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NRDC Steps Up Fight Against GRAS Notices

NRDC Steps Up Fight Against GRAS Notices

OFW Law has broad experience in matters before U.S. Customs and Border Protection (“CBP”), including both administrative proceedings before CBP and judicial proceedings before the federal courts, including:

  • Tariff classification and valuation
  • Country-of-origin determinations and marking requirements
  • Drawback 
  • Penalty and forfeiture proceedings
  • Detentions and seizures
  • Voluntary disclosures
  • Participation in tariff preference programs such as NAFTA, the Generalized System of Preferences, and other special regimes 
  • Development of customs compliance programs

In addition to CPB requirements, there are other FDA and USDA requirements affecting imports and exports.  FDA has the authority to stop regulated products at the border and require that individual entries be examined and tested prior to entry.  OFW regularly assists clients in obtaining relief from such Import Alerts by working with clients before the agency to design and implement measures to address FDA’s concerns, whether those concerns be directed to a particular company, a commodity, or an area or country of production.  Many plant products and animal products, including other products containing animal ingredients (e.g., in vitro diagnostic test kits or test kit components), may require either APHIS import permits or approval for export.  Importation of food products from certain regions may be restricted to prevent the spread of animal disease and plant materials must be cleared in order to protect U.S. agriculture.  Our attorneys can assist in identifying such import/export restrictions and assist in developing procedures and certifications to ease international trade in such products.

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