FTA Proposes Requiring 100% U.S.-Origin Components for Rolling Stock Overhauls
Client Alert | 1 min read | 05.31.12
To "reclarify" an issue the Federal Transit Administration (FTA) thought it had settled in its 2007 rulemaking, on May 21, 2012, the FTA provided notice (with opportunity to comment on or before June 20, 2012) of its interpretation that the statutory exception permitting acquisition of rolling stock with only 60% U.S.-origin components did NOT apply to overhauls, because overhauls are more akin to replacement and repairs. Engine rebuilds, on the other hand, which extend the useful life of the rolling stock, would continue to qualify for the reduced level of domestic content (but also subject, presumably, to the requirement that 60% of the subcomponents used in a rebuild must be U.S.-origin for the component to qualify as domestic).
Contacts
Insights
Client Alert | 3 min read | 04.07.26
Answering the Top Seven Questions About Pending Section 301 Deadlines
In March 2026, the Office of the United States Trade Representative (USTR) launched two parallel Section 301 investigations: one targeting manufacturing overcapacity across 16 countries (including China, the EU, Japan, India, Mexico, Vietnam, and other major manufactures), and one targeting forced labor enforcement failures across 60 countries. Here are the top seven questions Crowell & Moring’s International Trade team is getting regarding pending Section 301 comment deadlines from our clients and how to address them:
Client Alert | 3 min read | 04.07.26
EU Pharma Package: Fiscal Imports in the Supply Chain Compromise Proposal
Client Alert | 5 min read | 04.07.26
Client Alert | 5 min read | 04.07.26
Weight-Loss Drug Coverage Obligations: A Litigation and Regulatory Update

