The process for importing goods into the United States generally involves at least two private parties (exporters and importers) as well as the U.S. government. The U.S. AD/CV duty collection process typically involves the five steps summarized below and illustrated in figure 1. 1. Commerce communicates the initial estimated duty rate to CBP: Commerce issues an AD/CV duty order that specifies the products for which importers must pay AD/CV duties. The order communicates the initial estimated duty rates applicable to one or more specific exporters, producers, or both, as well as a catchall rate or, if appropriate, a countrywide rate for all other exporters and producers that were not individually investigated and that did not receive a specific rate. The order also instructs CBP to collect cash deposits at the time of importation for estimated duties owed on all entries of the applicable products. These duty rates represent Commerce’s initial estimates of the level of dumping or subsidization. Commerce typically communicates to the public the initial estimated duty rate that must be applied in the Federal Register. 2. CBP reviews importers’ assessments of duties owed and collects the initial estimated duty from the importer: The importer determines the value of estimated duties owed by applying the initial rate set in the applicable AD/CV duty order to its imports. CBP reviews the importer’s assertions for correctness and collects the required cash deposits or bonds from the importer. According to CBP officials, estimated duties are usually due within 10 days after CBP has released the product for entry into the United States. 3. Commerce determines and communicates the final duty rate to CBP: Each year, during the anniversary month of the publication of an AD or CV duty order, an interested party may ask Commerce to conduct an administrative review to determine the actual amount of dumping or subsidization and calculate a final duty rate. This can occur if the party believes that the initial estimated rate is too high or too low. During the administrative review, Commerce analyzes previous imports to determine the actual level of dumping or subsidization for those imports during the period under review. At the conclusion of the administrative review (typically about 12–18 months after the review began), Commerce establishes the final duty rate (also known as the liquidation rate) for the goods. If an administrative review is not requested, then the final duty rate is generally the same as the initial estimated duty rate. Commerce typically communicates to the public the final duty rate that must be applied in the Federal Register. Commerce sends CBP liquidation instructions communicating the final duty rate and designating the importers, producers, or both that are associated with the entries to which the rate must be applied. According to CBP officials, the liquidation instructions are communicated first to the AD/CV Division, a headquarters unit within CBP’s Office of Trade. 4. CBP instructs ports to apply the final duty rate and calculate final duties: CBP instructs staff at each applicable U.S. port of entry to assess the final duties on all relevant goods (i.e., applying the final rate to the value of applicable goods that have entered since the order was issued). 5. CBP liquidates the import entry and may issue a refund or a bill: CBP liquidates the entry, which can result in CBP’s issuing a bill to the importer (if the liquidation rate is higher than the initial estimated rate) or refunding money (if the initial estimated rate is higher than the liquidation rate). If the initial estimated and final duty rates are the same, CBP liquidates the entry without issuing a bill or refund. CBP must liquidate these entries within a 6-month time limit that begins when CBP receives a notice, such as final duty rate instructions from Commerce or notification from a court or another agency that the suspension of liquidation that was placed on those entries has been lifted. Otherwise, the entry will be liquidated by operation of law at the initial estimated duty rate regardless of whether the final rate has changed. This is referred to as a “deemed liquidation.” To ensure payment of unforeseen financial obligations to the U.S. government, most importers are required to post a security, usually a customs bond. The bond is like an insurance policy protecting the U.S. government against revenue loss if an importer defaults on its financial obligations. CBP allows importers to provide two types of basic importation and entry customs bonds—a continuous entry bond and a single transaction bond—to secure the duties, taxes, and fees associated with the import of goods into the United States. Continuous entry bonds are used to secure financial obligations for one or more entries for a period of up to 365 days; single transaction bonds are used to secure financial obligations related to a specific entry. If an importer fails to pay the full amount owed on a final duty bill for an AD/CV duty entry, CBP will attempt to collect payment from the company that underwrote the bond for the entry (referred to as the “surety”). The amount CBP may be able to collect from the surety depends on how much the bond covers. In some cases, the bond issued by the surety may cover the entire amount owed; in other cases, it may only cover a small portion of the debt—depending on the size of the bond and size of the additional duties resulting from a higher final duty rate. One of CBP’s key challenges is to set an accurate bond amount for any given entry that reasonably protects the amount of revenue that is potentially at risk of loss if the final duty bill for that entry is not paid in full. An importer who is billed for additional AD/CV duties has 180 days from the date of liquidation to protest the bill amount. CBP will send the importer monthly bills. According to CBP officials, if CBP does not receive full payment of the bill for additional duties within approximately 8 months of sending the bill and the importer does not file a protest, CBP sanctions the delinquent importer by requiring full payment of all estimated duties, taxes, and fees before any products subsequently imported by that importer can be released by CBP into U.S. commerce. Separately, if the bill has not been paid 60 days after it was issued, CBP will also request payment from the surety that underwrote the bond that the importer provided when the goods entered the United States. After CBP has requested payment from a surety, that surety has 180 days to pay the bond amount or protest the bill. Importers are responsible for the full amount of additional duties owed; sureties will generally cover the cost of a bill only up to the value of the bond. The AD/CV duty collection process is completed when and if the importer, the surety, or the two together pay the full amount of the duty and interest owed or the duty is written off. CBP’s ports generally handle the bill creation process, including collecting payments for duties that are not delinquent from importers. However, if a bill becomes delinquent, the Revenue Division within CBP’s Office of Finance takes the primary responsibility for collecting payment from either the importer or the surety or both. In general, if CBP does not receive full payment of duties and interest owed, CBP’s Revenue Division researches the account and recommends next steps to CBP’s Office of Chief Counsel, which determines whether options for collection are available through the legal process. The Office of Chief Counsel in turn can refer the matter to the Department of Justice for prosecution. When CBP determines that a bill for additional AD/CV duties is uncollectible, the Revenue Division and the Office of Chief Financial Officer, in conjunction with the Office of Chief Counsel, can take steps to write off the bill. Figure 2 illustrates the process for collecting payments on bills for additional AD/CV duties and writing off uncollectible bills. Our analysis shows that the total amount of unpaid AD/CV duty bills issued for goods that entered the United States during fiscal years 2001 through 2014 was about $2.3 billion as of May 12, 2015. However, in its Performance and Accountability Report for fiscal year 2015, CBP reported that it did not expect to collect about $1.6 billion in outstanding AD/CV duty debt. Most AD/CV duty bills are paid: We estimate that, on average, CBP collected duties owed for about 90 percent of the total number of AD/CV duty bills issued for entries from fiscal years 2001 through 2014. However, CBP’s collection rate for AD/CV duties measured by the total dollar amount paid as a portion of the total amount owed averaged about 31 percent for bills issued on entries during this time. Our analysis shows that AD/CV duty bills with unpaid amounts are concentrated among a small number of importers, with 20 importers accounting for about 50 percent of the $2.3 billion owed. CBP continues to face challenges in collecting on AD/CV duty bills, attributable in part to the U.S. government’s retrospective and complex process for determining final AD/CV duty rates. The average lag time between entry of goods and CBP issuing a bill for any additional duties during fiscal years 2001–2014 was about 2.6 years. Out of all AD/CV entries during this period that we examined, the final duty rate was higher than the initial estimated rate assessed upon entry about 18 percent of the time, and the final rate was lower than the initial estimated rate about 19 percent of the time. According to agency officials, CBP is considering the feasibility of contracting with private collection agencies to pursue debts for which the agency has exhausted all administrative collection efforts, including claims against applicable surety bonds.