Jennifer Diaz Featured in Inside U.S. Trade

We are pleased to announce that DTL President Jennifer Diaz was recently featured in Inside U.S. Trade!

In the article, “New Transshipment Limits Could Bring Confusion, Enforcement Hurdles,” reporter Brett Fortnam walks through how the Administration’s new approach to combatting transshipment includes goods with significant content from third countries in addition to traditional transshipment. He quoted Jennifer on how this approach is likely to cause confusion up and down the supply chain.

Below are a few snippets from the piece. Read the full article on InsideTrade.com here.

“Diaz said a new approach to transshipment will sow confusion up and down the supply chain. Changing what confers a product’s country of origin ‘adds another pillar of complexity’ to already complicated rules of origin, Diaz said.”

“If I were CBP, I would have a hard time understanding what kind of documentation and proof will be necessary,” Diaz said of the new policy. “Are we going to have the ability to audit raw material for every item? We all need a framework to start with. Now we’re all subject to audit risk, penalties and criminality. We need a good framework to ensure that everyone has the ability to comply.”

Diaz Trade Law is tracking the latest updates to U.S. trade policy.

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By |2025-08-05T13:34:46-04:00August 5, 2025|Import, news, Supply Chain|0 Comments

Bond Insufficiency Notices Are at an All Time High – Don’t Let This Happen to You!

With rising tariffs, U.S. Customs and Border Protection (CBP) is busy sending importers bond insufficiency notices advising them that their existing customs bond no longer covers their obligations. 

What is a Customs Bond

A customs bond, sometimes called a surety or import bond, is a financial guarantee that ensures importers meet CBP regulations and pay all applicable duties, taxes, fines, and penalties related to importing goods into the United States.

The most common type of bond is an import bond, which is required on all commercial shipments of goods valued over $2,500. An import bond is also required for shipments that are subject to other U.S. government agency requirements.

A single transaction bond can be used for a single entry. However, most importers utilize continuous bonds, which self-renew yearly and cover all customs transactions through any port of entry.

Insufficiency Notices on the Rise

CBP reviews the sufficiency of all active continuous import bonds on a monthly basis. If an importer’s bond has exceeded its capacity, CBP will issue a demand for a larger bond in the form of an insufficiency notice. The recent increase in tariffs means increased bond amounts, and many importers are struggling to properly calculate their bonds to keep them current. The number of bond insufficiency notices issued has quadrupled since 2017 and has accelerated recently with the volatile tariff environment. 50% of insufficient bonds are for bonds under $100k.

Chart courtesy of Colleen Clarke, SVP at Roanoke, GTE Conference 2025

Bond Calculations

CBP provides […]

ICYMI: Patio Furniture Company Agrees to Pay $4.9 Million to Resolve Duty Evasion Allegations

On July 24, 2025, the Department of Justice (DoJ) announced that Grosfillex, Inc., a Pennsylvania furniture company, agreed to pay $4.9 million to resolve allegations it evaded antidumping and countervailing duties (AD/CVD).

Grosfillex submitted false forms to Customs and Border Protection (CBP) claiming that furniture parts made of extruded aluminum from China were not subject to AD/CVD. The company attempted to hide the aluminum extrusions by falsely packing them as sham “furniture kits.” Additionally, for a different subset of extrusions, the company failed to correct customs forms it had submitted previously, even after learning that the forms contained false information.

The investigation arose from a whistleblower lawsuit filed under the False Claims Act by a former employee of Grosfillex. Under the False Claims Act, private citizens can sue on behalf of the government and share in any recovery. In this case, the whistleblower will receive $962,662.74.

Duty Evasion is on the Rise

This case is just one example of the growing incentive to cheat that comes with higher tariffs. Whether it’s through misclassifying goods, undervaluing imports, or using deceptive transshipment routes, some companies think they are being creative, but, instead, are participating in outright illegal strategies to reduce their tariff liability.

Higher tariffs have even contributed to the emergence of a cottage industry of “tariff reduction” companies that suggest ways to cut import costs. However, many of these so-called strategies amount to evasion, […]

What Happened This Month in International Trade (July 2025)

Another busy month in international trade news. Here’s the full roundup:

Administration

  • President Trump announced a trade deal with Japan. A 15% tariff rate will apply to all Japanese imports. Japan also committed $550B to invest in U.S. industry.
  • President Trump announced a trade deal with the Philippines. A 19% tariff rate will apply to all Philippine imports.
  • President Trump announced a trade deal with the EU. A 15% tariff will apply to most EU imports. 
  • President Trump announced a trade deal with Indonesia. A 19% tariff rate will apply to all Indonesian imports.
  • President Trump announced that Korea has agreed to a trade deal that will include a 15% tariff on all Korean imports.
  • President Trump signed an Executive Order imposing an additional 40% duty on certain imports from Brazil. 
  • President Trump announced that a 50% tariff on copper imports will take effect on August 1, 2025.
  • The White House released a Fact Sheet announcing that the de minimis exemption will end on August 29 for all imported […]
By |2025-08-01T10:25:43-04:00August 1, 2025|news, Snapshot, Uncategorized|0 Comments

New AD/CVD Case Filed: Unwrought Palladium from the Russian Federation  

A new antidumping and countervailing duty (AD/CVD) action has been filed against unwrought palladium from the Russian Federation (Russia). The allegation is that imports from Russia are unfairly subsidized and are being dumped.

Full list of exporters here.
 

Full list of importers here.  

Background on AD/CVD Investigations 

Antidumping duty (“AD”) and countervailing duty (“CVD”) investigations are brought jointly by the U.S. International Trade Commission (“USITC”) and the U.S. Department of Commerce (“Commerce”). AD investigations are triggered when a domestic industry alleges that it has been injured by competing imports of particular goods from specific countries being sold at less than a fair value. Meanwhile, CVD investigations are triggered when a domestic industry alleges that it has been injured by competing imports that are being unfairly subsidized by their governments. The domestic industry initiating the investigation is known as the petitioner while the foreign industry participating in the investigation is known as the respondent. 

 Scope of the Investigation 

The merchandise covered by these investigations is unwrought palladium, whether or not refined.  

 The products subject to the investigations are currently classified in the Harmonized Tariff Schedule of the United States (HTSUS) under subheading 7110.21.0000.  Full scope here.

Next Steps 

The Commerce Department will determine whether to initiate the investigations within 20 days. The USITC will reach a preliminary determination of material injury or threat of material injury within […]

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