CTPAT

Significant Changes to CTPAT Trade Compliance Program in 2022

Diaz Trade Law is enthusiastic to announce Bloomberg Law published another one of our articles, “Significant Changes to CTPAT Trade Compliance Program in 2022“! Below is the article reproduced with permission for your reading pleasure. You can read the article here (where you’ll have the ability to access all of the great hyperlinks). Please note you cannot click on the hyperlinks below.

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International Trade Week

Diaz Trade Law was enthusiastic to attend various events from International Trade Week which took place from May 16-20 of 2022. Here is a recap of all the events we attended!

ADCVD

  • Scott McBride talked about transshipment and how it is evasion and how fraud is not covered by circumvention laws but rather by CBP.
  • This presentation discussed 226b, 226d, and 226f.
    • 226b discusses self-initiation and how a notice will be issued if the government initiates it.
    • 226d allows rejection of circumvention injury and identifying problems where parties can fix the issues.
    • In this case, if commerce does not identify the issue, commerce must issue determination and if it is extraordinarily complicated, it can be expanded up to a full year.

Food and Drug Administration

  • Angel Omar explained how all products are required to meet the same standards as domestic goods/products.
    • Drugs and devices must be safe and effective and require a fee application prior to importation.
    • Every product must meet performance requirements and must contain a label that is presented in English.
  • Food, Drugs, and Cosmetics Act has an import section that allows for refusal for import electronics and products that fail to meet the applicable standards.
    • Appearance is very important and based on the standard, the FDA can refuse the entry of goods that appear to be misbranded.
    • Section 708 allows the FDA to destroy products without an opportunity to export/refuse if the product is valued at $2500 or less.
  • FDA’s import alerts allow […]

Customs and Trade Law Weekly Snapshot

Here is a recap of the latest customs and international trade law news:

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Maritime Industry Rocked by Cyber Attacks

Co-Authored by Sharath Patil

The maritime industry has been rocked by a string of cyber-attacks in recent weeks. Two of the most severe incidents involved the United Nation’s shipping agency, the International Maritime Organization (“IMO”), and the French shipping company CMA GCM S.A. (“CMA GCM”). These attacks remind the shipping industry about the dangers of such attacks and the importance of cybersecurity compliance. From a trade and customs perspective, such incidents trigger post incident analysis and other measures as part of the U.S. Customs & Border Protection’s (“CBP”) Customs Trade Partnership Against Terrorism Minimum Security Criteria. We will discuss two of the most severe cyber-attack incidents in recent weeks below and then discuss the trade and customs implications of such attacks.

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DTL Tuned-In to the 2020 World Trade Center Miami’s International Trade Week – Check out our Recap:

111During the weeklong series of 10 informative webinars on trade regulations, we heard TOP TIPs from numerous federal agencies, including U.S. Customs & Border Protection (CBP), U.S. Food and Drug Administration (FDA)’s Division of Southeast Imports, Miami’s CBP Fines, Penalties & Forfeitures (FP&F) Office, Miami CTPAT Field Office and more! Each webinar was produced to assist importers and exporters understand compliance and hot issues. Below are summaries of two webinars – FDA Import Operations Associated with COVID-19 Efforts and CTPAT – State of the Program / Minimum Security Criteria Updates:
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