Customs
Overview
Crowell & Moring’s Customs practice assists some of the world’s largest corporations, providing advice and counsel in every substantive area of customs law, administrative proceedings, audits, investigations, litigation, public policy and global customs disputes. We represent a diverse group of clients and industries and take a multi-disciplinary approach to customs issues, combining legal, economic and public policy experience as needed to obtain the best results for clients.
Insights
Client Alert | 4 min read | 06.24.25
CBP Issues First Comprehensive Guide to Modifying a Withhold Release Order (WRO)
On June 2, 2025, U.S. Customs and Border Protection (“CBP”) issued its first ever Withhold Release Order (“WRO”) and Finding Modifications Guide (“Guide” or “the Guide”). The Guide serves as a roadmap for importers facing a possible WRO or Finding due to allegations of forced labor in the supply chain of their goods imported into the U.S. It provides guidance on information to be included in a modification petition, identifies possible cases in which CBP might request additional information, and provides resources for importers facing a WRO or Finding.
Podcast | 06.06.25
Firm News | 11 min read | 06.05.25
Webinar | 06.04.25
Representative Matters
- Assisted a global manufacturer realize millions of dollars in duty refunds and duty savings based on an innovative interpretation of the NAFTA rules of origin related to U.S. exports of home appliances.
- Assisted a global producer of production equipment and vehicles with establishment of foreign trade zones allowing for over $1 million per year in total cost savings.
- Obtained favorable customs valuation decisions in the North American, EU, and Asian markets, which resulted in substantial duty savings in related party and multi-party transactions.
- Obtained U.S. legislation providing permanent and temporary tariff relief for high tech, chemical, plastic, agricultural, pharmaceutical, food, home appliance, and other industries securing over $80 million in duty savings.
- Obtained recovery of duty refunds in the EU and U.S. by challenging the assessment of antidumping and countervailing duties on chemical, steel, and agricultural productions.
- Challenged attempts to put agricultural and other products on U.S. and EU safeguard duty retaliation lists, which resulted in millions in duty savings and avoidance of additional duties.
- Represented a top 10 U.S. importer in criminal and civil penalty proceedings resulting in a declination of prosecution after grand jury indictment, and cancellation of penalty claims.
- Counseled importers and exports on valuation issues, including intercompany transfer pricing, first sale rule, agency agreement, royalties, license fees, and assists.
- Advised clients on customs enforcement of intellectual property rights, including copyright and trademark registration, and section 337 exclusion orders.
- Representation of a California producer of aerospace fasteners in litigation brought by the Customs Service alleging fraudulent importations.
Insights
Client Alert | 4 min read | 06.24.25
CBP Issues First Comprehensive Guide to Modifying a Withhold Release Order (WRO)
On June 2, 2025, U.S. Customs and Border Protection (“CBP”) issued its first ever Withhold Release Order (“WRO”) and Finding Modifications Guide (“Guide” or “the Guide”). The Guide serves as a roadmap for importers facing a possible WRO or Finding due to allegations of forced labor in the supply chain of their goods imported into the U.S. It provides guidance on information to be included in a modification petition, identifies possible cases in which CBP might request additional information, and provides resources for importers facing a WRO or Finding.
Podcast | 06.06.25
Firm News | 11 min read | 06.05.25
Webinar | 06.04.25
Insights
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04.20.23
Crowell & Moring's International Trade Law
Customs Ruling Of The Week – Country Of Origin Of Prepared Painting Canvas
|02.22.23
Crowell & Moring’s International Trade Law
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02.15.23
Crowell & Moring’s International Trade Law
Customs Ruling Of The Week – Country Of Origin Of An Aluminum Monitor Mount
|02.07.23
Crowell & Moring’s International Trade Law
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01.27.23
Crowell & Moring’s International Trade Law
Customs Ruling of the Week- Classification of a Biometric Scanner
|01.04.23
Crowell & Moring’s International Trade Law
Magnus Resigns from CBP Following Mayorkas Request, Troy Miller New Acting Commissioner
|11.17.22
Crowell & Moring’s International Trade Law
Lawmakers in Washington Propose Bill for Allowing Retroactive GSP Benefits
|09.21.22
Crowell & Moring’s International Trade Law
Professionals
Insights
Client Alert | 4 min read | 06.24.25
CBP Issues First Comprehensive Guide to Modifying a Withhold Release Order (WRO)
On June 2, 2025, U.S. Customs and Border Protection (“CBP”) issued its first ever Withhold Release Order (“WRO”) and Finding Modifications Guide (“Guide” or “the Guide”). The Guide serves as a roadmap for importers facing a possible WRO or Finding due to allegations of forced labor in the supply chain of their goods imported into the U.S. It provides guidance on information to be included in a modification petition, identifies possible cases in which CBP might request additional information, and provides resources for importers facing a WRO or Finding.
Podcast | 06.06.25
Firm News | 11 min read | 06.05.25
Webinar | 06.04.25