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Pillsbury’s Customs Compliance team has hands-on experience with customs audits, Customs-Trade Partnership Against Terrorism (C-TPAT) verifications and other customs-related interactions with the U.S. government.
Pillsbury’s experience encompasses virtually every aspect of U.S. customs laws and their administration. Our lawyers advise on tariff classifications, country of origin marking, rules of origin and import valuation (including intra-company transfer pricing) and are highly experienced in interpreting and applying the complex rules of origin that affect international trade.
The firm represents clients in requesting rulings from Customs and Border Protection (CBP) and assists the agency in designing internal customs compliance programs, handling audit responses and defending clients in seizure, enforcement and penalty proceedings. The firm represents clients in challenges to import duties before the Court of International Trade. Our lawyers also help companies evaluate the impact of international trade agreements and other tariff preference arrangements on their exports and imports, advise on how component-sourcing arrangements can affect price, and assist importer clients in complying with the more stringent responsibilities imposed by customs programs regarding regulatory and import shipment security requirements. We work closely with our clients to make certain they understand these programs thoroughly, including the Importer Self-Assessment program and the C-TPAT.
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Successfully appealed to CBP Headquarters a change in tariff classification made at a port, resulting in the cancellation of CBP invoices for $20 million in duties.
Advised manufacturer of steel products on interplay of U.S. and Canadian origin and tariff rules for products crossing border multiple times.
Successfully advised U.S. and foreign companies in obtaining exclusions from tariffs on products imported from China under Section 301 of the Trade Act of 1974, representing millions of dollars in tariff savings. Clients represent a broad range of industries including artworks, manufacturers of pipe fittings, machinery, computer hardware and supplier of technology, automation and services.
Representing several importers across a wide range of industries before the Court of International Trade in challenge to import duties on products from China under Section 301 of the Trade Act of 1974.
Represented U.S. importer in CBP investigations of tariff classification and valuation issues.
Assisted the U.S. subsidiary of a major foreign manufacturer with a Focused Assessment audit by CBP, including being present for the entire audit.
Advised large manufacturer on Harmonized Tariff Schedule (HTS) classification, and prior disclosure, and country of origin issues in connection with imports of steel, rubber, and glass construction materials.
Represented European crane manufacturer in connection with Department of Commerce Section 232 investigation on mobile cranes, successfully coordinating with U.S. industry members to help achieve termination of the investigation that could have resulted in duties.
Represented a U.S. company in negotiating a settlement with CBP of an enforcement action involving a failure to add the value of “assists” to the value of imported goods.
Represented a producer of food products in an administrative enforcement action in which CBP alleged that the imports did not comply with the North American Free Trade Agreement (NAFTA) rules of origin.
Advised a manufacturer on customs law origin marking requirements and Trade Agreements Act domestic content rules.
Advised U.S. manufacturer on Federal Transit Administration Buy America requirements associated with components, subcomponents and manufacturing processes.
Represented a manufacturer in obtaining CBP ruling that a remanufactured product could be considered substantially transformed in the U.S. and therefore eligible for sale to federal agencies.
Assisted a global manufacturer in evaluating the potential effect of free trade agreements on the relative costs of building a new factory in Asia.
Assisted a global security solutions company in reviewing the country of origin of its products related to Buy America, Buy American and Trade Agreement Act Compliance.
Advised metal components manufacturer on compliance with Recovery Act domestic content requirements of the Environmental Protection Agency (EPA).
Advised computer manufacturer on CBP requests for information and notice of action related to imports involving Section 301 tariff exclusions, and obtained impactful adjustments to those exclusions after engagement with the U.S. Trade Representative.
Advised commercial manufacturer on regulatory issues arising from inadvertent importation of radioactive products.
Assist U.S. semiconductor company with participation in Importer Self-Assessment program, including site visits by CBP and C-TPAT verification audits.
Assisted U.S. electronics company in applying for country-of-origin rulings (COOL) on whether products are eligible to be purchased by U.S. federal agencies under the origin restrictions of the Trade Agreements Act.
Developed Lacey Act compliance program for telecommunications company seeking to source wood materials for its products and import these products into the U.S.
Advised technology company on duty rates and taxes applicable in various countries for relevant products.