2024: A Year in Review | Customs & International Trade Law Blog

As we wrap up this extraordinary 12 months, we need to take a second to thanks on your belief, collaboration, and assist. This 12 months was marked by important milestones and significant accomplishments, together with saving our purchasers MILLIONS of {dollars}.

We stay up for working with you in 2025! 

Prime 2024 Success Tales

Assisted Quite a few Importers in Submitting Prior Disclosures

Diaz Commerce Regulation submitted quite a few prior disclosures to CBP on behalf purchasers. CBP thought-about the admission of the false statements made on the time of entry as violations of Title 19, United States Code, Part 1592. Nevertheless, Diaz Commerce Regulation’s declare for prior disclosure therapy was profitable and no additional penalty was assessed by CBP.

 Binding Ruling Requests

An importer of sports activities tools retained Diaz Commerce Regulation to submit a binding ruling request to CBP. We drafted a persuasive binding ruling request and CBP agreed with our classification and issued a binding ruling reflecting the proposed HTS classification.
Diaz Commerce Regulation requested a binding ruling on behalf of our shopper on a valuation-related inquiry. CBP agreed with our evaluation and offered a binding ruling agreeing that transaction worth was a suitable system and any changes to that worth will be made through reconciliation.

 CPSC, EPA, and FDA Detention Help

The U.S. Shopper Product Security Fee (CPSC) detained our shopper’s imported items. CPSC discovered the products to be violative and advisable Diaz Commerce Regulation reviewed the case and acquired authorization from CBP to recondition the products. CPSC launched the products saving our shopper from an pointless and dear seizure.
The EPA detained our shopper’s pesticides meant for export, requesting affirmation of compliance with EPA laws. Diaz Commerce Regulation promptly reviewed the entry documentation and product label and submitted an in depth letter to EPA, asserting the import label and the cargo complied with EPA laws. Inside lower than per week, EPA reviewed our letter and altered the standing of the entry to “Might Proceed,” ensuing within the launch of the products for exportation.
The EPA detained our shopper’s cargo, requesting affirmation of compliance with EPA laws (particularly 40 CFR 152.30). The cargo consisted of pesticides meant solely for export. Diaz Commerce Regulation promptly reviewed the entry documentation and submitted an in depth letter to EPA to make clear the cargo’s compliance with EPA laws. Inside lower than per week, EPA reviewed our letter and altered the standing of the entry to “Might Proceed,” ensuing within the launch of the products.
Our shopper’s flavored oral rehydration drinks have been listed on FDA’s Import Alert Checklist, subjecting all importations into the U.S. to Detention With out Bodily Examination (DWPE). On October 27, Diaz Commerce Regulation submitted a request for removing from the Import Alert Checklist and on November 8, FDA responded agreeing with our request, eradicating our shopper’s product from the Import Alert Checklist. Future importations are not topic to DWPE.

Efficiently Assisted Quite a few Importers in Numerous Seizure Circumstances

CBP seized our shopper’s high-value watches. Diaz Commerce Regulation filed a profitable Petition and CBP agreed to remit the forfeiture, securing the discharge of the property valued at $208,001!
Merchandise meant for export out of the U.S. was seized by U.S. Customs with an allegation that our shopper did not get hold of a BIS license which was required for exportation out of the U.S. Diaz Commerce Regulation filed a profitable Petition, confirming a BIS license was not in actual fact required for the topic export, and CBP agreed to launch the seized merchandise with no penalties assessed.

Efficiently Mitigated Penalty Actions

CBP assessed a penalty alleging a wooden packing materials violation. Diaz Commerce Regulation filed a profitable petition, and CBP in the end mitigated the penalty from $59,862.00 to $1,795.86 (3% of the unique penalty quantity) – saving our shopper $58,066.14!
Diaz Commerce Regulation scored a profitable win for his or her shopper! CBP mitigated a penalty from $44,145.34 to $8,829.07 (20% of the unique quantity)!
Inside someday of being retained to help with penalties assessed in 2021, Diaz Commerce Regulation was capable of successfully talk with CBP and get CBP to rescind a requirement letter and as a substitute present the requested mitigation, decreasing the penalty quantities from $28,388 to $1,000, an unprecedented outcome!
CBP mitigated a penalty from $16,438.00 all the way down to $500 – saving our shopper $15,938.00!
CBP issued a penalty within the quantity of $16,438 to our shopper alleging violations of Title 13 U.S.C. 305(b), 15 C.F.R. 30.71(b)(3), 30.26, 30.6, and 6.3(d). Diaz Commerce Regulation submitted a profitable petition, and CBP in the end mitigated the penalty all the way down to $1,000, saving our shopper $15,438.

 Efficiently Mitigated Liquidated Damages Claims 

CBP assessed two Liquidated Damages claims ($50k every) towards our shopper. Diaz Commerce Regulation filed a profitable petition and CBP agreed to cancel the claims, saving our shopper $100,000!
Diaz Commerce Regulation’s shopper acquired a Liquidated Damages declare within the quantity of $100,000. Diaz Commerce Regulation filed a petition with CBP discussing all related mitigating elements which CBP took into consideration and in the end mitigated the declare down 90%, saving our shopper $90,000!
CBP issued a $50,000 Liquidated Damages declare towards our shopper alleging violations of 19 CFR 142.12, 19 CFR 113.62(b), and 19 CFR 113.62(n)(1). Diaz Commerce Regulation filed a Petition asserting that cancellation was warranted. After evaluate, CBP decided that cancellation was warranted, and the case was efficiently closed!
CBP assessed a Liquidated Damages declare towards our shopper within the quantity of $50,000. Our shopper tried to hunt mitigation from CBP by submitting their very own Petition, after which got here to Diaz Commerce Regulation for help in submitting a supplemental petition after they have been unsuccessful. After our profitable supplemental petition, CBP mitigated the Liq Dam from $50,000.00 to $3,840.00 (about 8% of the unique quantity) – saving our shopper $46,160.00!
CBP assessed a Liquidated Damages declare towards our shopper. Diaz Commerce Regulation filed a profitable petition and CBP agreed to cancel the declare!
CBP assessed a Liquidated Damages declare towards our shopper. Diaz Commerce Regulation filed a profitable petition and CBP agreed to cancel the declare, saving our shopper $23,560.54.
CBP issued a $22,680 Liquidated Damages declare towards our shopper alleging the failure to re-deliver FDA refused merchandise. Diaz Commerce Regulation filed a profitable Petition and CBP determined to mitigate the declare all the way down to $226.80, (1% of the unique declare quantity)!
CBP issued a $10,000 Liquidated Damages declare towards our shopper alleging violations of 19 CFR 19.12(d)(4)(ii), 113.63(a)(3), and 113.63(j)(3). Diaz Commerce Regulation filed a Petition asserting that reduction was warranted attributable to clerical errors and the shopper’s sturdy compliance historical past. After evaluate, CBP agreed and diminished the declare all the way down to $1,500, saving our shopper $8,500!
CBP Safety issued a $5,000 Liquidated Damages declare towards our shopper alleging a late ISF (Importer Safety Submitting) in violation of 19 C.F.R. § 113.62(j). Diaz Commerce Regulation efficiently filed a Petition, and CBP granted mitigation, decreasing the declare all the way down to $1,000!

 Export Compliance and Enforcement Mitigation Help

A shopper requested help on reviewing a potential export to Cuba. Diaz Commerce Regulation reviewed the transaction and decided each a BIS license and OFAC particular license have been needed. We filed an export license utility through SNAP-R with the Bureau of Trade and Safety (“BIS”), in addition to a particular license utility with the Workplace of International Belongings Management (“OFAC”). Each BIS and OFAC issued their respective licenses authorizing our shopper to legally transaction enterprise with Cuba.
A shopper needed help making certain it complied with U.S. legal guidelines when exporting sure gadgets to Cuba and receiving cost for a similar. Diaz Commerce Regulation efficiently assisted in performing the requisite export compliance evaluation and submitted two BIS export license purposes (which BIS validated) and an OFAC particular license request (requesting and receiving written affirmation from OFAC that the transaction was, in actual fact, compliant).

CBP 28/29/Protest Help

CBP issued a Discover of Motion (CBP Type 29) confirming the origin of our shopper’s jewellery beneath the Jordan Free Commerce Settlement (JOFTA). Diaz Commerce Regulation efficiently assisted our shopper in securing a optimistic dedication from CBP that the jewellery qualifies as an originating good beneath Chapter 71.
CBP despatched our shopper a Discover of Motion (CBP Type 29) to confirm the origin of our shopper’s imported items and eligibility of the Chile Free Commerce Settlement (CLFTA). Diaz Commerce Regulation submitted a response offering the CLFTA eligibility and origin, and CBP agreed – leading to a closeout and liquidation of the entry as entered.

CBP despatched our shopper a invoice claiming antidumping and countervailing duties (AD/CVD) have been owed on our shopper’s imported Chinese language items. Diaz Commerce Regulation filed a profitable protest asserting the products have been in actual fact excluded from the AD/CVD scope and no duties have been in actual fact owed. CBP agreed with our protest – saving our shopper 1000’s!
Diaz Commerce Regulation efficiently filed a protest with CBP on behalf of our shopper asserting that countervailing duties (CVD) had been improperly collected primarily based on a last dedication by the Division of Commerce of a 0% subsidy price for the imported items and ought to be refunded to our shopper. CBP agreed to refund the full quantity of $52,280.28 in CVD paid!
Diaz Commerce Regulation efficiently assisted our shopper in submitting a Protest with CBP alleging the right info and rationale as to why entries have been filed as Kind 1 (consumption) and never Kind 3 (AD/CVD). CBP accredited our protest saving our shopper from paying any improperly price superior AD/CVD!
CBP price superior our purchasers entries claiming that AD/CVD have been owed and despatched our shopper a invoice. Diaz Commerce Regulation filed a profitable protest and, upon additional evaluate, CBP agreed that AD/CVD was not relevant and cancelled the invoice at situation – saving our shopper 1000’s!
Our shopper acquired a invoice from CBP price advancing an entry alleging antidumping and countervailing duties (AD/CVD), and Part 301 duties utilized to the entry. Diaz Commerce Regulation efficiently assisted out shopper in submitting a Protest with CBP alleging the right info and rationale as to why the AD/CVD and Part 301 have been appropriately omitted from the unique entry. CBP agreed with our protest cancelling the invoice at situation, saving our shopper over $175,000!

 Antidumping and Countervailing Obligation (AD/CVD)

Diaz Commerce Regulation filed a Scope Ruling on behalf of our shopper and the DOC agreed with our request and located our purchasers product was rightfully outdoors of the AD/CVD Scope.
Diaz Commerce Regulation requested a scope ruling for our shopper’s crushed glass floor merchandise. The U.S. Division of Commerce confirmed our shopper’s merchandise didn’t fall inside the scope of the AD/CVD order.
Diaz Commerce Regulation’s shopper imported roughly 30 entries which CBP rejected, claiming they have been topic to antidumping and countervailing (AD/CVD) duties and will have entered beneath “entry sort 3” not entry sort 1. The shipments’ complete worth exceeded $2 million. We argued that CBP wrongfully rejected the entries and so they have been rightfully sort 1 (not topic to AD/CVD duties).  After reviewing our arguments, CBP agreed that AD/CVD duties should not relevant, and rescinded its rejection of the entries, reverting them again to entry sort 1, and saving our shopper a whole bunch of 1000’s of {dollars}.
Diaz Commerce Regulation’s shopper imported 3 entries which CBP rejected, claiming they have been topic to antidumping and countervailing (AD/CVD) duties and will have entered beneath “entry sort 3” not entry sort 1. Whereas the shipments’ complete worth was solely about $45,000, the full assessed AD/CVD duties have been over $300,000. We argued that CBP wrongfully rejected the entries and so they have been rightfully sort 1 (not topic to AD/CVD duties). After reviewing our arguments, CBP agreed that AD/CVD duties should not relevant, and rescinded its rejection of the entries, reverting them again to entry sort 1, and saving our shopper a whole bunch of 1000’s of {dollars}.

 Courtroom Challenges

In a major victory, our agency efficiently challenged the USA Division of Commerce’s last scope ruling on composite tile, resulting in a remand by the USA Courtroom of Worldwide Commerce. The DOC scope ruling was discovered to be unsupported by substantial proof and never in accordance with the legislation.

Publications & Articles

Clock Ticking: Potential Authorities Shutdown on the Horizon, December 2024
CPSC Approves Closing Rule to Implement eFiling for Certificates of Compliance, December 2024
Commerce Information: New AD/CVD Case Filed on Lively Anode Materials from China, December 2024
Commerce Information: New AD/CVD Case Filed on Erythritol from China, December 2024
USTR Declares Part 301 Investigation into Nicaragua’s Acts, Insurance policies, and Practices Associated to Labor Rights, Human Rights, and the Rule of Regulation, December 2024
Case Replace: Investigation of Aluminum Extrusions from China, Colombia, Ecuador, India, Indonesia, Italy, Malaysia, Mexico, South Korea, Taiwan, Thailand, Turkey, United Arab Emirates, and Vietnam, December 2024
CPSC’s Upcoming eFiling Requirement: What You Have to Know, November 2024
ITC Terminates AD/CVD Investigation of Aluminum Extrusions from China, Colombia, Ecuador, India, Indonesia, Italy, Malaysia, Mexico, South Korea, Taiwan, Thailand, Turkey, United Arab Emirates, and Vietnam, November 2024
What Occurred This Month in Worldwide Commerce – November, November 2024
Commerce Information: AD/CVD Petition Filed In opposition to Sol Gel Alumina-Primarily based Ceramic Abrasive Grains from China, November 2024
CPSC Points New Security Requirements for Aquatic Toys, November 2024
BIS Releases New Version of “Don’t Let This Occur to You”, November 2024
Navigating Tariff Will increase: Methods to Reduce Tariff Prices Beneath the Trump Administration, November 2024
CBP Points Steering on Soften and Pour Necessities for Metal Articles, November 2024
Census Proposes Adjustments to International Commerce Rules Submitting Necessities, November 2024
ICYMI: USTR Opens Exclusion Course of for Home Manufacturing Equipment, October 2024
Reminder: Itemizing of OTC Monograph Drug Merchandise No Longer Certifiable by means of Outdated Classes within the FDA’s Itemizing System, October 2024
BIS Points Steering to Monetary Establishments on Greatest Practices for Compliance with the Export Administration Rules, October 2024
ICYMI: G7 Points Steering on Stopping Evasion of Export Controls and Sanctions Imposed on Russia, October 2024
Bloomberg Regulation, CBP Recordkeeping Necessities – Retention, the (a)(1)(A) Checklist, and Extra, September 2024
BIS Points Closing Rule on VSD Insurance policies and Penalty Tips, September 2024
FDA’s Proposed New Nationwide Drug Code – What You Have to Know, September 2024
USTR Finalizes Motion on 301 Tariffs, September 2024
BIS Points New Tips for Getting ready Export License Functions Involving International Individuals (Deemed Exports/Reexports), September 2024
ICYMI: State Division Reaches $200M Settlement with RTX Company for Export Violations, September 2024
Reminder: New Part 232 Duties on Sure Metal and Aluminum Merchandise from Mexico, September 2024
Commerce Information: New AD/CVD Petition Filed In opposition to Sure Corrosion Resistant Metal Merchandise from Australia, Brazil, Canada, Mexico, Netherlands, South Africa, Taiwan, Turkey, the United Arab Emirates, and Vietnam, September 2024
CPSC to Start Voluntary Stage of eFiling, August 2024
7 Suggestions for Submitting a Prior Disclosure with CBP, August 2024
ICYMI: Courtroom of Worldwide Commerce Tells Commerce to Confirm Exporter’s Nonuse of China’s EBCP, August 2024
S. Division of Treasury Publishes New Web site Clarifying CFIUS Penalties and Different Enforcement Actions, August 2024
The Positive Line Between Transshipment and Substantial Transformation, July 2024
Commerce Information: New Petition Filed In opposition to Tungsten Shot from China, July 2024
DHS Declares New Excessive Precedence Sectors for UFLPA Enforcement, July 2024
ICYMI: Supreme Courtroom Overturns Landmark Chevron Case, July 2024
ICYMI: BIS Updates Boycott Requester Checklist, July 2024
Commerce Information: New Petition Filed In opposition to Low Velocity Private Transportation Automobiles from China, June 2024
ICYMI: Congress Doubles the Statute of Limitations for Sanctions Violations, June 2024
Commerce Information: New AD/CVD Case Filed on Brake Drums from China and Turkey, June 2024
MoCRA Enforcement is Proper Across the Nook! Are You Prepared?, June 2024
Cuba Coverage Shift: Administration Eases Restrictions on Small Companies, Might 2024
Commerce Information: New Antidumping Case Filed In opposition to Disposable Aluminum Containers, Pans and Trays from China, Might 2024
White Home Declares Additional Part 301 Tariff Hikes on Chinese language Items, Might 2024
ICYMI: Commerce Information – New Petition Filed In opposition to Tile Producers from India, April 2024
Commerce Information: New Petition Filed In opposition to Photo voltaic Cells and Modules from Cambodia, Malaysia, Thailand, and Vietnam, April 2024
Organizations Urge State Division to Cease Avocado Imports Linked to Deforestation, April 2024
Commerce Information: New Petition Filed on Alkyl Phosphate Esters from China, April 2024
From Chaos to Compliance: A Information for Importers, April 2019
The Enviornment of EAPA: Transshipping, Pencils, and Evading Duties, April 2024
FDA Unveils Searchable Tobacco Merchandise Database to Bolster Compliance and Transparency, April 2024
UFLPA Enforcement Replace, March 2024
Breaking Commerce Information: New AD and CVD Petition Filed on 2,4-Dichlorophenoxyacetic Acid from China and India, March 2024
Ford Motor Firm Settles Claims Referring to Beneath-Valued Automobiles for $365M, March 2024
Clothes Wholesaler Government Avoids Paying Tens of millions in Duties – Sentenced to 4 Years in Jail, March 2024
ICYMI: Commerce, Treasury, and Justice Concern Compliance Observe on Obligations of International-Primarily based Individuals to Adjust to U.S. Export Legal guidelines, March 2024
Updates to CBP’s World Enterprise Identifier Check, February 2024
Know Your Provide Chain: Pressured Labor, February 2024
Breaking Commerce Information: New AD and CVD Petition Filed on Paper Plates from China, Vietnam and Thailand, January 2024
Authorities Shutdown Prevented Once more, January 2024
Upcoming Deadline to File Feedback: USTRs Part 301 China Tariff Exclusions Continuing, January 2024
Commerce Information: New Petition Filed on Glass Wine Bottles from China, Mexico and Chile, January 2024
Bloomberg Regulation, BIS Regulatory Updates: 2023 Vital Adjustments, January 2024

 Custom-made Coaching Applications & Webinars

North Miami, FL, Beth Moshe Congregation, Moderator, Past the Name: Challenges & Triumphs of Search and Rescue, December 18, 2024.
North Miami, FL, Beth Moshe Congregation, Moderator, We Will Dance Once more Screening | Let’s Do One thing Q&A, November 14, 2024.
Fort Lauderdale, FL, FITCE, “Importing into the U.S.,” October 23, 2024.
Webinar, FCBF, “Customs Bonds & Compliance Trending Subjects,” October 16, 2024.
Aventura, FL, FLN Chapter Speaker – AD/CVD & CBP Undervaluation Primer, September 27, 2024
Webinar, FCBF, Moderator, “Study to Navigate the Modernized ACE Portal and Studies Like a Professional,” September 25, 2024
Webinar, MSI, Navigating World Markets: Tax, Commerce, and Funding Methods, September 19, 2024
Miami, FL, Meals and Beverage Present, “Prime 10 Suggestions When Importing Meals into the U.S.,” September 17, 2024
Webinar, FCBF, Moderator, “The way to Be a Revenue Hero By way of Obligation Disadvantage & Foreign money Optimization”, August 7, 2024
Chicago, IL, GTEC, “CBP Varieties 28/29s, Put up Abstract Corrections & Prior Disclosures”, July 30, 2024
Webinar, Content material Enablers, Skilled Ways for Dealing with CBP Type 28s, 29s, and Prior Disclosures, July 18, 2024
FIU, Disruptive Expertise Strike Pressure: Southern Florida Outreach, “Constructing A Commerce Compliance Program,” June 27, 2024
Webinar, FCBF, “Reworking Commerce Compliance: From Ai Fundamentals to AI-Powered Effectivity,” June 26, 2024
Webinar, The World Chamber, “Commerce Knowledge for the Caribbean Market,” June 25, 2024
Reside Coaching, Navigating CBP Rules – Important Practices for Import Success, Might 23, 2024
Webinar, False Claims Act, Might 9, 2024
Webinar, World Chamber, SBPI Companies, Inc. Occasion: Import Export Discussion board (World Chamber), April 25, 2024
Webinar, FCBF, FMC, Leveraging AI in Small Enterprise, April 24, 2024
Webinar, World Chamber, Digital League of Alternatives, “Sizzling Subjects in Customs and Commerce,” April 19, 2024
Webinar, Mondaq, Sizzling Subjects in Commerce, March 12, 2024
Webinar, FCBF, The way to Digitize your Operations and Ship a Related Buyer Expertise, March 6, 2024
Webinar, MedMarc, Greatest Observe to Navigate FDA Enforcement Actions, February 14, 2024
Houston, TX, Deleon Commerce Convention, IPR: Leveraging CBP as A part of your Model Safety Plan and the E-allegation Course of, February 9, 2024
Tampa Bay, FL, FCBF, Navigating 2024: CBP, CPSC, and PGA Developments You Can’t Miss, January 31, 2024
Diaz Commerce Regulation Webinar, Getting MoCRA Compliant, January 24, 2024

Awards

2025, Diaz Commerce Regulation Ranked in 2nd Version of the Chambers Florida Highlight Information 2025 for Worldwide Commerce
2012-2025, AV Rated, Martindale-Hubbell
2016-2024, Tremendous Legal professionals Checklist, “Prime Worldwide Legal professional”
2024, Nominee, St. Thomas Authorized Luminaries

Diaz Commerce Regulation values you and appreciates your belief in us to be your Customs and Worldwide Commerce Regulation Skilled!