Get in Touch with Our International Trade Attorneys
Schedule a consultation with our international trade attorneys to assess your current customs compliance posture and identify optimization opportunities within existing regulatory frameworks.
U.S. Tariff & Customs Law Practice
Strategic counsel for importers navigating tariff regulations and customs enforcement.
At Harris Sliwoski, our international trade attorneys provide sophisticated legal guidance to importers and manufacturers confronting rising U.S. tariff obligations and increasingly aggressive customs enforcement. With tariff rates at historic highs and CBP ramping up supply chain verification, the need for strategic legal structuring of your import operations has never been more critical.
We offer specialized consultations on tariff regulations. Explore the options with our leading tariff and customs experts below.
Contact UsTariff Optimization & Compliance Counsel
Our trade law practice focuses on minimizing tariff exposure while ensuring full regulatory compliance. We structure complex international transactions to achieve optimal duty treatment under current U.S. customs law, including:
Contract Structuring & Transaction Planning
- Manufacturing Agreement Optimization: Separating dutiable manufacturing costs from non-dutiable elements including royalties, tooling expenses, technical assistance, research and development, and post-importation services under 19 CFR § 152.103.
- Transfer Pricing Coordination: Aligning customs valuation with IRS transfer pricing documentation to avoid conflicting agency positions.
- Related Party Transaction Compliance: Structuring affiliate transactions under 19 U.S.C. § 1401a(b)(2)(B) and the “circumstances of sale” test established in Generra Sportswear Co. v. United States.
Classification & Valuation Expertise
- Harmonized Tariff Schedule Analysis: Securing favorable classifications through binding ruling requests under 19 CFR § 177.1.
- Country of Origin Determinations: Navigating substantial transformation rules, marking requirements, and government procurement restrictions.
- Customs Valuation Disputes: Defending transaction value methodologies and challenging CBP appraisement under 19 U.S.C. § 1500.
Other Customs Programs & Procedures
- Foreign Trade Zone Operations: Implementing FTZ manufacturing and manipulation under 19 CFR Part 146 to defer, reduce, or eliminate duties.
- First Sale Rule Applications: Establishing compliant multi-tier transactions under J.C. Penney Purchasing Corp. v. United States.
- Duty Drawback Claims: Recovering duties on exported or destroyed merchandise under 19 U.S.C. § 1313.
- Temporary Importation Programs: Utilizing carnet procedures and temporary import bonds under 19 CFR Part 10.
Regulatory Compliance & Enforcement Defense
Import Compliance Programs
We develop comprehensive customs compliance frameworks incorporating:
- Reasonable Care Standards: Implementing systems satisfying the United States v. Golden Ship Trading reasonable care requirements
- Prior Disclosure Protocols: Establishing procedures for voluntary disclosure under 19 CFR § 162.74 to minimize penalty exposure
- Record-Keeping Systems: Ensuring five-year retention compliance under 19 CFR Part 163
Customs Enforcement & Penalty Mitigation
- Section 1592 Penalty Defense: Defending allegations of negligent, grossly negligent, or fraudulent customs violations under 19 U.S.C. § 1592
- Administrative Enforcement Responses: Managing CBP requests for information, focused assessments, and compliance examinations
- Anti-Dumping/Countervailing Duty Defense: Responding to Commerce Department investigations and defending scope determinations
Specialized Trade Enforcement Practice
Trade Remedy Proceedings
- Antidumping & Countervailing Duty Proceedings: Representing importers and foreign producers before Commerce and the International Trade Commission
- Section 337 Investigations: Defending intellectual property-based exclusion orders before the ITC
- Section 232 & 301 Proceedings: Advising on national security tariffs and China trade war measures
Anti-Circumvention & EAPA Proceedings
- EAPA Compliance Defense: Defending against anti-evasion investigations under 19 U.S.C. § 1517
- Transshipment Defense: Responding to allegations of circumventing antidumping and countervailing duty orders
- Supply Chain Verification: Managing CBP’s enhanced supply chain security requirements and forced labor enforcement
False Claims Act & Qui Tam Litigation
- Whistleblower Defense: Defending corporations against qui tam allegations of customs fraud
- Relator Representation: Representing whistleblowers exposing customs violations by competitors
- Government Investigations: Managing DOJ and CBP criminal investigations involving customs violations
Industry-Specific Expertise
Our customs law practice serves diverse industries with specialized regulatory frameworks:
- Automotive & Transportation: USMCA/NAFTA rules of origin, tariff engineering, fuel economy regulations
- Technology & Electronics: Section 301 China tariffs, semiconductor tariff classifications, telecommunications equipment restrictions
- Textiles & Apparel: Textile Trade Agreements, preferential duty treatment, labor compliance requirements
- Food & Agriculture: FDA import requirements, tariff classification of processed vs. unprocessed goods
- Pharmaceuticals & Medical Devices: FDA/CBP coordination, valuation of kits and mixed shipments
Representative Matters
- Represented a Chinese electronics exporter in a Section 301 tariff exclusion request before USTR, helping the client avoid millions in retaliatory duties.
- Advised a U.S. solar panel importer in a CBP origin verification audit focused on alleged tariff circumvention through Southeast Asia.
- Secured binding tariff classification rulings for semiconductor testing systems, achieving over $1.2M in annual duty savings.
- Restructured a multinational supply chain to reduce exposure to Section 301 tariffs, leveraging first-sale pricing and substantial transformation strategies.
- Defended a medical device importer in a DOJ investigation involving customs valuation fraud under the False Claims Act.
- Counseled an automotive parts manufacturer in an EAPA proceeding involving CBP allegations of AD/CVD duty evasion.
- Negotiated a prior disclosure and penalty petition for a U.S. consumer products company involving misclassification, resulting in full penalty mitigation.
- Represented a textile importer in a tariff reclassification dispute before CBP, successfully shifting classification to a duty-free preference program.
- Conducted comprehensive tariff risk audits for importers seeking to preempt CBP enforcement actions and reduce long-term duty exposure.
- Managed a Section 232 steel tariff exclusion petition based on product-specific national security exemptions.
Why Harris Sliwoski for Customs & Trade Law
- Deep Regulatory Experience: Our attorneys have held senior positions at CBP, Commerce Department, and the ITC.
- Cross-Border Integration: We align customs compliance with international tax and regulatory strategies.
- Proactive Risk Management: We structure transactions to minimize customs risk before issues arise.
- Government Relations Capability: Our lawyers have often testified before various Congressional international trade committees, and we have a long history of effectively engaging with regulatory bodies and policymakers.
- Regulatory Advocacy & Policy Development: We comment on proposed regulations and assist in shaping agency implementation.
- Focused Practice Advantage: Our narrow focus delivers high-level expertise efficiently and cost-effectively.
Emerging Regulatory Challenges
As global trade evolves, so do regulatory complexities. We help clients navigate cutting-edge issues including:
- Digital Trade & AI: Customs treatment of artificial intelligence, software, and digital services
- Cryptocurrency Valuation: Establishing customs value methodologies for blockchain-based transactions
- Environmental Compliance Integration: Coordinating customs compliance with carbon border adjustments and ESG requirements
- Supply Chain Transparency: Meeting enhanced due diligence requirements under forced labor and conflict minerals regulations
Expert Consultation Services: Master Your Global Strategy
Navigate the complexities of international trade and global business with our specialized, expert-led consultations.
60-Minute Tariff Strategy Consultation with Adams Lee
Our lead International Trade Attorney — $650 flat fee (upfront) • [View Full Bio]
Gain a clear roadmap to minimize your company’s tariff exposure and optimize your international trade operations. This session focuses on assessing your specific tariff challenges and developing practical solutions.
Before the call: Please briefly describe the products you’re importing (or plan to import) and their countries of origin so we can maximize our time together. If your needs fall outside our expertise, we will inform you in advance and issue a full refund if payment has been made.
60-Minute Global Business Strategy Consultation with Dan Harris
Our lead International Manufacturing Attorney — $650 flat fee (upfront) • [View Full Bio]
Develop a robust, country-specific strategy to confidently expand your business or relocate operations into new global markets. This session provides essential guidance on business and manufacturing strategies, independent of current tariff structures. It’s ideal if you’re considering entering new markets or relocating your operations.
Before the call: Please let us know which countries you’re considering. This ensures we are fully prepared and focused on your specific needs. If there’s a country outside our expertise, we will inform you in advance and issue a full refund if payment has been made.
Risk Assessment & Next Steps
Current enforcement trends indicate heightened scrutiny of:
- Related party transactions and transfer pricing coordination
- Country of origin representations in multi-country supply chains
- Customs valuation methodologies for intangible property
- Supply chain due diligence under forced labor regulations
Given the ever-evolving landscape of U.S. customs enforcement and international trade policy, a proactive review of your import operations is essential.
Schedule a ConsultationTo read what we have recently written regarding tariffs, please check out the following:
- THE Guide for LEGALLY Avoiding Today’s and Tomorrow’s U.S. Tariffs
- Beyond the 30%: The Real China Tariffs RIGHT NOW
- Buyer Beware: The Hidden Risks of Unpaid Tariffs Under DDP
- Why Following Your Chinese Supplier’s Tariff Advice Could Land YOU in Jail: It Will Likely Be Your DDP Deal That Will Put You There
- The First Sale Doctrine: A Tool for Reducing Tariffs—But Only If Done Right
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Our Clients' Successes
“Harris Sliwoski expertly guided us through the formation of our company. They continue to assist with necessary registrations and compliance with numerous regulations. They were able to promptly answer all our many questions and provide understandable options, explanations and practical advice. We expect to continue to use Harris Sliwoski on a regular basis as our company expands. They were also able to introduce us other professional experts. We would not hesitate to recommend Harris Sliwoski to any companies in need of legal advice.”
Three Continents Foods LLC
This law firm was a huge help as our company went through the process of commercial licensing in the California cannabis industry. They have helped us with a variety of legal issues in a timely fashion, while clearly communicating with us throughout the process. Everyone we’ve worked with at Harris Sliwoski is an expert in their field and we have always felt that we were in good hands through our legal representation.
Wil Crummer, CEO PRO Farms
Legal stuff is always scary. And I’ve had to play offense a couple times, begrudgingly. To have Harris Sliwoski have my back? It made things a lot less prickly. They quickly walked me through my options, and were refreshingly consistent in their communications, timing and billing. I’ve been lucky to stay out of the legal side of things my whole career, thankfully. When things went a little wrong, Harris Sliwoski quickly made things right.
Aaron Draplin, Founder Draplin Design Co.
I am impressed with this law firm. They answered all my questions regarding cannabis businesses and the California cannabis framework, and they have helped me with a variety of legal issues in a timely fashion, while always clearly communicating with us throughout the process. They also redirected me to other quality people for my business needs. Everyone I worked with at Harris Sliwoski is an expert in their field, and I was in good hands throughout my legal representation.
Corey T., CEO Thinc Cubed, LLC
I have been working with the lawyers at Harris Sliwoski for more than 20 years both as a business owner and as an executive at a large east-coast health system and that is because they have always efficiently provided high level and clear international law advice. Most recently, Harris Sliwoski provided legal support on many matters related to procuring medical products worldwide. Their support was particularly helpful to during the onset of COVID, when there was a big need for securing PPE quickly, all while navigating complicated international and domestic legal requirements. Harris Sliwoski’s team of international lawyers helped by conducting rapid-fire due diligence on potential suppliers, navigating the legal logistics for getting product from overseas and through U.S. customs, and drafting contracts to protect against various sorts of horribles. They did this by essentially providing what amounted to 24/7 service. I cannot recommend them highly enough.
Dan Pak Hospital Supply Chain Executive
Harris Sliwoski has represented our company in the legal cannabis industry for years. Harris Sliwoski has advised us in a wide variety of legal matters, and they are truly experts in their field. I would highly recommend Harris Sliwoski to anyone with questions about cannabis law, or any legal matters. They have been great for our Company, and will continue to guide us as our industry evolves
Matt Hurt, COO Cannabis Nation
You won’t find a better partner than Harris Sliwoski when trying to navigate the complex world of healthcare regulations. They not only give sound and reliable legal advice, but they are also very responsive and are able to guide you in a way that helps you reach your business objectives as well.
Joseph Axelrod, General Counsel Irwin Naturals
When we started the process of building a ‘seed to sale’ cannabis company in Oregon, we saw the need for expert legal counsel. The cannabis sector is fraught with potential peril at every turn, and we wanted the best legal advice we could find. After talking to several firms and individuals, we feel extremely fortunate to have chosen Harris Sliwoski as our legal counsel.
Tony Theiss, CEO and Co-Founder Redbarn Cannabis
We use Harris Sliwoski on all our international legal matters, including on our international litigation matters. We have over the last few years been involved in a couple big international legal disputes and Harris Sliwoski’s international dispute resolution team provided us with expert legal assistance on both matters. They were always very careful to explain to us what they were doing and why and what their actions would likely cost us in legal fees. Most importantly, we did extremely well on both cases and I have no doubt Harris Sliwoski was a big factor in that.
Kevin English, CEO We Are Camp
We have used Harris Sliwoski for legal help related to our international manufacturing. The lawyers with whom I worked had extensive familiarity with the international legal issues involved in our various projects and offered us key insights. I particularly appreciated how they always quickly and efficiently do what they say they will do and always within their cost estimates.
Andrea Barona Valladolid, Senior Legal Counsel Fairphone