Customs Proposes To Substantially Transform The Substantial Transformation Test
Client Alert | less than 1 min read | 08.08.08
By Notice of Proposed Rulemaking, 73 Fed. Reg. 43385 (July 25, 2008), Customs & Border Enforcement has proposed substituting, for many purposes including rulings under the Trade Agreements Act (TAA), a "tariff shift" approach for determining country of origin in lieu of the longstanding and subjective "case-by-case" approach to determining the place where "substantial transformation" occurred. Under the proposed rule, contractors selling products under the contracts subject to the TAA would have to reevaluate their products under the rigid, pre-established formulaic tariff shift analysis to ensure products with significant non-designated country content qualify for sale to the federal government.
Contacts
Insights
Client Alert | 4 min read | 07.27.26
On June 18, 2026, the California Department of Toxic Substances Control (DTSC) added microplastics to the list of Candidate Chemicals maintained under the state’s Safer Consumer Products (SCP) regulations. The listing of microplastics, which becomes effective on October 1, 2026, is the first step in the SCP regulatory process, which could lead to restrictions on products that contain or release microplastics.
Client Alert | 2 min read | 07.24.26
GAO Finds That Challenge to Agency’s Failure to Comply With DFARS Requirement Comes Too Late
Client Alert | 3 min read | 07.23.26
Client Alert | 3 min read | 07.23.26
Second Circuit Affirms Preliminary Injunction Against Nielsen in Constructive Tying Case


