Those of us in the business of global trade compliance are well aware of the increased attention in recent years to the issue of forced labor. This is not a new problem, but incidents in recent years with well-known brands, coupled with new legislation designed to curb behavior of this type, has increased the importance of supplier due diligence for those operating in global markets.

On January 31, 2019, the U.S. Office of Foreign Assets Control (OFAC) issued its first fine to e.l.f. Cosmetics for violating the Countering America’s Adversaries Through Sanctions Act (CAATSA), as it applies to North Korean labor under the North Korean Sanctions Regulations (NKSR).  The initial statutory maximum civil monetary penalty amount for the apparent violations was US$40,833,633. This enforcement action indicates that government agencies are watching closely for violations of this nature.

The G-20 summit concluded in Buenos Aires on December 1 and brought relief to Chinese and American importers as the leaders from both nations mutually agreed to halt new trade tariffs for 90 days.

The press release issued by the White House reads that on January 1, 2019, tariffs on $200 billion worth of imported Chinese products will not be raised to 25% from the existing 10%, as was initially announced by the United States. In return, China agreed to purchase a substantial amount of agricultural, industrial, and energy products from the U.S., though the exact amount has yet to be agreed upon. This ceasefire aims to reduce the trade conflict that has steadily escalated in the recent months between the two countries.

On November 9, Integration Point Director of the Greater China Region, Steve Tian, spoke at the 2018 ICPA China Conference in Shanghai. At the conference, Steve presented on “New Regulation and Implementation of China Pre-Ruling.”

The presentation detailed the basic requirements of the advanced ruling application for the import and export of Chinese goods. The advance rulings system for goods classification in China was first adopted in 2000 as a temporary measure, and was officially adopted in 2007, according to the World Customs Journal. Under the advanced ruling system, the importer/exporter can apply to a regional customs office for an advance ruling for the goods that they intend to import/export up to 45 days before the intended movement date.