U.S. Customs and Border Protection has determined that there is a reasonable suspicion that ten importers evaded the antidumping and countervailing duty orders on oil country tubular goods from China by transshipping such goods through Thailand.

As a result of this determination CBP is imposing the following interim measures.

- suspending liquidation of each unliquidated entry of covered goods entered by the named importers on or after Feb. 23, 2024, and extending the liquidation period for subject goods entered before that date

- if necessary, requiring a single transaction bond or additional security or the posting of a cash deposit with respect to such goods

- requiring live entry, meaning the importer must submit proper import documentation and cash deposits prior to the release of its goods from CBP custody; rejecting any entry summaries that do not comply; and requiring refiling of entries within the entry summary rejection period

- possibly evaluating the importers’ continuous bond to determine their sufficiency

Under the Enforce and Protect Act any interested party, including competing importers and federal agencies, may submit allegations that AD/CV duties are being evaded; e.g., by misrepresenting the goods’ true country of origin, submitting false or incorrect shipping and entry documentation, or misreporting the goods’ physical characteristics. CBP has broad authority to investigate these claims and can impose initial remedial measures that could interrupt a supply chain in as little as 90 days. Any final determination of evasion may be met with not only AD/CV duties but also other enforcement measures such as civil or criminal investigations.

For more information on AD/CV duty evasion, please contact attorney Kristen Smith at (202) 730-4965 or via email

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