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International Trade

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CBP Seized Your Goods at the Border: Your Options and Next Steps 

For more information on this topic, check out our webinar: ‘Goods Detained or Seized by CBP? Understand Your Options.” Watch here. 

 

Summary: When CBP seizes imported goods at the border, importers have several options — including filing a Petition, submitting an Offer in Compromise, or pursuing court action. This article explains the difference between detention and seizure, outlines the steps importers should take immediately after receiving a CBP Seizure Notice, and describes how a customs attorney can help recover seized merchandise and prevent future seizure. 

Importers expect the import process to run smoothly, but when a product is not compliant with U.S. laws and regulations, CBP is authorized under 19 CFR Part 162 and 19 CFR Part 151 to detain or seize goods upon importation. 

When goods arrive at a U.S. port of entry, CBP has the authority to detain a shipment if there is a question about its admissibility or compliance with U.S. laws and regulations. Detention is not the same as seizure. It is a temporary hold that gives CBP time to review the shipment and allows the importer to respond. During this window, a customs attorney can communicate directly with CBP on your behalf, provide the documentation or legal arguments needed to resolve the issue, and work to get your goods released before the situation escalates. 

If you do not respond effectively, CBP may move forward with a formal […]

By |2026-08-21T14:21:54-04:00June 19, 2026|Enforcement, Import, International Trade, Pre-compliance, U.S. Customs and Border Protection (CBP)|0 Comments
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Bosch Agrees to Pay $36 Million Penalty to BIS for Unauthorized Shipments to Huawei 

Robert Bosch GmbH (Bosch), the German multinational engineering and technology company, has agreed to pay a $36,184,680 penalty to the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) for exporting controlled items to Huawei Technologies Co. and its affiliates without the required U.S. government authorization. 

What Happened 

Between September 2020 and September 2024, Bosch exported approximately $72.4 million worth of Micro-Electro-Mechanical Systems (MEMS) sensor products and automotive software from abroad to Huawei and its affiliates. The exported items were subject to the Export Administration Regulations (EAR) under the Foreign Direct Product Rule, a rule that extends U.S. export controls to certain foreign-produced items that incorporate U.S. technology or are manufactured using U.S. equipment. Because Huawei and its affiliates are listed on BIS’s Entity List, any shipment of items subject to the EAR requires a license from BIS. No such license or authorization was obtained. 

The MEMS sensors at issue are widely used in consumer products, including smartphones, wearable technology, and automobiles. 

The Penalty 

In addition to the $36 million BIS civil penalty, Bosch separately agreed with the Department of Justice to disgorge profits from the transactions, with an actual payment of approximately $3.6 million. BIS suspended approximately $3.6 million of its penalty as credit for the disgorgement, bringing Bosch’s total financial exposure to roughly $39.8 million. 

Bosch filed a Voluntary Self-Disclosure with […]

By |2026-06-18T12:00:26-04:00June 18, 2026|EAR, Enforcement, Export, International Trade, U.S. Bureau of Industry and Security (BIS)|0 Comments
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CBP Just Rewrote the Forced Labor Rulebook: What the New Operational Guidance Means for Importers

Short summary: On June 9, 2026, CBP issued new guidance supplementing its 2022 UFLPA guidance and other resources with a single document covering every forced-labor authority it enforces. The new guidance outlines CBP’s detention and exclusion processes and gives practical guidance on how to respond.

On June 9, 2026, U.S. Customs and Border Protection (CBP) published its new Forced Labor Enforcement Operational Guidance for Importers (Publication No. 5560-0526). It is not a refresh. It updates the June 13, 2022, UFLPA Operational Guidance for Importers and, for the first time, consolidates all forced-labor enforcement authorities CBP wields into a single 89-page reference. 

That consolidation is the story. Until now, importers had to stitch together separate sources to understand how the Uyghur Forced Labor Prevention Act (UFLPA), Withhold Release Orders and Findings under 19 U.S.C. § 1307, and the Countering America’s Adversaries Through Sanctions Act (CAATSA) actually differ in practice. CBP has now mapped all of them — including the exact timelines, the review paths, and the documentation bar — in one place. The practical effect: ignorance of the process is no longer a defensible position. 

The one-line summary every importer needs 

CBP detains or excludes goods it suspects were made, wholly or in part, with forced labor — and the burden is on you to prove they weren’t, on a clock that can […]

By |2026-06-17T10:00:59-04:00June 17, 2026|CTPAT, Enforcement, Forced Labor, Import, International Trade, U.S. Customs and Border Protection (CBP)|0 Comments
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New Section 232 Action: What the June 2026 Aluminum, Steel & Copper Proclamation Means for Your Imports

Topline summary: On June 1, 2026, President Trump amended the Section 232 tariff framework for aluminum, steel, and copper. Importers of agricultural, industrial, and mobile equipment may qualify for temporarily reduced rates of 10–15%, while certain furniture parts, lithographic plates, and steel racks are newly dutiable for the first time. With a December 31, 2027, sunset on all temporary reductions, importers should audit their HTS classifications now to avoid overpaying or underpaying.

On June 1, 2026, the President issued Proclamation 11032, “Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States,” amending the April 2026 Section 232 framework (Proclamation 11021). U.S. Customs and Border Protection (CBP) followed on June 5 with implementation guidance in CSMS #68855869. The changes take effect for goods entered for consumption, or withdrawn from a warehouse for consumption, on or after 12:01 a.m. ET on June 8, 2026. 

This is not a uniform tariff cut. The proclamation does two opposite things at once. It reduces Section 232 rates on a large block of machinery and equipment, while simultaneously adding new products to the duty regime for the first time. If you import equipment, the change may help you. If you import certain furniture parts, lithographic plates, or steel racks, you may have just become newly dutiable.  

What Changed on June 8 

  1. New products […]

By |2026-06-08T17:20:18-04:00June 8, 2026|Import, International Trade, tariffs, Trade Policy, U.S. Customs and Border Protection (CBP), U.S. Department of Commerce (DOC), U.S. Office of the United States Trade Representative (USTR)|0 Comments
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FTC Cracks Down on False “Made in the USA” Claims 

The Federal Trade Commission (FTC) recently announced law enforcement actions involving three companies that falsely claimed that their products were made in the United States.  

Made in the USA

The “Made in the USA” labeling rules were enacted to prevent deceptive advertising and ensure customers can make informed purchasing choices. The concept of labeling products with the correct country of origin dates all the way back to the McKinley Tariff Act in 1890, and Congress and federal agencies have updated “Made in the USA” rules over the years.  

FTC Jurisdiction 

The FTC is charged with preventing deception and unfairness in the marketplace. Under the FTC Act, the Commission may bring legal action against “false or misleading claims that a product is of U.S. origin”. The agency is authorized to issue a civil penalty of up to $40,654 per violation. 

The FTC has issued guidance on complying with the “Made in the USA” standard, most recently in 2021. View the latest guidance here.

When Can I Say Made in the USA? 

For a product to be considered as “Made in the USA” without qualification, that product must be “all or virtually all” made in the U.S. How the Commission determines whether a product is “all or virtually all” made in the U.S. is by looking at whether there was “a ‘reasonable basis’ to support the claim at the time it is made”. To prove […]

By |2026-06-05T11:20:09-04:00June 5, 2026|Best Practices, Enforcement, Import, International Trade, Labeling, U.S. Federal Trade Commission (FTC)|0 Comments
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