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Bob focuses his practice on customs and international trade law. He brings 30 years of experience to a wide range of issues that affect inbound and outbound goods, including tariff classification, valuation, country of origin marking matters, free trade agreements, and special trade programs. He also has extensive customs compliance experience and regularly assists importers facing U.S. Customs and Border Protection (CBP) audits, penalties, seizures, redelivery notices and other agency enforcement activities. Bob works with importers and exporters proactively to achieve cost savings and structure programs that meet CBP "reasonable care" requirements. He also handles supply chain security issues, including Customs-Trade Partnership Against Terrorism (C-TPAT) enrollment, verification and annual reviews.

On Tuesday, January 23, 2018, President Trump signed the Presidential Proclamation to Facilitate Adjustment to Competition from Imports of Large Residential Washers, thereby announcing the President’s decision regarding the investigation of large residential washers (LRWs) under Section 201 of the Trade Act of 1974 (the LRW Safeguard Investigation). A copy of the Proclamation can be found here.

The government shutdown began on Saturday at 12:01am. Here is a list of several agencies involved in trade and transportation issues that will be affected.

International Trade Commission

The International Trade Commission will only have three to seven individuals working during the shutdown in order to protect life and property. The six Commissioners are presidential appointees and therefore are exempt from the furlough.

The Miscellaneous Tariff Bill (MTB) offers importers the opportunity to eliminate or reduce duties assessed on imported raw materials and intermediate products that are not produced in the United States or are unavailable domestically. The MTB’s goal is to aid U.S. manufacturers by reducing duties on inputs (raw materials, parts, etc.), thereby cutting domestic production costs and increasing the competitiveness of U.S. manufacturers. However, MTB duty benefits have also been granted to imported finished goods. For example, the last MTB granted duty benefits to certain shopping bags, basketballs and sports footwear. Duty savings for U.S. manufacturers under the MTB are anticipated to exceed $700 million annually. Interested importers should not miss the December 12, 2016, deadline to take advantage of these cost savings opportunities.

 On June 24, the Senate approved the Bipartisan Congressional Trade Priorities and Accountability Act of 2015, granting President Obama trade promotion authority, or TPA. The passage of this “fast-track” authority enables the President to leverage greater support during the upcoming negotiations for the Trans-Pacific Partnership (TPP) by guaranteeing that the trade agreement to be finalized by the 12-nation pact will be sent to Congress for approval without permitting lawmakers to amend the treaty.

The Miscellaneous Tariff Bill (MTB) process provides importers relief from duties on an item-by-item basis, up to $500,000 annually. On April 16, 2015, Senators Rob Portman (R-OH), Claire McCaskill (D-MO) and Pat Toomey (R-PA) introduced bipartisan legislation proposing to reform the MTB process. Many companies consider the new legislation a much overdue step that assists

On April 16, several pieces of key legislation were introduced that set the stage for a Bipartisan, Bicameral International Trade Package.  Senators Orrin Hatch (R-UT) and Ron Wyden (D-OR) along with Congressman Paul Ryan (R-WI) introduced long-awaited trade legislation to reauthorize Trade Promotion Authority (TPA) and renew several trade preference and liberalization programs.  TPA expired in 2007 and is necessary for the Obama Administration to move forward and conclude the Trans-Pacific Partnership and Transatlantic Trade and Investment Partnership negotiations.

Update to the TMT Industry Insider article, “New Federal Safety Standard Proposed for Phthalates in Children’s Toys and Certain Child Care Articles,” which was posted on February 12, 2015. The deadline to submit comments on the proposed CPSC rule on phthalates has been extended to April 15, 2015.

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A new and more stringent federal safety standard for phthalates in children’s toys and certain child care articles was proposed by the U.S. Consumer Product Safety Commission (“CPSC” or “Commission”) on Dec. 30, 2014. See Consumer Product Safety Commission, Prohibition of Children’s Toys and Child Care Articles Containing Specified Phthalates, 79 Fed. Reg. 78324 (Dec. 30, 2014) (amending 16 C.F.R. § 1307). This proposed rule on phthalates (the “proposed rule”) would establish a new federal standard on the use of specified phthalates in children’s toys and child care articles and expand the list of permanently banned phthalates under current law.