Q&A - The Great Trade Pivot: Changing Policies and Their Impact on Your Global Supply Chain

A few weeks ago, Amber Road's Global Trade Academy hosted the webinar The Great Trade Pivot: Changing Policies and Their Impact on Your Global Supply Chain. This webinar (available on-demand) walks through some of the biggest potential policy changes that could dramatically raise your import costs and have a profound impact on your company’s import compliance program.

Robin Grover, an international trade lawyer with over 35 years of experience handling all aspects of export-import issues, recieved a lot of great questions during the live broadcast and he has taken the time to answer some here.

Q: What is your opinion on GSP getting reinstated? What timing do you expect? 

1. CBP notes on its website: “GSP periodically expires and must be renewed by Congress to remain in effect. The 2015 GSP reauthorization (H.R. 1295) expired on December 31, 2017. All previous GSP renewals that have taken effect after a lapse have included a retroactive clause providing refunds to importers of eligible goods imported during the lapse period.”  Customs goes on to recommend that you “flag” all GSP entries: “Until further notice, importers are strongly encouraged to continue to flag GSP-eligible importations with the SPI “A,” even as they pay normal trade relations (column 1) duty rates on otherwise GSP-eligible importations. Importers may not file SPI "A" without duties.”   I fully agree with Customs on this and expect that Congress will ultimately renew GSP and make its benefits for entries retroactive.  On a related note, please be aware that CBP in conducting audits is looking for substantial documentation in your files to support claims of GSP duty-free status for your imported goods.

Q: Are the Section 232 cases against steel and aluminum seen as cases against raw steel and aluminum (rolls sheets etc.) or even articles made of steel and aluminum?

1. There is some secrecy attached to the Commerce investigation and recommendation to the President as to which products and countries would be covered.  From all that I have seen, it would appear to be primary forms of aluminum and steel.

Q: What is the number of the Executive Order that emphasizes enforcement of Anti-Dumping and Countervailing Duties?

1. Executive Order 13785, dated March 31, 2017 and entitled: Presidential Executive Order on Establishing Enhanced Collection and Enforcement of Antidumping and Countervailing Duties and Violations of Trade and Customs Laws.

source https://blog.amberroad.com/blog/qa-the-great-trade-pivot-changing-policies-and-their-impact-on-your-global-supply-chain