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David Gallacher is a partner in the Government Contracts, Investigations and International Trade Practice Group in the firm's Washington, D.C. office.

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Trade Agreements Act compliance changed fundamentally three years ago. Or, so we thought on December 7, 2016, when the U.S. Court of International Trade (“CIT”), the appellate body for country of origin determinations issued by the U.S. Customs and Border Patrol (“CBP”), for the first time analyzed the meaning of “substantial transformation” under the Trade Agreements Act.(“TAA”).[i] To celebrate this third anniversary, we reviewed the CBP decisions issued over the last three years: (1) to see if we were correct, (2) to determine exactly how the CIT decision fundamentally changed the substantial transformation analysis, and (3) to figure out… Continue Reading The Evolution of TAA Compliance Post-Energizer – “Substantially Transformed” Has Substantially Changed

About

David Gallacher is a partner in the Government Contracts, Investigations and International Trade Practice Group in the firm's Washington, D.C. office.