Enforce and Protect Act (EAPA)
Enforce and Protect Act (EAPA) is Title IV of the Trade Facilitation and Trade Enforcement Act of 2016, giving CBP an administrative procedure to investigate importers suspected of evading antidumping and countervailing duties.
What it requires
Domestic producers or agencies may file allegations; CBP must decide whether to initiate within 15 business days, impose interim measures within 90 days if there is reasonable suspicion, and issue a determination within 300 calendar days, extendable to 360. Interim measures include suspending liquidation, requiring cash deposits and limiting single transaction bonds. Importers found to have evaded duties through transshipment, misclassification or undervaluation owe them and can face Section 592 penalties.
Why it matters
EAPA is the main tool CBP uses against transshipment, such as Chinese goods routed through Vietnam or Malaysia to avoid antidumping duties, so it matters to any operator importing products under AD/CVD orders like quartz surfaces, aluminum extrusions or wooden cabinets. If a client's supplier is named in an allegation, CBP can require cash deposits on new entries within 90 days, tying up working capital. A 3PL acting as importer of record should verify factory origin and keep production records.
Related laws
Sources
Not legal advice.