth of Chinese imports as part of the US’s continued response to China’s ongoing theft of American technology. The new tariffs will take effect on September 24, 2018 and will be set at a level of 10% until year end. On January 1, 2019, the tariffs will rise to 25% with additional tariffs promised in the event the Chinese government takes retaliatory action against other US industries. China immediately countered with tariffs on $60 billion of US goods.
As a result of comments received from the March 19 rule on remedies to the actions taken by President Trump’s issuance of Proclamations 9704 and 9705 to protect national security from threats resulting from imports of aluminum and steel, the Department of Commerce instituted a new process, effective September 11, for submitting objections to exclusion requests. BIS expects the revisions to the rule to make significant improvements to the current process for submitting tariff exclusion requests.
On August 30, the Bureau of Industry and Security (BIS) amended the Export Administration Regulations to reflect changes to the Missile Technology Control Regime (MTCR) Annex that were agreed to by MTCR member countries in 2017. This final rule updates the following seventeen ECCNs: 1B117, 1B118, 1C111, 1C118, 2B109, 2B120, 2B121, 2B122, 6A107, 7A105, 7A107, 7A116, 9A012, 9A101, 9A115, 9A515, and 9A610.
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