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Frances P. Hadfield is a counsel in Crowell & Moring's International Trade Group in the firm's New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving customs compliance, audits, customs enforcement, as well as import penalties.

Frances represents clients before the U.S. Court of International Trade and the U.S. Court of Appeals for the Federal Circuit, as well as in proceedings at the administrative level. She advises corporations on both substantive federal and state regulatory issues that involve U.S. Customs and Border Protection, the Federal Trade Commission, Food and Drug Administration, and U.S. Fish & Wildlife in matters pertaining to product admissibility, audits, classification, import restrictions, investigations, marking, licenses, origin, penalties, and tariff preference programs.

In ruling N326984 (August 2, 2022), Customs and Border Protection (CBP) discussed the tariff classification of torrefied wood pellets from Vietnam. The pellets under consideration consist of agglomerated, powdered wood by-products – which include sawdust, sawmill waste, wood manufacturing waste, and tree waste. The powdered wood is agglomerated under heat and pressure. The pelletized material

In ruling N327063 (August 3, 2022), Customs and Border Protection (CBP) discussed the country of origin of mallets. The imported mallets are identified as 12-ounce and 24-ounce Hickory 2-sided Soft Face Mallets. The mallets consist of a forged, carbon steel head and an injection-molded handle. The mallets also come with replaceable plastic caps that are

In a report from April 2022, Washington, DC based-firm Horizon Advisory investigated the Xinjiang aluminum sector and reported how – alongside the textile, apparel, agriculture, and solar energy sectors in the region – this sector is at high-risk of forced labor exposure. The report found that the eight major aluminum companies operating in Xinjiang –

In ruling N326933 (July 27, 2022), Customs and Border Protection (CBP) discussed the tariff classification of a “2-in-1 Tot Swimmer” flotation device from China. The item comes in two different styles and functions as a swim training system to grow with children as they become more comfortable in the water. The flotation device consists of

In ruling N326929 (July 8, 2022), Customs and Border Protection (CBP) discussed the tariff classification of a portable chair-and-backpack from China. The product, identified as an the “Playamigo All-in-One Portable Chair & Backpack,” is a combination travel tote bag with storage compartments and a portable seat. The item is constructed of 3 internal round steel

In ruling N326692 (June 30, 2022), Customs and Border Protection (CBP) discussed the tariff classification of a plastic Apple AirPods case cover from China. The product, identified as an “AirPods Silicone Case-Black,” is made wholly from silicone plastic and is intended to be a protective cover for the Apple AirPods charging case. The cover is

On June 17, 2022, the Department of Homeland Security (DHS) – which serves as the chair of the Forced Labor Enforcement Task Force (FLETF) – released the Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China (UFLPA Strategy) Report. The UFLPA Strategy Report was

In ruling N324972 (June 24, 2022), Customs and Border Protection (CBP) discussed the tariff classification and country of origin of liquid sugar from Canada. The subject merchandise contains 66.7% sugar and 33.3% water and trace amounts of Calcium hydroxide. The raw cane sugar is a product from Brazil that is granulated, diluted with water, heated