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Regulatory Explainers

Wrong AD/CVD Scope on Your Entries: Detection and 19 USC 1520(d) Recovery

Anti-dumping and countervailing duty scope errors are the highest-dollar liquidation surprise in the US import stack. This guide walks through scope determination mechanics, the detection patterns the LandedFees engine flags, and the four post-entry recovery mechanisms in order of applicability.

Undervaluation Red Flags: Benchmark Invoices Against FRED PPI Before CBP Does

CBP valuation enforcement runs on statistical anomaly detection at scale. If your invoice unit price is more than one standard deviation below the industry Producer Price Index benchmark, an Automated Targeting System flag is likely. Here is how the LandedFees engine benchmarks invoice values against FRED PPI series and factory-quoted comparables so importers see the flag before CBP does.

Section 338 Canada T-Minus 1: ACE Summary Acceptance vs 3461 Transmission, 19 CFR 141.68 Timing Mechanic, and the 500k CIF Ontario Furniture Worked Example

T-1 to the Aug 22 12:01 AM EDT Section 338 Canada cliff. Deep dive on 19 CFR 141.68 time-of-entry, ACE Summary Acceptance latency, and defensive Immediate Transmission election.

Section 338 Canada T-0 Cliff Day: CBP CSMS Still Silent, First 24-Hour Playbook for Brokers, FTZ Operators, and IORs

Section 338 Canada goes live at 12:01 AM EDT August 19 2026 under the three July 20 Presidential Proclamations and U.S. Note 51 to Chapter 99 Subchapter III. As of 7:30 PM EDT August 18, CBP has not published its implementing CSMS. This is the first-24-hour operator playbook covering the CSMS silence gap, regional variance forecast between LA/LB and the Great Lakes and Northeast, the operator conversation script for Form 214 PF admissions, and the PSC queue formation math on a 500k CIF Ontario furniture shipment classified under HS 9403.30.