That’s Not ‘Buy America’
Various Origin Requirements in the United States for Importers

Harold Rader Jackson, Associate Attorney
[email protected]

Harold Jackson advises clients on a variety of issues related to international trade law. His areas of practice focus on import laws and export controls, representing companies before governmental agencies, including U.S. Customs and Border Protection (CBP), the Department of Defense’s Directorate of Defense Trade Controls (DDTC), the Food and Drug Administration (FDA), Department of Commerce’s Bureau of Industry and Security (BIS) and Census Bureau, Department of Energy’s National Nuclear Security Administration (NNSA), Department of the Interior’s U.S. Fish and Wildlife Service (FWS), and Department of the Treasury’s Office of Foreign Assets Controls (OFAC). He assists companies across a range of industries, including aerospace, medicine and medical devices, oil and gas, electronics, textiles and wildlife products, industrial equipment, logistics and customs brokerage, and other areas.

Career Highlights
Harold regularly advises companies on Customs and U.S. trade issues, such as tariff classification, valuation, bonds, country of origin and substantial transformation, Section 232 (Steel/Aluminum) and 301 Duties (China Tariffs) and exclusions, Antidumping & Countervailing Duties, forced labor enforcement, and tariff mitigation strategies. He assists clients with protests, prior disclosures, penalty and successor liability, liquidated damages, redelivery, seizures, intellectual property violations, Federal Procurement Contracts (Buy America, Buy American), CBP investigations, CBP ruling requests, labeling, Foreign Trade Zones (FTZ), drafting import compliance manuals and training, and litigation before the U.S. Court of International Trade.
In the export arena, Harold assists companies navigate the various U.S. export controls, including International Traffic in Arms Regulations, the U.S. Export Administration Regulations, and various sanction regimes (including sanctions on Russia, Iran, China, and designated persons). He advises clients on a variety of export control issues, such as applying for licenses before various agencies, filing voluntary disclosures, drafting export compliance manuals and training, preparing Commodity Jurisdiction requests, determining the classification of goods and technology under the Commerce Control List (CCL) and U.S. Munition’s List, and compliance screening for economic sanctions.

Leadership
Harold is a member of the Customs and International Trade Bar Association (CITBA), the International Bar Section of the State Bar of Texas, and the ICPA International Compliance Professionals Association (ICPA).

Credentials
Licensed in Texas, Harold earned his J.D. from South Texas College of Law in Houston, where he served as the Assistant Director of the International Trade & National Security Society and participated in the Trademark and Clara Barton Constitutional Law Clinics. He received his B.B.A. in Finance from the Bauer College of Business at the University of Houston. Harold is admitted to practice before the U.S. Court of International Trade and the U.S. District Court for the Southern District of Texas.