U.S. Customs and Border Protection has clarified its policy regarding collection efforts on bills for supplemental duties, taxes, and fees and vessel repair duties.

Effective March 26, CBP will start mailing dunning letters 120 days from the date of a bill to outline what will happen if payment is not received or a protest is not filed within 180 days. CBP states that “in general” if a protest is filed within 180 days the agency will not divert payments owed to the importer for refunds or place the importer on sanction until the protest has been decided. These policies represent a change from CBP’s August 2017 announcement that dunning letters would be issued on the 61st day after issuance of a bill and that collection activities (such as diverting refunds) would commence on any bill older than 60 days.

However, it is not clear what CBP means by “in general” when describing when it will divert refunds or sanction an importer that has not filed a protest even though time remains under the 180-day protest period. Importers should therefore take dunning letters seriously, even if they intend to file a timely protest.

For more information, please contact Michael Cerny at (212) 549-0160.

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