Last year, President Obama signed into law the Trade Facilitation and Trade Enforcement Act of 2015 (“TFTEA”).  Section 421 of the TFTEA (commonly called the Enforce and Protect Act, or EAPA), establishes procedures for submitting and investigating allegations of evasion of antidumping and countervailing duties.

The statute encouraged a wide variety of stakeholders to participate in this new administrative process.  For example, the statute defined “interested parties” who may file an allegation of evasion to include foreign exporters and producers, importers, and domestic manufacturers and wholesalers, of products covered by antidumping and countervailing duty orders.  Indeed, interested parties on all sides of the trade equation who play by the rules have an incentive to participate in the CBP’s evasion investigations. …
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