In our previous blog (see below), we concluded that whether Customs has the authority to seize in-transit goods depends on the statutory interpretation of “import,” “importation” or “imported.” First, let us look at precedents. Courts have consistently held that under the tariff law, importation means the bringing of goods within the jurisdictional limits of the United States with intent to […]
Customs and Border Protection (CBP) recently issued a memorandum providing new guidance regarding acceptable mechanisms for submission of post-importation preference claims (Post-Entry Amendments (PEAs), Post Summary Corrections (PSCs), protests in 19 USC 1514 and post-importation claims in 19 USC 1520(d)). The agency has eliminated the use of protests as a mechanism to file post-entry claims for free trade agreement and […]
On Friday October 10, 2014 the Federal Maritime Commission announced “compromise agreements” totaling $503,000 in civil penalties from five NVOCCs, two unlicensed OTIs, and one vessel-operator. “Compromise agreements” do not admit guilt. They are: Eastern Car Liner Ltd. a vessel-operating common carrier based in Tokyo, Japan. Commission staff alleged that Eastern Car Liner operated pursuant to an unfiled space charter […]
Given that October is upon us, it seems appropriate to remind everyone that an FDA registration window just opened for renewal. As many of you already know, on December 12, 2003 FDA established a new set of regulations that required food facilities to register with the department. Under FDA and FSMA law, any person dealing with domestic and foreign facilities […]