Search PillsburyLaw.com
  • All
  • Lawyers
  • Capabilities
  • Insights

Service

Customs Compliance & Enforcement

Contacts

Stephan E. Becker
Partner, Washington, DC
T: +1.202.663.8277
Nancy A. Fischer
Partner, Washington, DC
T: +1.202.663.8965
Christopher R. Wall
Partner, Washington, DC
T: +1.202.663.9250
See All Professionals

Pillsbury’s Customs Compliance team has hands-on experience with customs audits, Customs-Trade Partnership Against Terrorism (C-TPAT) verifications and other customs-related interactions with the U.S. government.

Pillsbury’s experience encompasses virtually every aspect of U.S. customs laws and their administration. Our lawyers advise on tariff classifications, country of origin marking, rules of origin and import valuation (including intra-company transfer pricing) and are highly experienced in interpreting and applying the complex rules of origin that affect international trade.

The firm represents clients in requesting rulings from Customs and Border Protection (CBP) and assists them in designing internal customs compliance programs, handling audit responses and defending clients in seizure, enforcement and penalty proceedings. The firm represents clients in challenges to import duties before the Court of International Trade. Our lawyers also help companies evaluate the impact of international trade agreements and other tariff preference arrangements on their exports and imports, advise on how component-sourcing arrangements can affect price, and assist importer clients in complying with the more stringent responsibilities imposed by customs programs regarding regulatory and import shipment security requirements. We work closely with our clients to make certain they understand these programs thoroughly, including the Importer Self-Assessment program and the C-TPAT. Our team is also experienced in assisting clients through UK and EU customs compliance, customs classification, and country of origin determinations, investigations and voluntary disclosures.

Representative Experience

  • Represented producer of food products in an administrative enforcement action in which CBP alleged that the imports did not comply with the NAFTA rules of origin.
  • Advised solar components manufacturer on compliance with Buy American Act and Trade Agreements Act compliance issues.
  • Successfully appealed to CBP Headquarters a change in tariff classification made at a port, resulting in the cancellation of CBP invoices for $20 million in duties.

View More

  • Energy
    • Advised importer of nuclear material in connection with Customs Notice of Action and response in connection with trade remedy case. Advised on the scope of U.S. requirements for use of domestic vessels in “coastwise trade” of oil under the Jones Act.
    • Conducted internal reviews and prepared prior disclosures to CBP concerning compliance by an energy company with an anti-dumping duty order.
    • Advised group of nuclear utilities on Section 232 investigation on uranium imports, persuading the U.S. government to take no action on petitioners’ import quotas that would have cost utilities $500-800 million per year.
    • Advised petroleum company on compliance issues concerning operations within U.S. foreign trade zones.
    • Represent nuclear engineering and manufacturing company before the Court of International Trade in challenge to import duties on products from China under Section 301 of the Trade Act of 1974.
    • Successfully represented multinational energy corporations in Department of Commerce exclusion requests in connection with Section 232 tariffs on steel.
  • Manufacturing
    • Successfully appealed to CBP Headquarters a change in tariff classification made at a port, resulting in the cancellation of CBP invoices for $20 million in duties.
    • Advised manufacturer of steel products on interplay of U.S. and Canadian origin and tariff rules for products crossing the border multiple times.
    • Successfully advised U.S. and foreign companies in obtaining exclusions from tariffs on products imported from China under Section 301 of the Trade Act of 1974, representing millions of dollars in tariff savings. Clients represent a broad range of industries including artworks, manufacturers of pipe fittings, machinery, computer hardware and supplier of technology, automation, and services.
    • Representing several importers across a wide range of industries before the Court of International Trade in challenge to import duties on products from China under Section 301 of the Trade Act of 1974.
    • Represented U.S. importer in CBP investigations of tariff classification and valuation issues.
    • Assisted U.S. subsidiary of a major foreign manufacturer with a Focused Assessment audit by CBP, including being present for the entire audit.
    • Advised large manufacturer on Harmonized Tariff Schedule (HTS) classification, and prior disclosure, and country of origin issues in connection with imports of steel, rubber and glass construction materials.
    • Represented European crane manufacturer in connection with Department of Commerce Section 232 investigation on mobile cranes, successfully coordinating with U.S. industry members to help achieve termination of the investigation that could have resulted in duties.
    • Advised large manufacturer on Harmonized Tariff Schedule (HTS) classification and prior disclosure issues in connection with imports of steel and glass construction materials.
    • Represented U.S. company in negotiating a settlement with CBP of an enforcement action involving a failure to add the value of “assists” to the value of imported goods.
    • Assisted manufacturing company enrolled in the Importer Self-Assessment program with its annual internal audits.
    • Represented producer of food products in an administrative enforcement action in which CBP alleged that the imports did not comply with the North American Free Trade Agreement (NAFTA) rules of origin.
    • Advised manufacturer on customs law origin marking requirements and Trade Agreements Act domestic content rules.
    • Advised U.S. manufacturer on the Federal Transit Administration’s Buy America requirements associated with components, subcomponents and manufacturing processes.
    • Represented manufacturer in obtaining a CBP ruling that a remanufactured product could be considered substantially transformed in the U.S. and therefore eligible for sale to federal agencies.
    • Assisted global manufacturer in evaluating the potential effect of free trade agreements on the relative costs of building a new factory in Asia.
    • Assisted global security solutions company in reviewing the country of origin of its products related to Buy America, Buy American and Trade Agreements Act compliance.
    • Advised metal components manufacturer on compliance with Recovery Act domestic content requirements of the Environmental Protection Agency (EPA).
    • Advised computer manufacturer on CBP requests for information and notice of action related to imports involving Section 301 tariff exclusions, and obtained impactful adjustments to those exclusions after engagement with the U.S. Trade Representative.
    • Advised commercial manufacturer on regulatory issues arising from the inadvertent importation of radioactive products.
    • Assisted U.S. semiconductor company in enrolling in the Importer Self-Assessment program, including the site visit by CBP; also assisted our client with a full-day C-TPAT verification audit.
    • Assisted U.S. electronics company in applying for country-of-origin rulings (COOL) on whether products are eligible to be purchased by U.S. federal agencies under the origin restrictions of the Trade Agreements Act.
    • Developed Lacey Act compliance program for a telecommunications company seeking to source wood materials for its products and import these products into the U.S.
    • Advised technology company on duty rates and taxes applicable in various countries for relevant products.
  • Travel & Transportation
    • Advised airline on customs enforcement matters involving submission of manifest data.
    • Advised airline on its airline customs penalty actions.
    • Counseled logistics company regarding USDA Animal and Plant Health Inspection Service Wood Packaging Material program in connection with an infested shipment held by Customs at a U.S. port.

Practice Area Highlights

  • Pillsbury’s International Trade practice is nationally ranked by Chambers USA for Export Controls & Sanctions (2017–2025), CFIUS (2021–2025), and Trade Remedies & Trade Policy (2021–2025).
  • Pillsbury’s International Trade practice is nationally ranked by Chambers Global for Export Controls & Sanctions (2018–2026), CFIUS (2022–2026), and Trade Remedies & Trade Policy (2022–2026).
  • Pillsbury received Best Lawyers recognition for International Trade & Finance.

View More

  • Recognized by The Legal 500 U.S. for the breadth of our International Trade capabilities across four categories: CFIUS (2023–2025); Customs, Export Controls and Economic Sanctions (2023–2025); National Security (2025); and Trade Remedies and Trade Policy (2023–2025). Client testimonial hails the Pillsbury International Trade team as “…a well-unified, collaborative team that leverages each other’s knowledge based to demonstrate ‘big picture’ understanding as well as specialized advice within categories of issues.”
  • Recognized by The Legal 500 UK for excellence in EU and Competition: Trade, WTO Anti-Dumping, Customs and Sanctions (2024–2026).

Resources

Blog

Global Trade & Sanctions Law

Related Insights

View More
View All