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
Frances P. Hadfield
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.
Customs Ruling of the Week – Country of Origin of Mallets
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…
Aluminum from Xinjiang Could be at Risk of Being Tainted with Forced Labor, Per April 2022 Report
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 –…
Customs Ruling of the Week – Classification of a Tot Swimmer Flotation Device
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…
Customs Ruling of the Week – Country of Origin of Sea Urchin Uni
In ruling N326746 (July 21, 2022), Customs and Border Protection (CBP) discussed the country of origin of Sea Urchin Roe Skeins. The Sea Urchin Roe (also known as “Uni”) is an organ of the sea urchin. Five strips of Uni reside within the structure of an urchin, and range in color from rich gold to…
Customs Ruling of the Week – Classification of Halloween-Themed Pet Toys
In ruling N326582 (July 6, 2022), Customs and Border Protection (CBP) discussed the tariff classification of a Halloween-themed pet toys from China. The item, which is described as “2-Pack Cat Toys,” is set of two plush pet toys that are meant for use by cats. Both toys are composed of 100% polyester woven plush fabric…
Customs Ruling of the Week – Classification of a Portable Chair-and-Backpack
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…
Customs Ruling of the Week – Classification of an AirPods Case Cover
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…
Department of Homeland Security Releases the Uyghur Forced Labor Prevention Act (UFLPA) Strategy Report
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…
Customs Ruling of the Week – Classification and Country of Origin of Liquid Sugar
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…