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 | 9 min read | 02.12.26
On 9 January 2026, the European Commission published its Guidelines on the application of Regulation (EU) 2022/2560, also known as the Foreign Subsidies Regulation (FSR).
Client Alert | 3 min read | 02.12.26
Client Alert | 2 min read | 02.12.26
Utilities and Data Centers Confront Congressional Scrutiny Over Rising Electricity Prices


