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Status of U.S. Trade Agreements Likely to Take Center Stage in 2017

Posted By Administration, Thursday, January 19, 2017
Updated: Tuesday, January 17, 2017


by Melissa Proctor, Polsinelli, P.C.


What could the election of Donald Trump and a Republican majority in the U.S. Congress mean for U.S. international trade policy in 2017 and beyond? And what are the potential opportunities and challenges for U.S. importers, exporters, manufacturers and retailers?

U.S. trade agreements, such as the Trans Pacific Partnership Agreement (TPP), the North American Free Trade Agreement (NAFTA) and other free trade agreements are likely to take center stage in 2017. The United States is currently a party to several free trade agreements involving twenty (20) countries. Free trade agreements (FTAs) are agreements between two or more countries that are intended to reduce or eliminate tariffs and non-tariff barriers on substantially all trade amongst the parties in order to allow for the free movement of qualifying goods and services in their territories. Goods that are subject to this preferential tariff treatment must satisfy certain FTA-specific rules of origin, which can include tariff shift rules, regional value content requirements, or a combination of the two. FTAs also result in significant cost and duty-savings for foreign customers of U.S. products, which make U.S. goods more attractive in foreign markets. In addition, FTAs result in lower costs for U.S. manufacturers that source raw materials, parts and components from FTA partner countries for manufacturing operations performed in the United States. Half of all U.S. exports are currently made to FTA partner country markets.

Presidential Authority to Negotiate, Enter and Withdraw from Free Trade Agreements
Congress has historically granted broad authority to the President to negotiate, enter and even withdraw from FTAs. The Trade Act of 1974,1 as amended, authorizes the President to negotiate trade agreements with foreign countries focusing on tariff and non-tariff barriers, and the resulting agreements are required to be submitted to Congress for approval.

The President currently has what is known as "fast track authority" or "Trade Promotion Authority" ("TPA") under which Congress agrees to consider trade agreements and vote on their implementing legislation without making any amendments to the agreements. This expedites the FTA implementation process and assures U.S. trading partners that the negotiated agreement will not be second-guessed or modified by U.S. legislators.

TPA is granted only for certain, limited periods of time, and must be reconsidered and reauthorized by Congress.2 Each time that Congress has extended TPA, it has also given the President authority to terminate or withdraw from FTAs. That is, after providing formal notice (i.e., six months) to FTA partner countries, the President has the unilateral authority to revoke prior Executive Orders that provided preferential tariff treatment under FTAs and to institute higher tariffs on imported goods. No formal approval from Congress is required before the President can take such actions. Per Section 125(c) of the Trade Act of 1974, as amended, the President is also authorized to increase tariffs on imported goods between 20% to 50% of the tariff rates that were in effect and applicable to the goods on January 1, 1975. However, the existing preferential tariffs established under an FTA could remain in effect for a certain period of time (i.e., 12 months) after the President's decision to terminate U.S. participation in an FTA in order to give U.S. importers and exporters time to adjust their operations and activities.

The Trans Pacific Partnership Agreement
The Trans Pacific Partnership agreement ("TPP"), which includes the United States and eleven other countries in the Asia Pacific region, would be the largest regional free trade and investment agreement ever negotiated. In February 2016, the United States and the various signatory countries signed the agreement. They currently have a maximum period of two (2) years in which to implement it into their local laws. If the TPP were implemented into U.S. law, the agreement itself would enter into force only after at least six of the signatory countries (that represent a minimum of 85% of the GDP of all of the participants) have implemented the agreement into their local laws. If the TPP were to enter into force, import tariffs on more than 18,000 "originating" goods traded between the parties would be eliminated.

The TPP was highly criticized by both presidential candidates. On November 21st, President-Elect Trump issued a YouTube video statement in which he stated that soon after the inauguration, he intends to submit formal notification to the TPP signatory countries of the United States' withdrawal from the agreement. Many of the signatory countries have already begun the TPP's ratification process. It is possible that they could enter into their own separate agreement absent the United States.

The North American Free Trade Agreement
The North American Free Trade Agreement (NAFTA) is an FTA that includes the United States, Canada and Mexico. It was signed into force by former President Bill Clinton on January 1, 1994, and eliminated duties on "originating" goods and non-tariff barriers on goods and services traded between the parties. According to the 2015 Congressional Research Services report on the NAFTA, U.S. trade with Canada and Mexico more than tripled since the agreement's entry into force. The report also stated that the NAFTA helped U.S. manufacturing industries, especially the U.S. automotive industry, become more globally competitive through the creation of new supply chains, especially along the U.S.-Mexico border.

The terms of the NAFTA itself, in Section 2205, allow the parties to unilaterally withdraw from the NAFTA after providing six months' written notice to the other parties. In addition, if the U.S. were to withdraw from the agreement, the NAFTA would remain in force for Canada and Mexico. It is anticipated that if the United States were to withdraw from the NAFTA and impose higher tariff rates to goods imported from Canada and Mexico, the costs borne by U.S. manufacturers that source Canadian and Mexican raw materials, parts and components would increase – those costs would likely be passed along to U.S. consumers in the prices of the finished goods. In addition, U.S. exporters would likely find that their products would become less competitive in Canadian and Mexican markets given that customers in those countries would be paying higher duties on U.S. goods.

During his campaign, President-Elect Trump criticized the NAFTA, and vowed to renegotiate the agreement or withdraw from it – it should be noted that President Obama made the very same promise when he was running for President, but never took steps to renegotiate or withdraw from the NAFTA. In November, Canadian Prime Minister Justin Trudeau announced that he is willing to renegotiate the NAFTA, and that trade deals such as the NAFTA should be periodically reviewed to ensure that they continue to provide benefits to the parties. Mexico's Foreign Minister, Claudia Ruiz Massieu, announced that the Mexican government would also be willing to discuss the NAFTA and how to modernize it, but ruled out renegotiation of the agreement. The NAFTA has been modified by the parties several times since it went into force in 1994 (e.g., changes in the rules of origin for certain products, modifications made to the dispute resolution processes, liberalized entry rights for certain professional occupations, etc.).

Other U.S. Trade Agreements
As noted above, the U.S. is currently a party to FTAs with twenty countries, and the Trump Administration would have the unilateral authority to terminate or withdraw from these trade agreements under the agreements themselves and the Trade Act of 1974, as amended, upon providing written notice to the various parties. The President would also have the authority to raise tariffs on goods imported into the United States from those countries. Such actions would likely draw opposition from many U.S. companies that have been relying on the preferential tariff treatment afforded under these agreements for many years. It is more likely that the incoming President would first seek to review these agreements and their renegotiation before moving to terminate them.

In addition to the FTAs that are currently in effect, the United States is also negotiating the Trans-Atlantic Trade and Investment Partnership (T-TIP) with the European Union, as well as the Trade in Services Agreement (TiSA) with twenty countries. To date, President-Elect Trump has not commented on the T-TIP. The Trade in Services Agreement (TiSA), currently in negotiations, is intended to promote and reduce barriers to international trade in services (e.g., business and professional services, such as accountancy, advertising, architectural and engineering, computer and related services, legal, communication, telecommunications, construction, energy, financial, transportation, and tourism services) amongst the U.S. and 20 trading partners that represent nearly two-thirds of global trade in services. Since the T-TIP and TiSA are still in their early stages, it is possible that President-Elect Trump will agree to allow the negotiations to continue. If the negotiations come to completion, if the new President does not oppose the agreements and if they were to come before Congress, it is anticipated that the Republican dominated Congress would approve them.

Companies that utilize FTAs are urged to stay abreast of the new developments and pronouncements from President-Elect Trump and his transition team, consider the various scenarios that could impact their sourcing decisions and supply chains in the near future, and begin thinking about contingency plans should the need arise.

[1] Trade Act of 1974, as amended (Public Law 93–618, as amended; 19 U.S.C. Section 12).
[2] The TPA was extended by Congress in the Omnibus Trade Act of 1988, TPA Act of 2002, and Bipartisan Congressional Trade Priorities and Accountability Act of 2016.


Melissa Proctor is a Shareholder with Polsinelli, P.C. With significant experience in the customs laws and regulations, export controls, economic sanctions, and international trade, Melissa is committed to understanding companies' operations and providing assistance geared toward helping them reach their specific business and operational goals. She may be reached at (602) 650-2002 or via e-mail at mproctor@polsinelli.com.

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Tags:  FTA  NAFTA  TiSA  TPP  trade agreements  Trump administration  T-TIP  world trade 

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Yusen, We Have a Problem!: In The News Round-up

Posted By Administration, Thursday, October 13, 2016
Updated: Tuesday, October 11, 2016



by Mark Kopp, Yusen Logistics (Americas) Inc.


Are you ready for Post-Panamax?
Okay, so the big ships are coming. For those not "in the know," post-Panamax describes ships that do not fall within the size limitations to travel through the Panama Canal. New size limitations, increasing the allowable dimensions, came into effect this past summer.

If you're a retailer on the East Coast, it will be great to avoid all that port congestion on the West Coast. Cost savings can be expected from all water shipping. There will be fewer railroad and trucking delays and costs. But what happens when your cargo gets through the canal? Currently only Baltimore, Norfolk, and Miami are deep enough to accommodate these vessels. Savannah is dredging and New York is talking about raising the bridges. According to The American Shipper, in an article of September 30th, Canadian ports in Montreal, Halifax, and Saint John are expanding their capabilities in anticipation of the increased cargo.1 But how long will that take?

What East Coast importers need to consider is whether or not this is really going to be a panacea. Will there really be any savings if the infrastructure on the East Coast is incapable of receiving the freight? You need to have some realistic conversations with your carriers to understand how they are planning to deliver the cargo that will be coming through the canal.

And will it really matter?
According to the World Trade Organization in a September 27 press release, world trade is growing at its slowest pace since the financial crisis of 2009. The WTO is forecasting world to grow by just 1.7% in 2016 and could be only slightly higher in 2017. Trade has been weaker than expected due to slowing GDP growth in several major developing economies as well as in North America.

According to WTO Director-General Roberto Azevedo, "the dramatic slowing of trade growth is serious and should serve as a wake-up call. It is particularly concerning in the context of growing anti-globalization sentiment. We need to make sure this does not translate into misguided policies…"2

Yes, but the TPP and TTIP are sure to help.
Maybe. According to rollcall.com posted on August 26, Senate Majority Leader Mitch McConnell stated the Senate will not vote on TPP this year.3 McConnell sited "serious flaws" in the agreement. "It can be massaged, changed, worked on during the next administration". Let's face it, the TPP will not work without the participation of the United States. The rollcall.com reports states that member nations Japan, New Zealand, and Singapore believe that reopening the negotiations will lead to its unraveling.

On the European front, hopes for an immediate implementation of the TTIP are no brighter. According to The Guardian, "Hopes of a deal before U.S. President Barack Obama leaves the White House in mid-January have evaporated…"4 There is doubt the agreement will be implemented at all amid growing hostility and street protests in Europe. Great Britain has been a supporter of the agreement but, of course, no one knows as of yet the full impact of Brexit in the negotiations.

In other news, this very expensive Bud's for you.
On September 28 the Security and Exchange Commission announced that Anheuser-Busch InBev has agreed to pay $6 million to settle charges that it violated the Foreign Corrupt Practices Act.5 Recent months have seen several fines and penalties, issued to various companies for violation of the FCPA.

This is just another reminder of the importance of having written compliance procedures. Not only just having procedures, but making sure all employees are properly trained and understand the importance of the procedures.

[1] http://www.americanshipper.com/main/news/special-coverage-canadas-eastern-ports-plan-for-up-65465.aspx?source=LatestNews
[2] http://www.wsj.com/articles/world-trade-seen-growing-at-weakest-pace-since-financial-crises-1474965904
[3] http://www.rollcall.com/news/mcconnell-comment-tpp-ends-obamas-chance-close-deal
[4] https://www.theguardian.com/business/2016/sep/30/ttip-eu-and-us-trade-negotiators-seek-to-get-talks-back-on-track
[5] https://www.sec.gov/news/pressrelease/2016-196.html


Mark Kopp is currently the Senior Manager for Import Compliance for Yusen Logistics (Americas) Inc. Mark has over 30 years experience in all aspects of supply chain management and compliance - from product development and buying, cargo management and shipping, customs brokerage, to warehousing, distribution and retail sales. He has managed/directed imports for Kinney Shoe Corporation, Woolworth Corporation, Russ Berrie & Co. and DHL. He has also served on the Footwear Distributors & Retailers of America government customs council, been a member of the Board of Directors for the Toy Shippers Association, and been an instructor at The World Trade Institute in New York. Currently, he is a member of the NY/NJ Freight Forwarders & Brokers Association and serves on the American Apparel & Footwear Association Government Relations Committee. Mark graduated from Franklin & Marshall College in Lancaster, PA with a B.A. in Political Science.

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Tags:  FCFA  Post-Panamax  TPP  TTIP  World Trade 

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Obama Administration Continues to Push Congress to Implement the Trans Pacific Partnership Agreement by the End of 2016

Posted By Administration, Thursday, September 8, 2016
Updated: Wednesday, September 7, 2016


by Melissa Proctor, Polsinelli, P.C.


The Trans Pacific Partnership agreement ("TPP"), which includes the United States and eleven other countries in the Asia Pacific region (i.e., Australia, Brunei, Canada, Chile, Japan, Malaysia, Mexico, New Zealand, Peru, Singapore, and, Vietnam.), is the largest regional free trade and investment agreement that has ever been negotiated. In February of this year, the United States and the various signatory countries signed the agreement, and have two (2) years in which to implement it into their local laws. Once the TPP is fully implemented and goes into effect, what would such an agreement mean for U.S. retailers, distributors, and manufacturers? The TPP would eliminate import tariffs on more than 18,000 goods, many of which are currently subject to high duty rates, and could provide U.S. companies with significant duty savings on imports of qualifying raw materials and goods into the United States. U.S. exporters may also find their duty-free goods to be in greater demand by foreign buyers located in TPP signatory countries. The Obama Administration has also hailed the TPP as a means for supporting higher paying jobs in the United States, growing the U.S. economy, and countering China's economic expansion.

During a press conference in early August, President Obama said that it is his wish for Congress to pass TPP implementing legislation before he leaves office, and on August 12, 2016, the U.S. Trade Representation sent the President's draft Statement of Administration Action to Congress. The Statement of Administration Action describes the White House's interpretation of the U.S. obligations under the TPP and the proposed executive actions that would be required for its implementation into U.S. law. During this time, the Administration and Congress may begin consultations, as well as hold committee hearings on the TPP. The submission of the draft to Congress initiates the 30-day time period after which a TPP implementing bill and the final Statement of Administration Action may be submitted to Congress for consideration.

However, on August 25, 2016, Senate Majority Leader Mitch McConnell said during a Kentucky State Farm Bureau breakfast in Louisville, Kentucky that the Senate will not vote on the TPP before Obama leaves office. Rather, he noted that the TPP may be passed after additional changes have been made to the agreement when the new Administration takes office in 2017. Nevertheless, given the recent submission of the draft Statement of Administration Act to Congress, it appears that the Obama Administration will continue to push implementation of the TPP by the end of 2016 despite the current political climate in Congress and rhetoric of both political parties' presidential candidates. Even after the TPP's implementation into U.S. law, the agreement itself will enter into force only after at least six of the signatory countries (that represent a minimum of 85% of the GDP of all of the participants) have implemented the agreement into their local laws. Thus, it may be some time before the TPP will go into force.

If the TPP is implemented into U.S. law and ultimately takes effect, U.S. retailers, manufacturers and distributors will need to know how to make the most of the agreement and should start planning accordingly. As noted above, customs duties on more than 18,000 products imported into the United States and other signatory countries will be eliminated under the TPP; however, only goods that "originate" in a TPP member country will be afforded preferential tariff treatment. There are three ways in which a good may qualify for TPP treatment – the goods must be:

  1. wholly obtained or produced entirely in the TPP territory;
  2. produced entirely from TPP-originating materials; or,
  3. in full compliance with product-specific rules of origin.

The agreement also provides a de minimis rule that will allow imported products containing non-originating materials to qualify for the TPP – even if they don't otherwise satisfy the agreement's product-specific rules of origin. Originating goods must also be shipped directly from one member country to another without passing through the territory of a non-party in order to qualify for the TPP.

Claims for duty-free treatment on imports of TPP-originating will be made at the time the qualifying goods are entered into a signatory country and the importer must have in its possession a certification signed by the producer or exporter of the goods attesting that the merchandise is in fact TPP-originating. There will be no specified form that must be used for these certifications; however, they must contain certain data elements relating to the producer, exporter, importer and the products themselves. In addition, both importers and exporters utilizing the TPP must maintain records (i.e., certifications and supporting documentation substantiating that the products qualify for TPP treatment) for a period of five (5) years from the date of importation or date of execution of the certification. At this stage, it is still too early to predict when the proposed agreement will actually go into effect. However, it is a good idea for companies to begin thinking about how the TPP may impact their operations and whether it could be used for greater duty and cost savings (for themselves or for their foreign buyers) in the future.


Melissa Proctor is a Shareholder with Polsinelli, P.C. With significant experience in the customs laws and regulations, export controls, economic sanctions, and international trade, Melissa is committed to understanding companies' operations and providing assistance geared toward helping them reach their specific business and operational goals. She may be reached at (602) 650-2002 or via e-mail at mproctor@polsinelli.com.

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Tags:  TPP  Trans Pacific Partnership 

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Another Step Closer to Implementation: The Current Status of the Trans Pacific Partnership and Its Implications for Manufacturers, Retailers and Distributors

Posted By Administration, Thursday, December 10, 2015
Updated: Wednesday, December 9, 2015

by Melissa Proctor, Polsinelli, P.C.


The Trans Pacific Partnership agreement ("TPP"), the largest comprehensive regional free trade and investment agreement that has ever been negotiated, is slated to be signed by twelve countries in the Asia Pacific region that represent roughly 40% of the world's economy. The Obama Administration has touted the TPP as a means for boosting U.S. exports, supporting higher paying jobs in the United States, growing the U.S. economy, and countering China's economic expansion. The full text of the agreement was made available to the public on November 5th.

What does all of this mean for retailers, distributors, and manufacturers? For starters, the TPP will eliminate import tariffs on more than 18,000 goods, many of which are currently subject to high duty rates. Although it may be quite a while before the TPP goes into force, companies are advised to take stock of the agreement, assess its potential impact on future sourcing decisions and international sales strategies, and contemplating the rollout of processes for making import claims under the TPP as well as responding to requests for TPP certifications from overseas customers. This article provides a brief overview of the current status of the TPP, the TPP's rules of origin and the requirements for making and supporting valid claims for preferential tariff treatment.

1. Current Status of the TPP and Its Entry into Force
For the past five years, the following countries have been actively negotiating the TPP: United States; Australia; Brunei; Canada; Chile; Japan; Malaysia; Mexico; New Zealand; Peru; Singapore; and, Vietnam. Negotiations officially concluded on October 4, 2015, and the signatory countries are slated to formally sign the agreement in New Zealand on February 4, 2016. Thereafter, the signatory countries' respective legislative bodies will have a maximum period of two (2) years in which to implement the TPP into their respective local laws.

With respect to implementation of the TPP in the United States, Section 106(a)(1)(A) of the Trade Priorities Act (Pub.L. 114-26) requires the President to notify Congress of his intent to enter into an international agreement, such as the TPP. President Obama provided that notification to Congress on November 5, 2015. The Trade Priorities Act also requires the President to sign the international agreement no later than ninety (90) days after providing notification to Congress, which will be February 3, 2016. On November 17, 2015, the U.S. International Trade Commission ("ITC") announced the commencement of an investigation on the likely economic impact of the TPP on the United States. Such ITC investigations are part of the international agreement implementation process and the ITC generally issues its reports to Congress when the implementing legislation is about to be voted upon. In the case of the ITC's investigation of the TPP, the impact analysis report is expected to be released on or around May 18, 2016. It is likely that Congress will delay its vote on the TPP implementing legislation until after the ITC's report has been released. Further, in light of the upcoming Presidential election at the end of 2016, there will likely be additional delays in the implementation of the TPP in the United States.

It should also be noted that the TPP will enter into force only after at least six of the signatory companies (that represent a minimum of 85% of the GDP of all of the participants) have implemented the agreement into their local laws. Thus, the TPP may not go into force until sometime in 2017 or later.

2. The TPP Rules of Origin and Direct Shipment Rule
As noted above, duties on more than 18,000 products will be eliminated under the TPP. However, only goods that are considered "originating" in a TPP member country will be afforded preferential tariff treatment. There are three ways in which a good may be eligible for preferential treatment under the TPP:

  • It is wholly obtained or produced entirely in the territory of one or more of the parties
  • It is produced entirely from TPP-originating materials
  • It satisfies the product-specific rules set forth in Annex 3-D to the agreement (e.g., regional value content rules, tariff-shift rules, etc.)

The agreement also provides a de minimis rule that will allow products containing non-originating materials to qualify for the TPP – where the product-specific rule of origin cannot be satisfied. Those goods will still be afforded preferential treatment if the value of all of the non-originating materials does not exceed 10% of the value of the finished good.

In addition to satisfying the TPP rules of origin, originating goods will only be eligible for preferential trade benefits if they have been transported directly from one member country to another without passing through the territory of a non-party. However, originating goods that transit a third country may still retain their TPP eligibility provided that: (a) they do not undergo any operation in the third country other than unloading, reloading, separation from a bulk shipment, storing, labeling or marking, or any other operation necessary to preserve them in good condition or to transport them to the importing TPP country; and, (b) they remain under the control of the customs authorities in the non-party's territory.

3. Making TPP Claims
Once the agreement goes into force, companies in TPP member countries may claim preferential tariff treatment on imports of qualifying goods. TPP claims may be made at the time of entry provided that the importer has the required certification statement. In addition, companies may submit retroactive claims for qualifying goods post-importation in order to obtain duty refunds – this scenario is likely where the required certification statement and supporting eligibility records were not available at the time of entry.

As noted above, importers are to make claims for preferential tariff treatment under the TPP based on a written certification of origin attesting to the fact that the goods in question satisfy the applicable rules of origin. The certifications are not required to be submitted to the importing country's customs authorities at the time of entry; rather, they must merely be in the possession of the importer when a claim is made. The certifications may be prepared by the exporter, producer or even the importer itself. The certification may apply to a single shipment or to multiple shipments made over the course of a 12-month period. Certifications may be submitted in English, but the importing country may also require that a translation into its local language be provided as well. There is no specified format for the certification or form that must be used. Rather, the certification must merely be in writing and contain the following data elements:

  • Names and addresses of the Importer, Exporter or Producer
  • Certifier's name, address, telephone number and e-mail address
  • Description and Harmonized System Tariff Classification of the goods
  • Invoice number (if known and if the certification of origin covers a single shipment)
  • Origin Criterion
  • Blanket Period covered by the certification
  • Signature and date of the certifier

As with other free trade agreement that are currently in force, it is likely that many of the importing TPP member countries will provide suggested templates or recommended formats for the certifications, though they will not be legally required to be utilized. Further, the certification must contain the following statement:

I certify that the goods described in this document qualify as originating and the information contained in this document is true and accurate. I assume responsibility for proving such representations and agree to maintain and present upon request or to make available during a verification visit, documentation necessary to support this certification.

Importers making TPP claims will be required to maintain documentation relating to their imports (including the certification of origin and additional documentary evidence that substantiates the goods' eligibility) for a period of five years from the date of importation. Similarly, exporters or producers that issue certifications to their customers must also maintain records for five years from the date the certifications were issued (as well as all records that demonstrate TPP eligibility).

At this stage of the TPP process, it is still too early to predict when the agreement will actually go into effect. However, it is a good idea for companies to begin thinking about how the TPP may impact their operations and whether it could be used for greater duty and cost savings in the future. Companies are urged to review the agreement, assess whether their goods or raw materials may qualify, monitor developments relating to the ITC's investigation and release of the draft U.S. implementing legislation down the road.


Melissa Proctor is a Shareholder with Polsinelli, P.C. With significant experience in the customs laws and regulations, export controls, economic sanctions, and international trade, Melissa is committed to understanding companies' operations and providing assistance geared toward helping them reach their specific business and operational goals. She may be reached at (602) 650-2002 or via e-mail at mproctor@polsinelli.com.

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Tags:  Exports  Imports  TPP  Trans Pacific Partnership 

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