SCOPE RULINGS Q1:

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1 Thank you for participating in the NEI Webinar on AD/CVD & Scope Rulings held on Wednesday, January 20, 2016, with the Department of Commerce (DOC). Please find below a complete list of questions that were submitted during the webinar and answered to the best of our knowledge. If you have any further questions, please contact Lisa Gelsomino at lgelsomino@avalonrisk.com or the DOC s Customs SCOPE RULINGS Q1: Can you go over how to find on the website a scope for an AD/CVD case? Please refer to slides from the presentation as noted below or link to the DOC website at and search under Antidumping and Countervailing Duty Operations or Products Currently Subject to AD/CVD Orders. CBP also issued a CSMS message on 12/1/15 to address this question from the trade: CSMS# Avail of Scope Ruling and Anti-circumvention Determ Summaries for Active AD/CVD Orders.

2 Q2: Published scope rulings are very helpful as resources to determine when aluminum extrusions and candles are subject to ADD. How can we find scope ruling information for other products? This was answered during the webinar and in Q1 above. A short summary of DOC s scope rulings since 1990 can be found on the DOC website at Click on Antidumping and Countervailing Duty Operations towards the bottom of the page, then click on Products Currently Subject to AD/CVD Orders under Scope Information on the bottom left. Currently, all scope rulings issued on four cases since 1990 are available on this site. The DOC is also working to update the website with scope rulings as far back as 1990 for all current orders, but these must be scanned individually and will take more time. Q3: Are there restrictions on who can request a scope ruling? importers, brokers, consultants? Any party that files a scope ruling must be an interested party in the proceedings, which is defined by statute at 19CFR (c)(1). The DOC also received a response from legal office: Pursuant to 19 CFR (c)(1), any interested party may apply for a ruling as to whether a particular product is within the scope of an order. To qualify as an interested party, an entity must meet one of the definitions in section 771(9) of the Tariff Act of 1930, as amended (the Act ) (see 19 USC 1677(9)), and 19 CFR (b)(29). An importer of merchandise subject to an antidumping or countervailing duty order would be considered an interested party pursuant to section 771(9)(A) of the Act. Brokers and consultants do not qualify as an interested party, but may appear as a non-attorney representative before Commerce in a representative capacity for an interested party. See 19 CFR (d)(1), (g), (b), Q4: What is the best course of action to request a scope ruling? Scope rulings must be requested in writing and filed in the DOC s ACCESS system. The best course of action is to start on the DOC website under How to Request a Scope Ruling and then call the CLU at with any questions. The CLU will assist or put you in touch with the case team that handles that specific AD/CVD order. The direct link to the website is Q5: Can a scope ruling, with specifics, be relied upon by another party (competitor) in making a determination that their product (similar) would also be included or excluded. Or does each company need to secure a scope ruling themselves to be considered compliant? This was answered during the webinar and goes back to the difference between a binding ruling from CBP vs. a scope ruling from DOC. You should always come to the DOC for your own scope ruling and there are certain cases or circumstances that require it. If there is already a scope ruling for another company with the same exact product type as yours, pursuing another scope ruling would not alter the outcome of your own scope ruling. Lug nuts are a good example of this because the commodity was very standard for each importer. Cake-shaped candles from China is a good example of where a separate scope ruling was always required to be excluded from the AD/CVD Order because the nature of each candle was so unique and different. Q6: Can you file a scope ruling for products imported in prior periods when there is a dispute with CBP whether the goods are covered by the scope? This is a bit more complicated. You may file a scope ruling at any time, but how that will apply retroactively depends on several circumstances. If the DOC determines that a product is not covered by the scope of an order, that decision is retroactive for all unliquidated entries subject to the scope ruling. This would not apply to entries that have already liquidated since that is not feasible, and the law doesn t provide for it. Q7: On the DOC website why is China missing from the Products Subject to AD/CVD Duties? You will need to look under People s Republic of China to find the scope rulings for products subject to AD/CVD from China. Please refer to the following CBP message for further guidance: CSMS# Avail of Scope Ruling and Anti-circumvention Determ Summaries for Active AD/CVD Orders.

3 Q8: Currently, how long do binding rulings take on average? The DOC does not handle binding rulings; these pertain to the classification of imported goods and are obtained from CBP s Office of Regulations & Rulings. If you are inquiring about how long it takes the DOC to process a scope ruling, the time frame can vary from 45 days or much longer if there is a scope inquiry and/or additional litigation. According to 19CFR (c), the DOC will respond to scope rulings as follows. Please refer to the regulation for full details: Within 45 days of the date of receipt of an application for a scope ruling, the Secretary will issue a final ruling under paragraph (d) of this section or will initiate a scope inquiry under paragraph (e) of this section. (d) Ruling based upon the application. If the Secretary can determine, based solely upon the application and the descriptions of the merchandise referred to in paragraph (k)(1) of this section, whether a product is included within the scope of an order or a suspended investigation, the Secretary will issue a final ruling as to whether the product is included within the order or suspended investigation. The Secretary will notify all persons on the Department s scope service list (see paragraph (n) of this section) of the final ruling. (e) Ruling where further inquiry is warranted. If the Secretary finds that the issue of whether a product is included within the scope of an order or a suspended investigation cannot be determined based solely upon the application and the descriptions of the merchandise referred to in paragraph (k)(1) of this section, the Secretary will notify by mail all parties on the Department s scope service list of the initiation of a scope inquiry. Q9: You gave an example of when an "industry tolerance" caused the product to fall within the scope of the ruling. Is this something that occurs frequently and is it strictly based on a common industry tolerance or are there other factors that could come into play when applying tolerances to a scope? The example provided, lug nuts, is based on a standard industry tolerance. But every industry and product is different. How tolerance levels impact whether or not a product is covered by the scope of a particular order would depend upon several things including the language of the scope and possibly, but not always, standard tolerances for the product within the industry. Q10: Can you define difference between when a case is "revoked" vs. "terminated"? Yes, there is a difference as discussed during the webinar. Revoked and Terminated both mean the entire case or order goes away, but for different reasons. Terminated means that a domestic party is no longer interested in pursuing the case, or the DOC has found no injury to move forward so the case is Terminated. Revocation is what happens after an AD/CVD Order is in place, such as a Five-Year Sunset Review. In these cases, the DOC may revoke the order. There are also times when there is a partial revocation where one company may be removed from an AD/CVD Order, but this is based on old legislation that has been rescinded, but you may still see this occur in older cases. Q11: Could you please provide some definitions around the ACE ADCVD case status? Some cases are inactive - order revoked versus Inactive - Terminated versus deactivated? What would be the best way to define the different status that are entered for ADCVD cases in ACE and what is the difference between these? For a discussion regarding the terminology revoked and terminated please see the response to Q10. The term Inactive-Company Deactivated means that a company-specific (or chain specific) case number has been turned off and entries are no longer allowed to be made under that 10-digit case number. For example, in non-market economy cases when an exporter loses its separate rate at the end of an administrative review and is subsequently treated as part of the NME-entity. Future entries that used to be allowed to enter under that case number would subsequently have to be entered under the case # ending in -000.

4 Another example would be when an exporter that was part of a manufacturer /exporter chain rate is granted an exporter rate in an administrative review; the chain rate is deactivated, and future entries from that exporter would enter under the new exporter-specific rate. An Inactive Company Deactivated does not mean that the order is no longer in place for that company, but rather that the company-specific or chain-specific 10-digit case number is no longer valid for use. Q12: If a company specific scope is revoked/terminated are they still subject to "general scope"? Yes, if an individual product or group of products is/are found by DOC to be outside the scope, the order is still relevant to the company s products that meet the narrative description of the scope of that order and country of origin. Once an AD/CVD Order is issued, foreign manufacturers and exporters may qualify for an individual rate by participating in an administrative review process with the DOC. If the exporter or manufacturer (as appropriate) does not have an individual rate, the importer s entries will be liquidated at the All Others rate. The ability to partially revoke a company from an AD/CVD Order has been rescinded. AD/CVD CLASSIFICATION & MARGINS Q13: If an HTS flags for AD/CVD and product falls under the scope of the case, but the shipper/manufacturer is not on the list, will this importer be subject to ADD? Yes, the importer would be subject to AD/CVD and should be classified as Entry Type 03. If there is no rate provided for the specific shipper or manufacturer, you must use the All Others Rate that applies country-wide. This is typically much higher than an individual rate that shippers/manufacturers obtain through a detailed review process with the DOC. Q14: Are ADD(03) entries still required for specific companies with 0% specific ADD rate? Yes, an AD/CVD entry must still be declared because the 0% rate is only an estimate and is subject to change with any new shipper proceedings and/or administrative reviews due to the retrospective nature of our system (see Slide 26). As referenced in Q23 below, even a 0% rate at time of entry can later change to a higher rate. Q15: What should we do if an item falls under an ADD scope, but the HTS number(s) is not flagged, and we are not able to declare the ADD within the entry? CBP in the past has advised to reclassify an item under the HTS that has the ADD flag, but it isn't the correct HTS for the commodity? In cases where the appropriate HTS # is not identified with the case in ACE, you may ask the port to please request that DOC add the HTS # to the ACE Case Reference File. Additionally, you may contact the CLU Call Center to alert DOC to the issue. DOC will then follow up with CBP to ensure that the party is requesting the appropriate HTS #, and as soon as that is confirmed, DOC will add the HTS #. To the extent you need to file an entry that is not correctly flagged for AD/CVD, you should use the correct HTS number to process the entry and follow the procedures CBP has provided for a Post Summary Correction. Please see CSMS# Post-Summary Correction where AD/CVD Duty is Due, which states: This is an important reminder to all importers and brokers that an importer of record must deposit estimated Antidumping and Countervailing Duties (AD/CVD) at the time a Post-Summary Correction (PSC) or Post-Entry Amendment (PEA) is filed when the PSC/PEA is submitted to amend the following: An entry type 01 is changed to correctly identify the AD/CVD entry type 03; A change/correction is made to an entry type 03 that results in additional AD/CVD being owed. The importer s failure to deposit AD/CVD may result in a claim for liquidated damages. For further information, see the Federal Register notices for PEAs and PSCs published at 76 FR 37136, June 24,

5 Q16: When there is a foreign manufacturer and a foreign supplier and they both have case numbers, which case applies for the customs entry? The Federal Register Notice will outline the hierarchy of what AD/CVD margin applies in each case. A good example of this was the Sebacic Acid case from China, Case# A Sebacic Acid produced by Hengshui was only exempt from the PRC-wide all others rate of 243.3% when Tianjin was also the exporter of record. If Tianjin was not the exporter of record on a specific transaction, Hengshui was subject to the PRC-wide all others rate. Q17: If an Exporter in the country of production has its own case #, but the goods are being exported out of Canada (not the country of production), can the exporter's case # still be used? Or does the "all other" case # need to be used? DOC s cash deposit instructions identify what party s rates may be used for cash deposit purposes. When a third-country reseller of merchandise does not have its own individual rate, it may use the cash deposit rate of its supplier from the country under the order. However, it is important to note that the assessment rate may change if the manufacturer or exporter is subject to a new shipper or administrative review. Q18: If a commodity that has ADD was imported and ADD paid, then the product is found nonconforming to the importer. It is of no value or use to the importer. Can the product be destroyed under customs supervision and a refund be provided to the importer? With regard to refunds of AD/CVD duties, the statute and regulations clearly prohibit any remission, abatement refund or drawback of duties See 19 U.S.C. 1558, and 19 CFR 191.3(b)(3). Once the merchandise has been released from CBP custody, the importer is not entitled to a refund of AD/CVD duties. Q19: For goods classified as a set and the HTS code of the item that occurs last to classify the set is subject to AD like pencil for example in as stationary case, does the AD applies to the entire set and the total value of the shipment? Generally, the AD/CVD just applies to the portion of merchandise that is subject to AD/CVD duties. However, please review the language of the scope of the relevant AD/CVD to be certain. Please also see procedure for handling these special value shipments on CBP s website at Q20: Who enters ADCVD Case information into ACE? CBP or DOC directly? How often are the instructions or is the information in ACE updated? The DOC enters the information into ACE and updates it as needed through the various AD/CVD proceedings, such as new orders, annual administrative reviews, etc. Preliminary findings in administrative reviews don t have an impact on the border due to NAFTA so an update would not be made until the findings are final. The case analysts do have specific timeframes to update the information, which is typically 5 business days for a new case requiring cash deposits and 15 calendar days for liquidation instructions once an order gets issued or an administrative review is completed (41 days for orders on products produced in NAFTA countries). Q21: When we submit an inquiry through ACE for AD/CVD on a particular tariff#, the response back does not show any information. Is this our software issue or ACE query issue? As mentioned in Q20 above, the DOC must update ACE with information within specific timeframes. As mentioned in Q15, if the entry is not being flagged for AD/CVD, you should first reach out to your ABI vendor for clarification. If not due to an ABI error, you should reach out to the DOC directly by calling the CLU call center at or ask the port to please request that DOC add the HTS # to the ACE Case Reference File.

6 Q22: If a rate to a case is found to be lower than what the importer has paid will a refund be issued? Yes, the importer would receive a refund if the assessment rate is found to be lower than the estimated duties provided at time of entry. This would occur at liquidation and include any interest that accrues during the time period the funds were held by CBP (the interest provision does not apply to cash deposits paid during the provisional measures phase of an investigation). Q23: With regards to issuing liquidation instructions to CBP, can you comment about circumstances which would cause the original duty deposit to increase and therefore an importer receive an additional invoice? There are many reasons why this can occur during the various proceedings of the AD/CVD process because of the retrospective nature of our AD/CVD system. At the time of entry, estimated duties are paid at the AD/CVD duty rate in effect at that time. However, that rate is subject to administrative review and could change upon completion of a review by the DOC. Once the review is completed, sometimes as much as two to three years later, the DOC provides instructions to CBP to liquidate the entries at the final AD/CVD rates. If the shipper had its own AD/CVD rate, this rate could increase through the administrative review process or revert to the All Others country-wide rate if the shipper no longer qualifies for its own rate. The best way to illustrate this is by example using an Administrative Review of Wooden Bedroom Furniture from China (PRC). On 6/17/15, the DOC issued its Final Review for entries falling within the 2013 Period of Review. In its final results, the DOC determined that 24 exporters reverted to the All Others PRC-wide country rate of %. As a result, DOC deactivated 13 company (or company grouping) 10-digit case numbers associated with that AD order. In instances where companies had their own AD/CVD rate when they imported in 2013, they paid the estimated duties upon entry and over two years later, upon completion of the administrative review, they lost their separate rates so their assessment rate increased to % upon liquidation of the entries. CBP then has six months to liquidate the entries from the date the DOC issues its liquidation instructions.

7 Q24: After a CF29 was issued to assess ADD and CVD duties, the FP&F officer advised that only those entries which did not already liquidate were impacted, and that liquidated entries were subject to the importer's discretion -- meaning, they would only have to pay the duties if they *volunteered* to. Is that accurate? It seems to contradict the retrospective. The entries listed in a CF29 are just a Notice of Action and are not due until the entries actually liquidate and generate the supplemental/increased duty bills for the amount of AD/CVD and interest that is due. Once the bills are generated, they must be paid or protested within 90 days from liquidation for entry dates prior to 12/18/04, or 180 days from liquidation for entry dates on or after 12/18/04. While importers may voluntary tender AD/CVD duties that are due if there is no protestable issue, CBP can process voluntary reliquidation using 19USC1501 to correct any errors within 90 days of liquidation. The importer is also subject to 19USC1592 penalties if the AD/CVD duties are not paid. Q25: The non-reimbursement certificate is for ADD only, not CVD, correct? Your slide indicated both. Generally, that is correct. A non-reimbursement certificate is not required for CVD cases unless there is a companion Anti-Dumping proceeding. For more information, please see CBP.gov at Q26: So what happens when an importer discloses entries of AD goods when the liquidation has occurred but certificates were not provided (because the entry was not filed as an 03). Can they still provide certificate? The regulations that became effective April 27, 1989, require importers to file the reimbursement certificate prior to liquidation per 19CFR (f). Currently liquidation occurs on the date that the bulletin notice of liquidation is posted in the Customs house. The importer of record has until the bulletin is posted to provide CBP with the certificate of reimbursement. For more information, please see CBP.gov at Q27: What happens to the monies collected under ADD/CVD orders? In most instances, the duties are collected by CBP just like any other duties or fees that CBP collects on behalf of the U.S. Government. However, there is a period of time where AD/CVD entries were subject to the Continued Dumping and Subsidy Offset Act of 2000 (CDSOA), otherwise known as the Byrd Amendment. Based on legislation put forth by Senator Robert Byrd of WV, CDSOA was enacted by Congress on October 28, 2000, and was repealed on October 1, 2007, consistent with a determination made by the World Trade Organization (WTO). The provisions of the CDSOA allow for AD/CVD duties collected by CBP to be distributed to domestic producers injured by foreign dumping and subsidies. Per the repeal, AD/CVD duties collected on entries made prior to October 1, 2007, are still eligible for CDSOA at liquidation. The AD/CVD duties that CBP collects subject to the CDSOA are publicly available at CBP.gov at: GENERAL QUESTIONS Q28: Who at CBP or C&E is responsible to ensure that entries get liquidated timely and do not stay unliquidated for long periods beyond the lifting of suspension or court injunction? E&C is responsible for issuing timely liquidation instructions to CBP once suspension of liquidation is lifted. E&C generally issues such instructions within calendar days (NAFTA countries 41 days). Once in receipt of the liquidation instructions, CBP is responsible for effecting the liquidation in a timely fashion. CBP import and entry specialists, under the supervision of port or Centers of Excellence (CEEs) management, are responsible for liquidating AD/CVD entries. Q29: Can the trade access the DOC templates? No. Unfortunately, the templates the DOC uses to provide instructions to CBP cannot be shared with the trade since they must be updated with relevant information and could be misconstrued.

8 Q30: What is a market economy and non market economy? What is the difference? In determining whether a country should be treated as a Non-Market Economy (NME) under section 771(18)(A) of the Act, section 771(18)(B) requires that the Department of Commerce (DOC) take into account six factors: The extent to which the currency of the foreign country is convertible into the currency of other countries; The extent to which wage rates in the foreign country are determined by free bargaining between labor and management; The extent to which joint ventures or other investments by firms of other foreign countries are permitted in the foreign country; The extent of government ownership or control of the means of production; The extent of government control over the allocation of resources and over the price and output decisions of enterprises; and Such other factors as the administering authority considers appropriate. If the DOC has designated a country as an NME, this determination remains in effect until revoked by the administering authority, pursuant to section 771(18)(c)(i) of the Act. For the DOC to conduct a review of a country s NME status, the country s government must make a formal request for a review, or support a respondent s claim in an antidumping case, that the country has a market economy. After the DOC receives a formal request, there is an analysis of the six factors outlined above to determine whether to treat the country in question as an NME. If a country has not been formally designated as an NME, it is presumed to be a market economy. If an interested party alleges that the country is an NME and documents its allegation with respect to each of the factors listed above, the DOC will initiate a formal inquiry to determine whether the country should be treated as an NME (See E&C Policy Bulletin 03.1, February 28, 2003). Q31: Is the standard Power of Attorney authorizing a Broker to transact customs business for an importer enough to also allow requesting a scope ruling? As discussed during the webinar, the customs broker is not considered an interested party in a DOC scope ruling proceeding. The DOC also received this response from their legal office: Pursuant to 19 CFR (c)(1), any interested party may apply for a ruling as to whether a particular product is within the scope of an order. To qualify as an interested party, an entity must meet one of the definitions in section 771(9) of the Tariff Act of 1930, as amended (the Act ) (see 19 USC 1677(9)), and 19 CFR (b)(29). An importer of merchandise subject to an antidumping or countervailing duty order would be considered an interested party pursuant to section 771(9)(A) of the Act. Brokers and consultants do not qualify as an interested party, but may appear as a non-attorney representative before the Department of Commerce in a representative capacity for an interested party. See 19 CFR (d)(1), (g), (b), We also checked with NCBFAA legal counsel who advised that the process of applying for a scope ruling from the DOC does not fall within the definition of customs business so the standard power-of-attorney (POA) would not specifically contemplate this type of activity. A customs broker should receive specific authorization from its client to assist with the scope ruling. Because AD/CVD matters and scope rulings can be quite complex, the customs broker should be sure that terms and condition of service are acknowledged in writing to address any assistance provided in a scope ruling from the DOC or general AD/CVD matters. A customs broker should also maintain an errors and omissions (E&O) policy that is going to cover any mistakes made in handling AD/CVD transactions and/or scope rulings and/or providing advice on AD/CVD matters. In a nutshell, a customs broker is not an interested party in a DOC scope ruling, and must evaluate the risks of taking on such services very carefully and in consultation with its Customs attorney, insurance broker, and client.

9 Q32: What risks are there for the broker, if any, when an importer is found to be subject to antidumping? i.e., what preventive measures do you recommend that brokers maintain? In the eyes of CBP or the DOC, customs brokers do not take on the risk of being liable for AD/CVD duties unless they act as the Importer of Record, which is never recommended by the NCBFAA or from a risk management perspective. Customs brokers are regulated by CBP under the provisions of 19CFR111. There is also a new provision for penalties against customs brokers in the Customs Reauthorization Bill. Congress recently passed this law, and the President is expected to sign it soon. The provision would then take effect within 180 days of execution: SEC CUSTOMS BROKER IDENTIFICATION OF IMPORTERS. (a) IN GENERAL. Section 641 of the Tariff Act of 1930 (19 U.S.C. 1641) is amended by adding at the end the following: (i) IDENTIFIC ATION OF IMPOR TERS. (1) IN GENERAL. The Secretary shall prescribe regulations setting forth the minimum standards for customs brokers and importers, including nonresident importers, regarding the identity of the importer that shall apply in connection with the importation of merchandise into the United States. (2) MINIMUM REQUIREMENTS. The regulations required under paragraph (1) shall, at a minimum (A) identify the information that an importer including a nonresident importer, is required to submit to a broker and that a broker is required to collect in order to verify the identity of the importer; (B) identify reasonable procedures that a broker is required to follow in order to verify the authenticity of information collected from an importer; and (C) require a broker to maintain records of the information collected by the broker to verify the identity of an importer. (3) PENALTIES. Any customs broker who fails to collect information required under the regulations prescribed under this subsection shall be liable to the United States, at the discretion of the Secretary, for a monetary penalty not to exceed $10,000 for each violation of those regulations and shall be subject to revocation or suspension of a license or permit of the customs broker pursuant to the procedures set forth in subsection (d). Because AD/CVD is a Priority Trade Issue (PTI), it is important to be compliant with AD/CVD requirements. NCBFAA has a Broker Known Importer Program (BKIP) that provides a detailed questionnaire that can help better understand the complex nature of AD/CVD exposures. Importers of AD/CVD products are liable to CBP for the exposure they take on for the estimated duties due at the time of entry as well as any change in duties that may occur under the retrospective nature of our system (even if the margin is 0% at the time of entry). The AD/CVD margin can change (increase, decrease or remain the same) years later after the DOC completes its review for many different reasons as outlined in Q23 above. As preventive measures, please see Q31 above for additional guidance. Customs brokers should ensure they handle AD/CVD business under proper instruction from the client, power-ofattorney that addresses the services being offered, and acknowledgement of terms and conditions of service that limit liability for handling AD/CVD entries. Customs brokers and their importer clients should be aware and responsible for the following: Importers must know the scope of their product based on applicable scope rulings from the DOC and corresponding HTS classifications from CBP (provided for convenience only). The applicable AD/CVD cash deposit margin that applies to the importer of record based on the foreign manufacturer, exporter of record, and country of origin as outlined in the Federal Register Notices that are issued once an AD/CVD Order is effective. Once an AD/CVD Order is issued, the AD/CVD margins paid at entry are only estimates and are subject to change for each administrative review and different stages of proceedings. It is often the case that a foreign manufacturer s AD/CVD rate may fluctuate each year and/or increase to the country-wide all others rate if the foreign manufacturer no longer qualifies for its own rate.

10 In certain cases, the AD/CVD margin is different for the foreign manufacturer and the exporter of record. The importer is responsible for knowing their supply chain and vetting their suppliers to ensure the correct AD/CVD margin is utilized. Any change in the foreign manufacturer, exporter of record, or country of origin can also change the AD/CVD margin that will apply to merchandise that is imported and fluctuate as outlined above based on each period of review or different stages of proceedings. Importers are liable to CBP for penalties under 19USC1592 for fraud and duty evasion. Importers and customs brokers should be cautious of AD/CVD evasion that can result from: o Alteration of the product (i.e., honey vs. honey syrup), o Trans-shipment (i.e., claiming country of origin is Taiwan when the true origin is China) o Evasion that CBP reports on CBP.gov at In particular, see AD/CVD SCAM ALERT and AD/CVD Enforcement Updates. o CBP encourages the trade to report violations or suspected criminal/illegal activity to BE-ALERT or (800) or CBP.gov under e-allegations at: We hope you have found this Q&A from the NEI webinar helpful, and please do not hesitate to contact one of the presenters with any additional questions you may have. Please also remember to review information provided by the DOC on its web page at and by CBP on its designated web page at