The U.S. International Trade Commission is best known for deciding high-stakes trade disputes involving dumped or subsidized imports and infringement of intellectual property rights.  Worthy of at least equal attention, however, are the wide panoply of trade policy resources the Commission makes available free to the public.  Businesses, associations, and NGOs can all make use of the Commission’s expertise in support of their policy goals.

Looking for trade data?  Visit the Commission’s DataWeb service.  DataWeb is an interactive platform that provides access to import and export statistics, tariffs, and tariff preferences, including historical data going back to 1989.  Users can make and save customized product and country lists or generate reports for geographic regions, FTA partner countries, and trade preference programs.  Also accessible via DataWeb is the HTS Online Reference Tool, which allows users to search by Harmonized Tariff  System classification, translate common product descriptions into tariff compatible terminology, or translate between HTS classifications and other common product classification systems such as SIC, SITC, and NAICS.  The system is set up to permit users to download data to a spreadsheet.

Even with all the data available, stakeholders sometimes find that the kinds of data needed to advocate in support of their policy goals do not exist, even from a commercial source.  The Commission has a variety of tools for developing new trade data, most of which can be made public, at least in aggregated form.  Upon request from the Office of the U.S. Trade Representative, the Senate Finance Committee, or the House Committee on Ways & Means, the Commission can conduct a study under section 332 of the Trade Act of 1930, which grants the agency nationwide subpoena power to gather industry data through the use of questionnaires.  Recent studies collecting previously unavailable trade data include Used Electronics, Inv. No. 332-528 (Feb. 2013),  Remanufactured Goods, Inv. No. 332-525 (Nov. 2012), and Digital Trade II (forthcoming).  The Commission also heads up the interagency 484f Committee, under Section 484(f) of the Tariff act of 1930, which evaluates petitions requesting new statistical breakouts in the Harmonized Tariff Schedule.  The 484f process can be used to obtain import statistics on a product that would otherwise fall within a basket category.

The Commission’s extensive staff of trade economists and industry specialists are themselves valuable resources to those in the trade policy space.  Staff research papers on a range of international trade and investment topics are available on the web site, and staff members are often available to give presentations on current trade topics at industry and professional meetings.  Of particular note is the agency’s numerous recent reports on global supply chains.

For those engaged in public discourse on U.S. trade policy, international investment, or global competitiveness, the International Trade Commission’s treasure trove of data and analysis should not be overlooked.

Photo of Shara Aranoff Shara Aranoff

Shara helps clients navigate trade remedies, tariffs, and customs regulations in support of their U.S. and global market strategies.

Shara is the Chair of Covington’s International Trade Practice Group, and co-leads the Customs practice.

Drawing on her 20 years of service in the…

Shara helps clients navigate trade remedies, tariffs, and customs regulations in support of their U.S. and global market strategies.

Shara is the Chair of Covington’s International Trade Practice Group, and co-leads the Customs practice.

Drawing on her 20 years of service in the U.S. government, she develops legal and public policy strategies to assist clients engaging with the U.S. International Trade Commission (ITC), U.S. Customs and Border Protection (CBP), Congress, and the courts. In high-stakes antidumping and countervailing duty investigations, Shara helps global manufacturers, distributors, and retailers protect their access to the U.S. market. She assists technology, life sciences and manufacturing companies enforce and defend their intellectual property rights in cross-border Section 337 investigations. Chambers praises her for bringing “behind-the-curtain knowledge to the private sector” in proceedings before the ITC by leveraging her experience as a decision maker.

Shara also regularly advises clients in a wide range of industries on Customs compliance and tariff mitigation, including:

  • Providing legal opinions or seeking Customs rulings on classification, valuation, country of origin, and product marking/labelling.
  • Conducting internal compliance reviews, drafting compliance policies, and providing training.
  • Responding to CBP audits and inquiries and filing voluntary disclosures.
  • Developing strategies to reduce tariffs and take advantage of trusted trader programs.

Prior to joining the firm, Shara was a Commissioner and Chairman of the ITC, where she was a decision-maker in hundreds of Section 337, antidumping, countervailing duty, and safeguard investigations.

She previously served as Senior International Trade Counsel for Senator Max Baucus (D-MT) at the U.S. Senate Committee on Finance, where she was responsible for legislative and policy issues including Trade Promotion Authority; negotiations involving the World Trade Organization and free trade agreements; and trade remedy and customs laws. She was also an attorney-advisor in the Office of the General Counsel at the ITC, where she was lead counsel in litigation before the Court of Appeals for the Federal Circuit and the Court of International Trade.

Read more about Shara Aranoff
Show more Show less