This bulletin has been prepared especially for clients of A. N. Deringer, Inc. by:

 

SERKO SIMON GLUCK & KANE LLP – Customs & International Trade Law

 

January 4, 2007

 

CUSTOMS and BORDER PROTECTION (CBP)

 

  • Vietnam 2007 Quota Announced:  The U.S. Committee for the Implementation of Textile Agreements (CITA) announced the 2007 import limits for Vietnamese textiles and apparel.  Although import limits will be lifted once Vietnam officially becomes a World Trade Organization (WTO) member on January 11, 2007, exports prior to that date are subject to quota, visa, and ELVIS requirements.
  • Ukraine Quota Suspended:  As the bilateral textile agreement between the U.S. and Ukraine expired on December 31, 2006, textile exports are no longer subject to quota and visa requirements.  However, quotas may be reinstated should the two countries agree to extend their bilateral textile agreement at a future date.
  • Certain Products to Lose GSP Eligibility:  Certain products that are currently eligible for preferential treatment under the Generalized System of Preferences (GSP), and have reached their Competitive Need Limitations (CNL), may lose their GSP eligibility from July 1, 2007.  Under the current GSP program, if a product has reached its CNL, i.e., if imports of a particular product from a specific country are either more than $125 million or exceed 50% of total U.S. imports of that product, the President may waive the CNL restrictions to allow continued GSP benefits.  However, under recently signed legislation extending the GSP program, the President will be required to revoke these waivers when in effect for at least five years if the product from a specific country exceeds 150% of the annual trade cap or compromises 75% of all U.S. imports of that product.  The U.S. Trade Representative (USTR) preliminary listed the following products/countries which may be subject to these limitations: 1) brakes, brake pads, and ferrozirconium from Brazil; 2) kola nuts from Cote d’Ivoire; 3) gold jewelry and brass lamps from India; 4) gold jewelry from Thailand; 5) wiring harnesses from Philippines; and 6) methanol from Venezuela.  The USTR will publish the final list in February.

 

TRADE TALK

 

·         Free Trade Developments: 

Panama – The U.S. and Panama recently completed negotiations for a free trade agreement (FTA), subject to further negotiations with regard to labor details.  More than 88% of U.S. exports will enjoy duty free treatment as soon as the FTA comes into effect with most of the remainder being phased in over a 10-year period.  

Additional AGOA Benefits – CITA announced that certain handmade, handloomed, and folklore articles from Niger (from January 3, 2007), Tanzania (from January 10, 2007), and Mali (from January 16, 2007) will enjoy additional preferential duty free treatment under the African Growth and Opportunity Act (AGOA).

·         Fair Trade Developments:  The U.S. Commerce Department recently took the following action:

Coated Free Sheet Paper – Preliminarily found that coated free sheet paper from China, Indonesia, and Korea are being sold at less than fair value in the U.S. and are injuring domestic producers.

Polyester Staple Fiber – Preliminarily determined that certain polyester staple fiber is being sold at less than fair value in the U.S. and assessed an AD rate of between 4.39% and 44.3% (China-wide).

·         Comments Sought on Applying CV Duties on Non-market Economies:  Following the filing of a CVD case on coated free sheet paper from China, the first CVD case filed on Chinese goods in 15 years, the U.S. International Trade Administration (ITA) is             seeking public comments by January 16, 2007 on whether it should alter its current policy of not applying CVD duties on non-market economies such as China and India.

 

WORLD TRADE ORGANIZATION (WTO)

 

  • Vietnam: Vietnam is scheduled to become the WTO’s 150th member on January 11, 2007.  
  • “Zeroing” Calculations:  The ITA announced that following a WTO Dispute Settlement Body finding against “zeroing” calculations, it is changing the methodology it uses when calculating the weighted average dumping margin in certain AD investigations.  In certain investigations, it will use offsets for non-dumped exports when making average to average comparisons. 

In a related note, the U.S. Trade Representative (USTR) is seeking comments by February 28, 2007 on a complaint filed by Mexico at the WTO against the U.S. practice of “zeroing” in general, and specifically, its use during the AD investigation of stainless steel sheet and strip coils from Mexico.   

 

  BUSINESS BRIEFS

 

·         China Trade Developments: 

Currency Exchange Rate – In its latest semi-annual report to Congress, the U.S. Treasury Department declined to name any country, including China, as a currency manipulator.  While acknowledging the continued trade distortions that the artificially low value of the Yuan has on U.S. trade, the Treasury Department noted the cautious approach China is taking to liberalize trade in the Yuan.  During the recent visit to China by the U.S. Treasury Secretary, Chinese authorities reiterated their intent to liberalize the Yuan’s exchange rate but did not set forth any             concrete commitments.

China Trading Policy – Two recently released reports, the U.S.-China Economic and Security             Review Commission and the USTR’s annual report to Congress on China’s WTO commitments, were both critical of China’s trade policies and belated commitments to its WTO requirements.  The U.S.-China Economic Commission report focused, among others, on China’s woeful enforcement of intellectual property rights (IPR), the huge counterfeiting problem across many different categories, and the apparent failure of the current export control regime to stop China             from acquiring military capabilities.  The USTR’s report focused on IPR enforcement, China’s favoring of domestic businesses, regulatory intervention in the agricultural market, and lack of transparency regarding the publishing of trade related laws. The reports can be viewed at: http://www.ustr.gov/assets/Document_Library/Reports_Publications/2006/asset_upload_file688_10223.pdf and  http://www.uscc.gov/annual_report/2006/06_annual_report.php .

 

LEGISLATIVE DEVELOPMENTS

 

·         Wool Labeling Fairness Act:  The U.S. Senate recently passed the Wool Suit Fabric Labeling Fairness and International Standards Conforming Act (H.R. 4583) establishing a   

            legal standard for the labeling of wool and cashmere products and adopting international standards for “superfine” wool designations. 

 

COURT CASES

 

·         Improper NAFTA Claim Ends in Default Judgment:  In United States v. Jean Roberts of California, Inc., the U.S. Court of International Trade (CIT) entered a judgment by default in favor of the U.S. to recover civil penalties amounting to $242,375.46, twice the amount of the loss of duties, for the alleged negligence in claiming NAFTA preferential treatment when the imported merchandise did not qualify for such treatment.  Importer claimed NAFTA duty free treatment for woven blankets when in fact the blankets were knitted and not eligible for duty free treatment.  Judgment by default was entered in favor of the government after the importer failed to secure representation by counsel as entreated by the CIT.      

·         No Trademark Protection for In-transit Goods in the EU:  The European Court of Justice (ECJ) recently ruled that trademark protection can not be invoked over goods in transit through a country if there is no risk that the goods will actually be marketed in that country.  The case arose after an importer shipped trademarked goods from Poland to Ireland through Germany.  The German authorities seized the goods while they were passing through their territory after receiving a complaint from a German company which owned the trademark in Germany.  The Irish importer owned the same trademark in Ireland, the ultimate destination of the goods.  After a German court found in favor of the German trademark owner, the Irish importer appealed, and the German court requested clarification from the ECJ.  The ECJ ruled that it is irrelevant whether the goods actually infringed on a protected trademark, as long as there is no chance that the goods will be sold in that territory, it was in transit and protected from removal by a customs seal, they can not be seized for trademark infringement.  

 

Serko Simon Gluck & Kane LLP
1700 Broadway, 31st Floor
New York, New York 10019
Phone (212) 775-005 Fax (212) 839-9103
Outside of New York State: 1-800-46-TRADE
E-mail address:
serko-simon@customs-law.com On the internet at: www.customs-law.com

 

Note:  This information is current as of the date of this document, and is not, nor is it intended to be, legal advice, which can only be provided by Serko Simon Gluck &Kane LLP on a case-by-case basis. ©2007