New "600 Series" Export Classification Brings No Relief from Offset Reporting
Client Alert | 1 min read | 12.09.15
On December 2, 2015, Commerce's Bureau of Industry & Security (BIS) published a proposed rule clarifying that annual reporting of offset arrangements exceeding $5 million associated with sales of defense articles or services will include sales of items now classified within any "600 Series" of the Commerce Control List, except for certain submersible or semi-submersible cargo transport vehicles. This proposed rule expands the range of sales that can trigger offset reporting by expressly including sales of various "600 Series" items (e.g., military helmets) that were previously controlled under other Export Control Classification Numbers within the Export Administration Regulation and, thus, not subject to the offset reporting obligations mandated by 15 C.F.R. Part 701.
Insights
Client Alert | 3 min read | 05.06.24
FTC Imposes $3.17 Million Civil Penalty for Violation of Prior Made in USA Order
Last week, based on a referral from the Federal Trade Commission (“FTC”), the Department of Justice (“DOJ”) filed a complaint against Williams-Sonoma alleging that the company violated a previous Federal Trade Commission decision and order dated July 13, 2020 (the “2020 Order”) pursuant to which Williams-Sonoma was prohibited from making unsubstantiated U.S. origin claims. The complaint alleged that, following entry of the 2020 Order, Williams-Sonoma made “numerous false and unsubstantiated representations that their home goods or other products are ‘Made in USA’ or otherwise of U.S. origin, when, in fact, they are wholly imported or contain significant imported components.”
Client Alert | 14 min read | 05.03.24
Client Alert | 3 min read | 05.03.24
EEOC’s New “Enforcement Guidance on Harassment in the Workplace” Hits Hot-Button Issues
Client Alert | 11 min read | 05.03.24
FDA Moves Forward on Laboratory Developed Tests while Stakeholders and Congress Weigh Next Steps
