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

Martín Yerovi
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…
Customs Ruling of the Week – Classification of a Robotic Vacuum Cleaner
In ruling N326460 (June 23, 2022), Customs and Border Protection (CBP) discussed the tariff classification of a robotic vacuum cleaner from China. The product is identified as the YEEDI Model DVX46, K850+ (the “K850+”). The K850+ is round in shape, measuring approximately 508 mm in diameter and 474 mm in height. The model is rated…
CBP Issues its Uyghur Forced Labor Prevention Act (UFLPA) Operational Guidance for Importers
On June 13, 2022, US Customs and Border Protection (CBP) issued CBP Publication No. 1793-0522, its UFLPA Operational Guidance for Importers (Operational Guidance). The Operational Guidance was issued by CBP to assist the trade community with its preparation for the UFLPA rebuttable presumption, which is set to go into effect next week on June…
Crowell & Moring Webinar – Balancing US/China Export Controls
Please join us for a Crowell & Moring webinar where attorneys will examine the myriad of challenges that companies face when balancing efforts to comply with the export regulations of both the United States and China. We will delve into both nations’ export control regulations and provide observations on areas to watch over the next…
Customs Ruling of the Week – Classification and Country of Origin of Frozen Scallops
In ruling N326448 (June 23, 2022), Customs and Border Protection (CBP) discussed the tariff classification and country of origin of frozen scallops. Per the ruling, Japanese Scallops (Patinopecten yessoensis) are harvested in Japan and then exported frozen, whole, in shell to China. Once in China, they are thawed, shucked, and soaked in a water solution…
Customs Ruling of the Week – Classification of a Motorcycle
In ruling N326004 (June 3, 2022), Customs and Border Protection (CBP) discussed the country of origin and tariff classification of a motorcycle. The merchandise was identified as the XR-150L Series Motorcycle, which has a gas-powered engine with a displacement of 149.16 cubic capacity (cc). The motorcycle’s manufacturing and processing operations take place in Mexico, which…
CBP Issues Minimal UFLPA Guidance: What We Know Based on WRO Detentions of Goods Alleged to be Made from Forced Labor in the XUAR Region.
With just over two weeks until the Uyghur Forced Labor Prevention Act (UFLPA) goes into effect on June 21, 2022, U.S. Customs and Border Protection (CBP) has issued very minimal guidance to the importing community on how it will enforce the legislation. In webinars and meetings conducted by CBP last week, CBP stated that it…
Customs Ruling of the Week – Classification of Wireless Intercom Headset

In ruling NY N324883 (April 15, 2022), Customs and Border Protection (CBP) discussed the tariff classification of a wireless intercom headset system from China. The item, referred to as the “Solidcom C1 full-duplex wireless intercom headset system,” is compromised of up to 8 wireless headsets and a HUB station. The audio communication between the headsets…
Customs Ruling of the Week – Cost Plus Transfer Price and Transaction Value
In ruling H313988 (February 18, 2022), Customs and Border Protection (CBP) addressed whether certain costs should be added to the customs value as assists when using the transaction value method in situations where the products are imported from related parties. For this case, there are two entities, which are referred to as the U.S. Entity…