Paul Fudacz, Author at Braumiller Law Group

Aluminum Extrusions from 13 Countries – Commerce Makes Affirmative Final AD and CVD Determinations

October 7, 2024

By Paul Fudacz, Partner, Braumiller Law Group
On September 27, 2024, Commerce announced its affirmative final determination in the ongoing AD / CVD aluminum extrusions investigation. On the same day Commerce also posted its Final Scope Issues and Decision Memorandum. In both, Commerce almost uniformly deferred to Petitioners in dismissing numerous comments of interested parties primarily challenging the scope of the investigation on a wide range of legal theories and practical considerations.

New Presidential Proclamations – Section 232 Duties on Certain Steel and Aluminum Products from Mexico

August 9, 2024

By Paul Fudacz, Partner, Braumiller Law Group and Senior Associate Attorney Megan Mohler

On July 10, 2024, the President issued two Presidential Proclamations related to the imposition of Section 232 duties on certain steel and aluminum products from Mexico. The first establishes a “melt and pour” requirement for imports of steel articles that are products of Mexico and will increase the section 232 duty rate for imports of steel articles and derivative steel articles that are products of Mexico that are melted and poured in a country other than Mexico, Canada, or the United States.

Aluminum Extrusions II – Scope Modifications Proposed, Dept. of Commerce Questioning Manageability

April 1, 2024

By Paul Fudacz, Partner, Braumiller Law Group

Since the last update on the AD / CVD aluminum extrusions investigation (dubbed Extrusions II) in what appears to be a response to strong opposition from trade industry groups, legislators, governments, and other interested parties, as well as dubious signals from the Department of Commerce, (Commerce) the Petitioners in the ongoing Aluminum Extrusions investigation have proposed modifications to the scope of the investigation.

New Antidumping and Countervailing Duty Investigation Initiated Covering Aluminum Extrusions from 15 Countries

November 8, 2023

By Paul Fudacz, Partner, Braumiller Law Group

On October 4, 2023, A coalition of 14 U.S. aluminum extrusion producers and labor unions filed petitions before the Department of Commerce, International Trade Administration (Commerce) and the International Trade Commission (ITC) seeking to impose antidumping (AD) and countervailing duties (CVD) on aluminum extrusions produced in 15 countries and exported to the U.S.

Update: Quartz Surface Products from China – New Certification Requirements for Shipments from Malaysia

December 8, 2022

By Paul Fudacz, Partner, Braumiller Law Group

On October 21, 2022, the Department of Commerce, International Trade Administration (The DOC) published its Final Scope Ruling on Malaysian Processed Quartz Slab. The DOC determined that imports of quartz slab manufactured in the People’s Republic of China (China) and processed in Malaysia are covered by the scope of the antidumping duty (AD) and countervailing duty (CVD).

Antidumping Duties – Can I Obtain a Separate Lower Rate?

October 2, 2022

By: Paul Fudacz, Partner, Braumiller Law Group
In Antidumping (AD) investigations, the U.S. Department of Commerce (DOC) typically selects only a limited number of exporting entities for review, with these exporters referred to as “individual” or “named” respondents. Selection of these respondents is based on U.S. Customs and Border Protection Data, and in most cases due to limited DOC resources, will consist of only a few of the largest exporters. If the selected respondents cooperate fully with the government investigation, and can demonstrate fair export pricing, they can obtain an individual AD rate that is generally favorable, or possibly de minimis, resulting in a zero rate.

Is Your Company in Compliance with US Immigration Form I-129 EAR / ITAR Certification Requirements?

August 9, 2022

By: Paul Fudacz, Partner, Braumiller Law Group

Most companies that employ non-U.S. persons in the United States are familiar with visa requirements, including completing U.S. Citizenship and Immigration Services Form I-129 – Petition for a Nonimmigrant Worker. However, many are less familiar with the affirmative due diligence and certification requirements contained in Part 6 of the I-129.

Cautions When Marking and Labeling Goods for Export from the United States

April 10, 2022

By: Paul Fudacz, Partner, Braumiller Law Group

Many importers are familiar with marking and labeling requirements for products imported into, and sold in the U.S. These include mandatory requirements such as U.S. Customs country of origin marking and labeling requirements, Federal Communications Commission labeling for certain electronic equipment, specific labeling for certain consumer products under the Federal Trade Commission and Consumer products Safety Commission, as well as a host of other mandatory marking and labeling requirements of other regulatory agencies for specified products.

I Just Found Out My Imported Goods are Subject to Antidumping – What Should I do?

February 6, 2022

By: Paul Fudacz, Partner, Braumiller Law Group

Currently there are close to 400 active antidumping cases involving nearly 40 countries. The cases cover a wide range of products including steel commodity products and steel articles (number one category), chemical products, other metal commodities and articles, plastics and rubber products, food products, paperboard and manufactured articles. Key countries subject to ADD are China (number one country by far), Korea, Indonesia, Taiwan, Thailand, Turkey, and Vietnam.

Federal Trade Commission Puts Teeth into False ‘Made in USA’ Claims Enforcement

December 6, 2021

By: Paul Fudacz, Partner, Braumiller Law Group

The U.S Federal Trade Commission (FTC) recently codified product labelling rules related to unqualified “Made in USA” (MUSA) claims under 16 CFR Part 323

A Beginners Guide to Exporting – Resources for Growth

June 7, 2021

By: Paul Fudacz, Partner, Braumiller Law Group It is well known going back to the founding of our country that exporting is the most beneficial

Department of Commerce Announces General Approved Exclusions (GAEs) for Steel Articles Under the 232 Exclusions Process

February 1, 2021

By Paul Fudacz, Partner, Braumiller Law Group

The Grinch came early in 2020 with the introduction by the U.S. Department of Commerce of new steel licensing requirements that instruct importers to indicate the “country of melt and pour” on standard steel licenses imported after October 13, 2020, and also the introduction on December 14 of new certification requirements related to the Section 232 exclusion process.

Recent Changes to Steel Import Monitoring and Analysis System

October 8, 2020

By: Paul Fudacz, Partner, Braumiller Law Group

On September 11, 2020, the U.S. Department of Commerce International Trade Administration published a final rule modifying its regulations pertaining to the Steel Import Monitoring and Analysis (SIMA) System. These changes include requiring steel import license applicants to identify the country where the steel used in the manufacture …

Recent CBP Entry Summary Guidance for Pipe Spools from Multiple Countries of Origin – Shapes of Things to Come?

June 1, 2020

By: Paul Fudacz, Partner, Braumiller Law Group On March 24, 2020, U.S. Customs and Border Protection published Cargo Systems Messaging Service # 42133823 “Entry Summary

Department of Homeland Security Announces Actions to Combat E-Commerce Counterfeiting

February 7, 2020

By: Paul Fudacz, Partner, Braumiller Law Group U.S. Department of Homeland Security (DHS) data shows that between the years 2000 and 2018, seizures of counterfeit

Section 301 Considerations When Importing from a NAFTA Country

April 5, 2019

By: Paul Fudacz, Senior Associate Attorney With the advent of the Section 301 tariffs, an issue that has been raised frequently is how to accurately

New NAFTA? – What NAFTA Practitioners Can Expect Under the United States-Mexico-Canada Agreement (USMCA)

February 11, 2019

By: Paul Fudacz, Senior Associate Attorney, Braumiller Law Group, PLLC Many importers are aware that the United States, Canada, and Mexico have negotiated a replacement

Are My Goods of Chinese Origin? Update on Country of Origin Rules in view of the Section 301 Tariffs

August 15, 2018

By BLG Senior Attorney Paul Fudacz With the first round of Section 301 tariffs in place as of July 6, and with the second round

President Announces Updated Steps to Address China’s Trade Practices to Protect U.S. Technology and Intellectual Property

June 15, 2018

By Paul Fudacz, Senior Attorney BLG On May 29, 2018 President Trump updated the steps his administration initially announced in March related to trade actions

Update on NAFTA Negotiations —April 2, 2018

April 3, 2018

By Paul Fudacz, Senior Attorney As negotiators from Canada, Mexico and the United States prepare for the eighth round of NAFTA discussions, there is increasing

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