Import

$5.15 Million Settlement Highlights Growing Customs Enforcement Under the False Claims Act

Short summary: A Taiwanese manufacturer has agreed to pay $5.15 million to resolve allegations that it violated the False Claims Act by underpaying customs duties on imported goods. According to the Department of Justice, the company used improper customs practices to reduce duties owed to CBP, resulting in significant lost tariff revenue. The settlement underscores the federal government’s continued focus on customs enforcement and the growing use of the False Claims Act to pursue alleged duty evasion. 


The U.S. Department of Justice recently announced that a Taiwan-led manufacturer agreed to pay $5.15 million to resolve allegations under the False Claims Act and related administrative claims involving customs duties owed on imported goods. While the company did not admit liability, the settlement serves as another reminder that customs compliance remains a significant enforcement priority for the federal government. 

The Case – What Happened 

According to the DOJ, the alleged conduct went well beyond a simple classification error. The government alleged that the company used multiple methods over several years to reduce the customs duties it owed on imports. Specifically: 

  • Country of Origin Misrepresentations: From July 2018 through January 2022, Everlight allegedly knowingly misrepresented the country of origin on Chinese-manufactured LEDs. Everlight knew these products were manufactured in China, and then transshipped to Taiwan, before shipping them to the U.S.  Everlight allegedly misrepresented to CBP that the products originated in Taiwan rather […]

DOJ and DHS Publish Comprehensive Trade Fraud Enforcement Guide: What Importers Need to Know 

Short summary: The DOJ and DHS have jointly published a new Resource Guide to Trade Fraud Enforcement, highlighting the government’s coordinated approach to combating customs fraud and strengthening import compliance. The guide explains key enforcement authorities, common trade fraud schemes, and the government’s expectations for importers, customs brokers, and others participating in global supply chains.


The U.S. Department of Justice (DOJ) and Department of Homeland Security (DHS) have released a new 31-page Resource Guide to Trade Fraud Enforcement, providing one of the clearest public statements yet on how the federal government views customs fraud, enforcement priorities, and importer compliance obligations. The guide was developed by the Trade Fraud Task Force, a partnership that includes DOJ’s National Fraud Enforcement Division, Homeland Security Investigations (HSI), U.S. Customs and Border Protection (CBP), and other federal agencies. 

While much of the guide summarizes existing laws and enforcement authorities, its significance lies in the government’s messaging. It makes clear that customs violations are no longer viewed as merely technical or administrative issues. Instead, DOJ and DHS repeatedly characterize trade fraud as a threat to economic security, national security, public safety, and human rights, signaling that aggressive enforcement will continue across multiple agencies. 

Combatting Trade Fraud Is a Priority for the Federal Government 

One of the report’s primary themes is that trade fraud extends far beyond the underpayment of duties. According to the guide, fraudulent import practices undermine domestic manufacturers, deprive the government of […]

IEEPA Tariff Refund Update: CIT Will Order Reliquidation of Some Finally Liquidated Entries 

Short summary: The U.S. Court of International Trade has announced that it plans to order U.S. Customs and Border Protection (CBP) to reliquidate certain finally liquidated entries in approximately 3,700 pending IEEPA tariff refund cases once CAPE Phase 3 launches. The court also confirmed that CBP continues to expand CAPE’s refund capabilities, including future functionality for entries with open protests, and provided an update on the billions of dollars in refunds already being processed. These developments represent another significant step toward resolving pending IEEPA tariff refund claims for importers. 


The U.S. Court of International Trade (CIT) has announced another significant development in the ongoing litigation over tariffs imposed under the International Emergency Economic Powers Act (IEEPA). In a July 15, 2026, order, Judge Richard K. Eaton confirmed that the court intends to direct U.S. Customs and Border Protection (CBP) to reliquidate certain finally liquidated entries in the approximately 3,700 pending CIT IEEPA refund cases once the next phase of CBP’s Consolidated Administration and Processing of Entries (CAPE) refund system becomes operational. 

While the order does not immediately authorize refunds of liquidated entries, it provides important insight into how the court and CBP plan to move thousands of pending refund claims toward resolution. 

Reliquidation Order Planned for Thousands of Cases 

The court stated that, in connection with the anticipated launch of CAPE Phase 3, it will issue an order directing CBP to reliquidate certain finally liquidated entries […]

Understanding HTSUS Classification: Why Getting It Wrong Is Expensive

Summary: HTSUS classification determines the duty rate, applicability of tariffs such as Section 301 and Section 232, trade program eligibility, and helps determine whether any AD/CVD duties apply to every imported product. Misclassification often goes undetected for months or years, and since importers tend to reuse the same code for every entry of the same product, a single error can compound into significant back duties, penalties, and prior disclosure obligations. This article breaks down how classification errors happen, what reasonable care looks like, and how a documented classification process can prevent a small mistake from becoming a costly one. 


Every product entering the United States must be assigned a classification code under the Harmonized Tariff Schedule of the United States (HTSUS), and that ten-digit number determines far more than most importers realize. It sets the duty rate and tariffs owed on a shipment, flags whether a product needs additional agency review, and establishes whether it qualifies for preferential trade programs. A misclassification, even an unintentional one, can trigger back duties, penalties, and a prior disclosure process that could have been avoided entirely with the right classification from the start. 

What HTSUS Classification Actually Determines 

The Harmonized Tariff Schedule of the United States is the United States’ implementation of the international Harmonized System, a standardized numerical method of classifying traded products used by customs authorities around the world. Every entry filed with U.S. Customs and Border Protection (CBP) requires an HTSUS code, and […]

Mandatory CPSC eFiling is Here

Key Takeaways 

  • Starting July 8, 2026, importers of most regulated consumer products must electronically file (eFile) Certificate of Compliance data into CBP’s ACE system at the time of entry, no longer on request. 
  • At launch, CPSC does not intend to have ACE reject entries or deny admission solely for failure to eFile, only warning messages. But CPSC will still enforce certificate requirements, seek seizure of non-compliant goods, and adjust your risk score. 
  • A testing exemption or determination does not eliminate the certificate. You must still issue a certificate citing the rule and naming the exemption. This is a trap that catches importers who assume “exempt” means “nothing to file.” 
  • Products entering a Foreign Trade Zone and later withdrawn for consumption or warehousing get a later effective date: January 8, 2027
  • The eFiling rule changes how certificate data is filed, not which products need a certificate. Certification has been required since 2008. 

A Compliance Shift Disguised as a Filing Update

Since 2008, importers and domestic manufacturers of CPSC-regulated consumer products have been required to maintain a Certificate of Compliance: a Children’s Product Certificate (CPC) for children’s products, or a General Certificate of Conformity (GCC) for regulated general-use products, and produce it on request. Under […]

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