April 2021

CIT overturns 232 Duties Paid on Steel Derivative Products

On April 5, the Court of International Trade ruled that these duties were illegally assessed on the importer who brought this action and ordered that entries with the Section 232 duties paid by the importer on its derivative steel products: (i) be liquidated without the assessment of duties if they are still pending; and (ii) be refunded if such duties have already been collected and liquidated. Several customs attorneys suggest that the basis for this decision, that the  Government did not issue its Section 232 Proclamation timely, applies to aluminum derivative products as well.  If you imported steel or aluminum derivative products since January 24, 2020, and paid the Section 232 duties, you should contact your customs attorney immediately.  If you do not have a competent customs attorney, we would be glad to refer you to several that we can recommend.

Reminder:  Rates for all modes of shipping at all time highs

ALL modes of transport plus warehousing are at or near all-time highs right now, and most knowledgeable sources available to us tell us not expect them to ease until at least late Summer or early Fall. One usually reliable source claims air freight rates will be elevated for 3 years because airlines are still trimming passenger flights that usually carry cargo in their belly compartments. Ocean freight rates from Asia to Europe are up 155 percent!

Port congestion at all major ports & gateways

Port congestion is still being reported at all major ports & gateways, so please plan for delays in receiving your shipments. This will be exacerbated for the next month or so by the blockage of the Suez canal for a week by the grounded Ever Given.

Supply Chain Reviews for Forced Labor Encouraged for All Industries (From Sandler Travis & Rosenberg)

Companies in all industries are being encouraged to conduct reviews of their supply chains as international scrutiny of the use of forced labor intensifies. Sandler, Travis & Rosenberg offers a comprehensive suite of services to help companies address forced labor concerns, including supply chain reviews, due diligence strategies, and proactive remediation. For more info,  please go to