Photo of Martín Yerovi

Martín Yerovi is an international trade analyst in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border Protection (CBP). He works closely with attorneys developing courses of action for clients impacted by investigations under Section 301 of the Trade Act of 1974 and Section 232 of the Trade Expansion Act of 1962. He also supports unfair trade investigations, including antidumping (AD) and countervailing duty (CVD) investigations, sunset reviews, and changed circumstance reviews before the Department of Commerce and the International Trade Commission (ITC).

On October 4, 2023, a new ADCVD petition (“the Petition”) covering an estimated $1.5 billion in imports of aluminum exclusions was submitted before the U.S. Department of Commerce (“Commerce”) and the U.S. International Trade Commission (“USITC.”)  The Petition alleges that certain aluminum extrusion from Colombia, the Dominican Republic, Ecuador, India, Indonesia, Italy, Malaysia, Mexico, China

After more than 6 months since the UFLPA went into effect in June 2022, CBP released its UFLPA Statistics Dashboard. The UFLPA Dashboard provides users a snapshot of the number of shipments that have been subjected to UFLPA-related reviews and enforcement actions. Per CBP, the Dashboard contains “data related to enforcement of the UFLPA,”

Main Idea: HTSUS Chapter 98, Subchapter 17, U.S. Note 4(b) exclusions are determined based on weighing all criteria. Although a product may meet the definition outlined in U.S. Note 4(a), they may fit the criteria outlined in U.S. Note 4(b) and therefore be excluded.

In ruling N330488 (Feb. 9, 2023), Customs and Border Protection (CBP)

Main Idea: When making multiple determinations in a single ruling, the totality of evidence based on each determination contributes to the final decisions.

In ruling N330744 (Feb. 28, 2023), Customs and Border Protection (CBP) issued a decision on the classification, country of origin, marking and eligibility of the United States-Mexico-Canada Trade Agreement (USMCA) for a

Main Idea: The regulations used to determine the country of origin of textile and apparel products require the sequential application of rules much like the General Rules of Interpretation (GRIs) in the HTSUS

In ruling N326416 (Feb. 2, 2023), U.S. Customs and Border Protection (CBP) determined the country of origin of a prepared painting canvas.

Main Idea: A product’s essential character and primary function are key criteria to keep in mind in for both classification and country of origin determinations.

In ruling N330046 (Feb. 2, 2023), U.S. Customs and Border Protection (CBP) determines the classification and the country of origin for a glass water bottle with an aluminum shell.  The

At the end of December 2022, Congress passed the Consolidated Appropriations Act of 2023.  This Act contains a number of discretionary spending acts for different Departments, including the Department of Homeland Security Appropriations Act, 2023.  Per the Senate Committee on Appropriation, the Department of Homeland Security Appropriation Act for FY 2023 includes a total

Main Idea: Simple assembly operations will not substantially transform components that give shape and form (i.e., character) to the finished article and define its use.

In ruling N329853 (Jan. 12, 2023), Customs and Border Protection (CBP) considers the country of origin of the Sapper XYZ Arm Assembly (the Sapper).  This product is a monitor mount

Main Idea: Feeling positive about your country of origin determination? CBP’s decision on battery modules and packs confirms the importance of understanding the complexity of the substantial transformation rules.

In a decision impacting the electric vehicle, renewables, and other related industries, U.S. Customs and Border Protection (CBP) discusses the country of origin of battery modules

Main Idea: CBP has long history of limiting classification of items as furniture in chapter 94, HTSUS, to articles used by humans.

A variety of factors impact a product’s classification under the Harmonized Tariff Schedule of the United States (HTSUS).  However, U.S. Customs and Border Protection (CBP) has long demonstrated that the most important