Entry / Entry Summary

AD/CVD, EAPA, Liquidation, Protests & Penalties

What happens after the entry summary: liquidation and its extensions, protests and the Court of International Trade, 1592 penalties and prior disclosure, petitions for relief, AD/CVD deposits and the EAPA evasion process. Most questions are deadlines and maximum amounts, so the numbers here are worth memorising.

Entry / Entry Summary4 min read8 sections

Must-know for the exam

Liquidation: 1 year from entry or deemed liquidated as the importer asserted; extensions up to 1 year each, 3 years total, 4-year outer limit (19 CFR 159.11-159.12).
Formal-entry liquidation notice is posted on cbp.gov and dated that day; ABI notices are courtesy only (159.9).
Protest within 180 days of liquidation or decision (entries since Dec 18, 2004); filed when CBP receives it (174.12(e)-(f)).
CBP decides protests within 2 years; exclusion protests and accelerated disposition requests within 30 days, else deemed denied (174.21-174.22).
Sue in the Court of International Trade within 180 days after the denial (174.31).
1592 maximums without prior disclosure: fraud domestic value; gross negligence lesser of value or 4x loss (40%); negligence 2x (20%) (162.73(a)).
With prior disclosure: fraud 1x loss (10%); negligence or gross negligence interest only. Certified mail counts from mailing (162.73(b), 162.74(d)).
Petitions: seizure 30 days, penalty 60 days, bond claim 60 days, surety 60 days from demand (171.2, 172.3-172.4).
EAPA: initiate within 15 business days, interim measures by day 90, determination by day 300 (360), review request within 30 business days (Part 165).

On this page · 8 sections

Traps that cost marks

Using the four-year outer limit for an entry that was never extended.
Assuming CBP's own view of the duties applies to a deemed liquidation.
Thinking an extension can be requested after the 1-year period ends.
Confusing the 3-year cap on extensions with the 4-year outer limit.
Treating the ABI courtesy notice as the official notice.
Applying the formal-entry notice rules to an informal entry.
Starting interest at the bill date instead of the deposit date.
Using the 90-day period that applies only to entries before December 18, 2004.

Why it matters on the exam

These rules sit in the Entry / Entry Summary category, the largest on the exam (25 questions). Expect a date to count, a penalty ceiling to compute, or a choice of remedy (protest, petition, prior disclosure).

Liquidation

Rule	Detail	Cite
Deadline	1 year from entry or final warehouse withdrawal	159.11(a)
Deemed liquidation	At the rate, value, quantity and duty asserted by the importer	159.11(a), 159.12(f)
Extension	Up to 1 year at a time: CBP needs information, or importer shows good cause in writing before expiry	159.12(a), (d)
Cap	Extensions total 3 years; 4 years from entry unless suspended by statute or court order	159.12(e)-(f)
Notice	Posted on cbp.gov, dated that day; informal entries liquidate on payment	159.9, 159.10

Interest on an underpayment runs from the deposit due date to liquidation (24.3a(b)(2)(i)).

Premium

Every note. Every question. One pass.

6 more sections of this note are part of Premium.

Every section of every study note
1,000+ original questions across every outline topic
Full timed practice exams
A worked explanation on every question
Your full mistake bank and weak-area review

Unlock with Premium

From about US$12.42/mo on the Until-you-pass pass (12 months)

Exam-style questions

← Previous note: Trade Agreements & Special Programs All study notes