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GOODS REQUIRING SPECIAL CARE

Textiles | Steel | Food | Dairy | Products Subject to Trade Actions

Textiles

A product sector which has been subject to a significant level of scrutiny for many years is textiles and apparel.  In addition to high duties, importation into the U.S. of textiles has been subject to quotas and restrictions.  While international agreements entered into by the United States are to eliminate quotas beginning in 2005, the U.S. textile and apparel industry, which maintains a strong anti-import stance, is aggressively fighting for new restrictions.

In addition to restrictions, textile and apparel importations are also subject to other controls such as fiber content, labeling, country-of-origin labeling, manufacturer identification labeling, fabric care labeling requirements and various inflammability standards and warnings. 

Steel

The United States steel industry and related heavy industries (bearings, silicon metal, etc.) have been very aggressive for many years in seeking to insulate the domestic industry, and to a lesser extent their Canadian and Mexican subsidiaries, from import competition.  A broad range of trade related actions have been used from Congressional legislation imposing controls and other restrictions, to formal unfair trade actions (antidumping and the like) and safeguard actions.  As a result, importation of these products can be subject to duties, quotas or other restrictions at varying times.  Such importations are also often subject to enhanced documentary requirements.  Anyone in these industries should take extra precautions.

Food

The Food & Drug Administration (FDA) and the U.S. Department of Agriculture (USDA) jointly regulate importations of food products into the United States.  The USDA regulates meat products and related items, while the FDA regulates most other food products.  The specific regulations are in large part product specific. However, many FDA requirements have near universal application including food nutrition labeling requirements, food information labeling and food phyto-sanitary requirements.  Importers of food products and foreign manufacturers of food products should make sure that they are aware of all issues that face their specific market sector.

Dairy

Dairy products, which are a subset of food products, are considered of great importance to the United States. They are subject to political pressure from powerful domestic dairy interests. Dairy products are subject to tariff rate quotas and safeguards.  These can result in the imposition of additional high tariffs in the event that certain pricing or volume levels are reached.  As with any product subject to restrictions, importers of dairy products must exercise caution and constantly monitor the dairy restrictions. 

Products Subject to Trade Actions

A wide range of products have been subject to trade restrictions, ranging from industrial products such as steel and other base materials to consumer products such as crepe paper.  The list of products subject to trade actions is constantly changing.  If a product being imported falls under a trade restriction, special care is required.  Due to the changing nature of sanctions, it is wise to have trade counsel that is aware of your full range of products and to have that trade counsel prepared to represent you in the event that your product is named in a trade action.  RIGGLE & CRAVEN can notify you if a product sector of interest to you becomes subject to an action.  Simply provide the list of products and your contact information in the link above.  If an action is brought, you will be notified.