Customs

Mr. Bilaniuk has wide-ranging experience on customs compliance counseling, tariff mitigation strategies, and forced labor supply chain compliance. 

• Secured exclusions and exclusion extensions through the exclusion process administered by the Office of the U.S. Trade Representative (USTR) for Section 301 tariffs on Chinese-origin goods for multiple clients across industrial manufacturing, electronics, medical device, leisure, and recreation industries for imports on the various Section 301 Lists.  Tariff refunds and savings to clients totaled in tens of millions of dollars.
• Counseled range of clients across various industry sectors about correct Harmonized Tariff Schedule (HTS) classifications and counseled on supply chain reengineering and country of origin analysis of production processes for purposes of tariff mitigation.
• Filed actions in the Court of International Trade on behalf of companies in a range of industries  challenging the authorization of the U.S. government to levy List 3 and List 4a Section 301 China tariffs and seeking full refund of tariffs paid.  Litigation pending.
• Investigated potential Customs violations of importer of importing goods from China subject to antidumping/countervailing duties (AD/CVD) without paying proper duties; confirmed violations and submitted prior disclosure to Customs; Customs closed case with no penalties assessed.
• Advised various clients on Customs marking rules.
• Advised electronics manufacturer about whether imported products sold to the U.S. government qualified as Trade Agreements Act (TAA) compliant by conducting country of origin analysis.
• Assisted clients with respect to seizure of goods by Customs due to apparent violation of export controls.
• Counseled suppliers of OEM auto parts on different options for complex manufacture and assembly processes in China and Mexico of mechanical, electronic, safety auto parts, and engine subassemblies given implications on Section 301 China tariffs, country of origin analysis for NAFTA preferential treatment, marking rules, and United States–Mexico–Canada Agreement (USMCA) automotive rules of origin analysis.
• Counseled importers of goods from China in various industries on the enforcement provisions of the Uyghur Forced Labor Prevention Act (UFLPA) and the significant due diligence expected by the U.S. Government to demonstrate forced labor was not used in all tiers of the supply chain.  Assisted with evaluating due diligence results and in update compliance policies and internal controls.