China Origin Labeling to be Required for Imports from Hong Kong, Raising Tariff Concerns (From Sandler, Travis & Rosenberg Trade Report)
U.S. Customs and Border Protection has announced that imported goods produced in Hong Kong will have to be marked to indicate China as their country of origin rather than Hong Kong. CBP is granting importers a 45-day transition period for this change, which will take effect for goods entered or withdrawn from warehouse for consumption on or after Sept. 25.
19 USC 1304 requires articles of foreign origin to be marked so as to indicate to purchasers the country of origin of imported goods. Pursuant to a July 14 executive order, CBP states that it suspending the application of section 201(a) of the U.S.-Hong Kong Policy Act of 1992, under which the U.S. continued to treat Hong Kong as a separate customs territory after it reverted to Chinese control in July 1997, to 19 USC 1304. As a result, goods of Hong Kong will have to be labeled as products of China.
However, this change also raises concerns that goods produced or substantially transformed in Hong Kong will be treated as having originated in China for purposes of the Section 301 tariffs the U.S. currently levies against products of China. This is because CBP generally follows a substantial transformation test to identify the country of origin for purposes of 19 USC 1304. For more info, please go to
Apparel Care Labeling Rule Repeal Has Sept. 21 Comment Deadline
(From Sandler, Travis & Rosenberg Trade Report)
The Federal Trade Commission is accepting comments through Sept. 21 on a proposal to repeal the mandatory care labeling requirements for apparel and certain textile piece goods.
The care labeling rule requires importers and manufacturers of apparel and certain textile piece goods to attach labels with care instructions to their products, including instructions for dry cleaning or washing, bleaching, drying, and ironing. For more info, please go to
Air Freight rates sky high
Demand for PPE, as well as shortages of other commodities such as hand sanitizer, is pushing air freight rates up to levels we have not seen before. Carriers are converting passenger planes into cargo planes, some by removing seats, others by using cargo nets over the seats. This is a result of the “unprecedented times” we are experiencing.
GSP expires Dec 31
A reminder that Generalized Systems of Preference (GSP) expired December 31 this year. Congress historically has reinstated GSP, several times retroactively, but in this political environment, there are no predictions.