EAPA Cons. Case 8052: Various Importers (Notice of Initiation of Investigation and Interim Measures, January 28, 2025)

EAPA Action: Notice of Initiation of an Investigation and Interim Measures for EAPA Cons. Case 8052 – Thermal Paper

WASHINGTON — On January 28, 2025, CBP issued the notice of initiation of investigation and implemented interim measures for EAPA Cons. Case 8052 filed by the Paper Receipts Converting Association, against U.S. importers, Lollicup USA Inc. (Lollicup), Lifeguard Gloves (also known as DuroSafe Inc.) (collectively, Lifeguard), FAV Holdings LLC (FAV Holdings), Direct Marketing USA (Direct Marketing), E Merchant Supplies (E Merchant), Quality Paper Distributors, Inc. (Quality Paper), and Top Traders, Inc. (Top Traders) (collectively, the Importers) for evasion of the antidumping duty orders on lightweight thermal paper from the People’s Republic of China (China), Germany, Japan, and/or Republic of Korea (case numbers A-570-920, A-428-850, A-588-880, and A-580-911, respectively); and countervailing duty order on lightweight thermal paper from China (C-570-921). Specifically, the allegations suggested that the Importers entered thermal paper either from China, Germany, Japan, and/or South Korea into the United States via transshipment through Malaysia and failed to declare the correct country of origin at the time of entry. For one importer, Quality Paper, CBP has not imposed interim measures but rather is issuing Quality Paper a formal notice of investigation. For the remaining importers, because evidence establishes a reasonable suspicion that E Merchant, Lollicup, Lifeguard, FAV Holdings, Direct Marketing, and Top Traders entered merchandise into the United States through evasion, CBP has taken the following interim measures:

• Require “live” entry for all imports of mattresses, meaning E Merchant, Lollicup, Lifeguard, FAV Holdings, Direct Marketing, and Top Traders must submit proper import documentation and duties prior to the release of their merchandise;
• Suspend or extend entries of E Merchant, Lollicup, Lifeguard, FAV Holdings, Direct Marketing, and Top Traders without final computation or determination of duties (liquidation), as appropriate; and
• Review continuous bonds of E Merchant, Lollicup, Lifeguard, FAV Holdings, Direct Marketing, and Top Traders and application of single transaction bonds for their entries, as appropriate.

These actions do not preclude CBP from taking additional enforcement measures as it determines appropriate under its EAPA or other legal authorities, which include pursuing civil penalties or investigations into criminal violations.

For additional information on CBP and EAPA, please visit the EAPA Homepage. If you suspect an importer of duty evasion, CBP encourages you to submit an allegation through our online portal.

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