China continues to engage in U.S. tariff fraud by transshipping products through other countries including Thailand, Indonesia and Sri Lanka

U.S. Customs and Border Protection has stated that there is a reasonable suspicion that an importer is evading the antidumping and countervailing duty orders on forged steel fittings from China by transshipping subject goods through Indonesia, Sri Lanka, and Thailand. As a result, CBP is requiring that for any imports of forged steel fittings from Indonesia, Sri Lanka, and Thailand the importer deposit estimated duties at the time of entry. CBP will also evaluate the importer’s continuous bond and require single transaction bonds as appropriate.

Under the Enforce and Protect Act any interested party, including competing importers and federal government 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.

CBP is imposing “interim measures” on C.I.S. Investments after preliminarily finding in an Enforce and Protest Act (EAPA) investigation that the importer evaded antidumping and countervailing duty orders on Chinese-origin forged steel fittings. The case is based on an allegation by Flatlands that CIS evaded AD/CVD orders by transshipping the subject fittings through Sri Lanka, Indonesia, and Thailand. Flatlands alleges that two exporters in Sri Lanka and one exporter each in Thailand and Indonesia were involved in the transshipment scheme.

Jeffrey Newman is a whistleblower lawyer who can be reached at or at 978–880-4758