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On Friday, February 13, 2015, the US State Department published on its website the “Section 515.582 List,” which describes the Cuban goods and services eligible for importation into the United States. This announcement is the latest component of the US Government’s recent relaxation of the comprehensive US embargo of Cuba, which we described in our recent blog post. The State Department also published a Fact Sheet with FAQs about the Section 515.582 List. Under Section 515.582 of the Cuban Assets Control Regulations (“CACR”), persons subject to US jurisdiction are authorized to engage in all transactions (including payments) necessary to import certain goods and services produced by independent Cuban entrepreneurs, as determined by the State Department. The Section 515.582 List published by the State Department provides the current list of eligible and excluded Cuba goods and services. Independent Cuban entrepreneurs (e.g., self-employed individuals; private small businesses; private cooperatives) from which certain goods and services may be imported must (i) be independent of Cuba’s state sector and (ii) provide documentary evidence that demonstrates their independent status (e.g., license to be self-employed issued by the Cuban Government; evidence that a private entity is not owned or controlled by the Cuban Government). All services from independent Cuban entrepreneurs are eligible for importation into the United States. All goods, except for those contained in certain sections/chapters of the US Harmonized Tariff Schedule (“HTS”) identified on the Section 515.582 List, are eligible for importation in the United States.

  • Eligible goods are those in the following HTS sections/chapters: Section VI (Chapters 33-34, 37); Sections VII to X (all Chapters); Section XI (Chapters 50, 53-63); Sections XII to XIV (all Chapters); Section XV (Chapters 82-83); Section XVIII (all Chapters); and Sections XX to XXII (all Chapters).
  • Excluded goods are those in the following HTS sections/chapters: Sections I to V (all Chapters); Section VI (Chapters 28-32, 35-36, 38); Section XI (Chapters 51-52); Section XV (Chapters 72-81); Sections XVI and XVII (all Chapters); and Section XIX (all Chapters).

Importation of eligible goods into the United States may be subject to applicable duties, taxes, and fees. This latest US Government action authorizes persons subject to US jurisdiction to import eligible Cuban goods or services into the United States. This new authorization does not extend to imports by persons subject to US jurisdiction, such as non-US entities owned or controlled by US companies, of Cuban goods or services into other countries. By Alexandre Lamy (Washington, DC),  Eunkyung Kim Shin (Chicago), Christopher W. Lucas (Washington, DC).


Alexandre Lamy joined Baker McKenzie in 2009 and currently works in the Firm's International Trade Practice Group. He assists clients with sanctions and export controls (Export Administration Regulations (EAR); International Traffic in Arms Regulations (ITAR)) and he advises clients on corporate compliance matters. Since August 2011, Alex has served on the steering group for the ABA Section of International Law’s Export Controls & Economic Sanctions Committee and is currently a Vice Chair of the Committee. He has organized several events regarding recent developments in US trade sanctions and export controls for the Committee.

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