Today Customs and Border Protection (CBP) published an updated version of its “Guidance for Reimbursement Certificates”; see https://www.cbp.gov/document/guidance/guidance-reimbursement-certificates.
In the memorandum, CBP reminds the public that regulations by the Department of Commerce (“DOC”) require that importers must file a certificate advising whether the importer has entered into an agreement, or otherwise has received reimbursement of AD duties, prior to liquidation of the entry.
Failure to file reimbursement certificates (stating that importer was not reimbursed) may double importer’s antidumping duties upon liquidation. CBP’s memorandum offers specifics on how to file the certificates and includes an example of a blanket reimbursement form.
The memo also outlines procedures for filing in ACE and ACS. Although CBP will accept paper reimbursement certificates, it is encouraging importers to file electronically.
CBP addresses other guidelines for filing reimbursement certificates, including the following:
• Required language for reimbursement certificates
• Instructions for filing blanket certificates
- Instructions for filing blanket certificates
• Information regarding reimbursement certificates submitted in a CBP protest
CBP also provides more details in regards to individual and blanket certificates, countervailing cases, and the process for when the exporter and importer of record are the same party, and if the importers are no longer in business.
For further information, please visit www.kelleydrye.com/Our-Practices/International/International-Trade or contact a Kelley Drye attorney.