Lawyers with extensive experience in Uyghur Forced Labor Prevention Act detentions said that CBP processes have been changing, and that companies should stress test how quickly they can get documents about materials from their suppliers and suppliers' suppliers, and how quickly they can understand all they've been given and send the right documents to CBP.

Crowell & Moring partner David Stepp, a trade expert in the Los Angeles office, said that he and other trade lawyers have been hearing rumors about how the Trump administration will define "transshipment" in its reciprocal trade agreements. He said the rumor is that details will be released "in coming days."

EU Trade Minister Maros Sefcovic said that the EU "will need to translate key elements of the joint statement into legislative proposals," and that politicians have a "firm intention" to "present these legislative proposals and launch this process still this month."

Businesses should anticipate that even more derivative products could be added to the list of Section 232 tariffs for steel and aluminum (see 2508150063), Flexport senior trade advisory manager Anna Zajac said during an Aug. 20 company webinar on the tariffs.

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The Forced Labor Enforcement Task Force will be scrutinizing five additional sectors for forced labor violations: caustic soda, copper, jujubes, lithium and steel, according to an Aug. 19 DHS report.

CBP released another ruling in which the agency denied a party's request to use first sale appraisement in determining transaction value because the agency deemed there was insufficient evidence to grant this usage.

Some companies and associations in the solar industry endorsed additional tariffs on Chinese polysilicon, but others expressed concern that allied countries will be hit with overlapping Section 232 tariffs on both imports of polysilicon and solar cells, in public comments to the Bureau of Industry and Security.

Section 232 tariffs on steel and aluminum derivatives, currently set at 50%, will cover 407 additional Harmonized Tariff Schedule subheadings beginning at 12:01 a.m. on Aug. 18, the Commerce Department said in a notice released late on Aug. 15. The notice includes no exception for goods in transit as of the effective date.

CBP ruled an importer didn't provide enough documentation to qualify for first sale treatment, and that the middleman couldn't be considered a buying agent, either, because its relationship with the importer was a buyer/seller relationship.