Press & Resources
Special Reports & Research
In-depth analysis, research papers, and comprehensive reports on trade fraud
In-depth analysis, research papers, and comprehensive reports
U.S.–China Section 301
Tariff Evasion: 2018–2025
Alliance for Trade EnforcementNOW
U.S.–China Section 301 Tariff Evasion: 2018–2025
Alliance for Trade EnforcementNOW comprehensive research study examining the scope, methods, and impact of Section 301 tariff evasion on Chinese imports from 2018 through 2025. The report documents how systematic evasion schemes — including transshipment, misclassification, undervaluation, and de minimis abuse — have undermined U.S. trade policy objectives and cost American businesses and workers billions in lost revenue and market share. Drawing on enforcement data, industry testimony, and economic analysis, the study provides a definitive account of how determined actors exploit gaps in customs enforcement and offers concrete policy recommendations for closing those gaps.
CBP Needs to Improve Its Oversight and Monitoring of Penalty Cases
DHS Office of Inspector General comprehensive audit examining CBP's oversight and monitoring of penalty cases across all enforcement operations. The report identifies critical deficiencies in how CBP manages penalty assessments, tracks collections, and maintains accountability for duty evasion enforcement, revealing systematic failures in penalty administration and revenue recovery. The audit findings demonstrate how inadequate tracking systems and inconsistent enforcement practices undermine the effectiveness of trade enforcement, allowing violators to escape consequences while compliant businesses face unfair competition.
CBP Investigations Into Underpayments of Duties
Treasury Inspector General critical report examining CBP's investigations into duty underpayments across all import categories. The report reveals significant enforcement challenges, including inadequate staffing levels, inconsistent processes across ports, and persistent difficulties in recovering lost revenue from importers who systematically undervalue goods or deliberately misclassify merchandise to evade proper duty payments. The audit exposes how resource constraints and procedural inconsistencies create enforcement gaps that sophisticated importers exploit, resulting in billions in uncollected revenue annually.
Comments to the US International Trade Commission Regarding the Economic Impact of Revoking China's PNTR Status
Information Technology and Innovation Foundation (ITIF) formal comments to the USITC examining the economic impact of revoking China's Permanent Normal Trade Relations (PNTR) status. The analysis finds that revoking PNTR could cost up to $7 billion annually to national power industries and $36 billion to non-national power industries. ITIF supports revocation as a last resort if China fails to meet its WTO commitments, while recommending mitigation strategies including gradual tariff increases for highly dependent goods and temporary tax rebates for national power industries. The report identifies 930 product categories dependent on Chinese imports, with 474 classified as highly dependent.
New Head of DOJ Trade Fraud Task Force Signals Aggressive Enforcement Shift
Mayer Brown analysis of DOJ Criminal Division Senior Counsel Cody Matthew Herche's first formal remarks as Head of the Trade Fraud Task Force, delivered February 23, 2026. Herche announced a "fundamental shift" toward criminal investigations and prosecutions, emphasis on individual accountability, and expanded interagency partnerships with the FDA, EPA, and CPSC. The DOJ reported $6.8 billion in False Claims Act recoveries in 2025 and $140 million recovered by the TFTF to date. Herche outlined four strategic initiatives: expanded agency partnerships, data-driven lead generation, engagement with Inspectors General to identify non-compliant federal contractors, and forced labor enforcement collaboration. The address makes clear that trade fraud penalties are no longer simply a cost of doing business, and companies with compliance gaps face heightened risk of criminal resolution.
Identifying Tariff Evasion: A Framework for Measuring Unexplained Trade
A 2026 USITC working paper offers a practical framework for spotting possible transshipping by measuring "unexplained trade" — trade that falls outside normal expected patterns. Its findings point to trade flows that may reflect rerouting to avoid tariffs or sanctions, while making clear that the method is an indicator of risk, not proof of wrongdoing. The framework provides enforcement agencies and policymakers with a systematic analytical tool for identifying suspicious trade patterns that warrant further investigation, helping to prioritize limited enforcement resources on the highest-risk trade flows.
Krishnamoorthi, DeLauro Issue Statement on Empowering Trade Fraud Prevention Task Force
Representatives Raja Krishnamoorthi and Rosa DeLauro issued a powerful statement on empowering the Trade Fraud Prevention Task Force to dramatically strengthen enforcement against tariff evasion, customs fraud, and illegal trade practices that severely harm American manufacturers and workers. The lawmakers emphasize the urgent need for enhanced interagency coordination, increased enforcement resources, and stricter penalties for trade criminals who systematically violate U.S. trade laws. The statement signals Congressional commitment to providing the Task Force with necessary tools and authority to combat sophisticated fraud schemes. The legislators specifically call for expanded investigative capabilities, improved data sharing between agencies, dedicated funding for advanced detection technologies, and legislative reforms to close loopholes that enable evasion. They highlight alarming statistics showing billions in annual revenue losses from tariff fraud and underscore how enforcement failures create unfair competitive disadvantages for law-abiding American businesses.
Made in China 2025: Evaluating China's Performance
US-China Economic and Security Review Commission comprehensive strategic assessment of China's ambitious "Made in China 2025" industrial policy initiative, examining the strategic goals, implementation progress, and profound implications for U.S. economic competitiveness and national security. The report analyzes China's state-directed efforts to achieve global dominance in advanced manufacturing and emerging technologies through massive government subsidies, coerced forced technology transfer, and systematic market-distorting industrial policies. The assessment evaluates how these unfair practices undermine global trade rules, disadvantage American manufacturers, and threaten critical supply chain security.
CX-0125 Traceability Use Case Standard
Catena-X Automotive Network comprehensive technical standard defining precise rules and protocols for tracing physical parts and materials across the entire value creation chain in automotive manufacturing. Enables standardized exchange of quality investigations, quality alerts, and block notifications to address defective parts in a coordinated manner across the complex supply chain. This traceability framework provides essential infrastructure for verifying origin claims, detecting counterfeit components, and ensuring compliance with trade regulations and country-of-origin requirements. The standard establishes interoperable data models and API specifications that enable real-time tracking of components through multi-tier supply networks, creating an immutable audit trail that customs authorities and manufacturers can leverage to combat fraudulent origin declarations and ensure regulatory compliance. This technical framework represents a critical tool for preventing tariff evasion through sophisticated supply chain documentation and verification mechanisms.
U.S. Businesses Across Industries Launch Alliance to Spotlight Trade Fraud and Demand Enforcement Outcomes
American businesses from multiple industries have joined forces to form a new alliance focused on exposing trade fraud and demanding tangible enforcement outcomes from government agencies. This unprecedented coalition brings together manufacturers from diverse sectors who have all suffered competitive harm from systematic tariff evasion and customs fraud by foreign competitors. The alliance represents a coordinated effort to amplify the voices of domestic businesses that have struggled individually to get enforcement agencies to prioritize trade fraud cases. Coalition members are pooling resources to document evasion schemes, sharing intelligence on fraudulent import patterns, and jointly advocating for legislative and regulatory reforms to strengthen enforcement capabilities and close loopholes that enable widespread violations.
CPA Welcomes DOJ and DHS Partnership on Cross-Agency Trade Fraud Task Force
The Coalition for a Prosperous America (CPA) welcomes the announcement of a new cross-agency trade fraud task force partnership between the Department of Justice and Department of Homeland Security, marking a significant step forward in combating trade crime and protecting American workers and businesses. This historic interagency collaboration represents a major milestone in trade enforcement, bringing together DOJ's criminal prosecution capabilities with DHS's investigative resources and customs expertise to mount a coordinated assault on tariff evasion and customs fraud. CPA emphasizes that this task force addresses longstanding concerns about fragmented enforcement efforts, where cases fell through jurisdictional cracks between agencies with overlapping but uncoordinated mandates. The organization calls for adequate funding and staffing to ensure the task force can effectively investigate and prosecute the massive volume of trade fraud cases, and urges swift action to demonstrate that trade criminals will face serious consequences.
Unpacking the Early Tariff Impact on China's Exports
ING comprehensive economic analysis examining the initial effects of tariffs on Chinese export patterns and trade flows during the opening phase of enhanced enforcement. The report provides detailed data-driven insights into how tariff policies are fundamentally reshaping China's export strategy and global supply chain dynamics, with profound implications for trade enforcement and monitoring systems. Analysis reveals adaptive strategies employed by Chinese exporters and identifies emerging patterns of trade diversion that enforcement authorities must anticipate and counter. The research examines specific sectors experiencing the most significant disruption, quantifies the magnitude of export shifts to alternative markets, and evaluates the effectiveness of current enforcement mechanisms in tracking these evolving trade routes. This analysis is particularly valuable for understanding how Chinese companies are restructuring their export operations to minimize tariff exposure while maintaining global market access.
Primer: The Threat of Tariff Evasion Within the U.S.
Comprehensive foundational primer from America Renewing examining the severe and growing threat of tariff evasion within the United States across multiple industry sectors. Analyzes sophisticated schemes used to systematically circumvent trade enforcement, the devastating economic impact on American manufacturers, and detailed policy recommendations to strengthen customs enforcement and close critical loopholes exploited by trade criminals. The report documents enforcement gaps, provides case study examples of successful prosecutions, and outlines necessary legislative and regulatory reforms to protect American industry. The primer includes detailed analysis of common evasion techniques such as transshipment through third countries, systematic undervaluation of imports, deliberate misclassification of goods, and fraudulent country-of-origin certifications. It quantifies the economic harm inflicted on specific manufacturing sectors and proposes concrete resource allocation priorities to maximize enforcement effectiveness and deter future violations.
How the China trade shock impacted U.S. manufacturing workers and labor markets and the consequences for U.S. politics
Comprehensive in-depth analysis by Washington Center for Equitable Growth examining the profound economic and political consequences of dramatically increased trade with China on American workers and manufacturing communities across the nation. The research documents how the China trade shock devastated entire regional economies, caused mass factory closures, eliminated millions of manufacturing jobs, and fundamentally reshaped political alignment in affected communities. Analysis reveals lasting effects on wages, labor force participation, and intergenerational economic mobility in regions hit hardest by import competition. The study employs rigorous econometric methods to trace causal links between Chinese import penetration and outcomes including increased disability claims, reduced marriage rates, declining birth rates, and rising mortality from drugs and alcohol in manufacturing-dependent regions. This research demonstrates how trade policy failures created concentrated economic devastation that persists decades later, with profound implications for current enforcement priorities and the urgent need to prevent continued erosion of American industrial capacity.
Digital Trojan Horse
Comprehensive strategic analysis of how digital technologies and trade policies critically intersect with national security concerns, examining vulnerabilities in digital infrastructure, supply chain dependencies, and data sovereignty. The analysis explores how foreign adversaries leverage commercial trade relationships to gain access to sensitive technologies, compromise critical infrastructure, and collect strategic intelligence. Particular focus on the risks posed by embedded software, hardware backdoors, and dependencies on foreign-controlled digital platforms that create national security vulnerabilities. The report documents specific case studies where ostensibly commercial technology imports have facilitated espionage, intellectual property theft, and the insertion of surveillance capabilities into critical systems. It provides detailed policy recommendations for screening foreign technology investments, establishing secure supply chain verification protocols, and developing domestic alternatives to reduce dangerous dependencies on adversarial nations for essential digital infrastructure components.
The Economic Influence of China and the United States on Southeast Asia
US-China Economic and Security Review Commission testimony by Dr. Vikram Nehru, Senior Fellow at the Foreign Policy Institute, Johns Hopkins University School of Advanced International Studies, examining the competing economic influence of China and the United States in Southeast Asia and recent trends in regional economic integration. The testimony analyzes China's growing economic integration with Southeast Asian economies, which serve as a critical southern hinterland providing essential components, raw materials, and manufacturing capacity that enable China's export dominance. Dr. Nehru warns that the current China economic shock is likely to be more severe than previous disruptions, with uncertain prospects for Southeast Asian economies to adjust without triggering unemployment crises or financial instability. The testimony emphasizes strategic recommendations for U.S. policy, urging focus on sectors where America maintains comparative advantage over China, particularly in advanced services, high-technology industries, including advanced semiconductor manufacturing, telecommunications, and aerospace. This analysis provides critical insights into the regional dynamics of U.S.-China economic competition and the strategic imperative for enhanced American engagement with Southeast Asian partners to counter China's growing economic influence and ensure regional stability in the face of intensifying trade tensions.
The China Wash: Tracking Products To Identify Tariff Evasion Through Transshipment
A February 2025 policy report from Caroline Freund at UC San Diego's 21st Century China Center presents a new product-level methodology for estimating transshipment of Chinese goods through third countries like Mexico and Vietnam. The study finds that after the 2018 tariffs on China, transshipment through Vietnam peaked at over 7 percent of imports in 2020 before declining, while Mexico never exceeded 1.5 percent. Top transshipped products include solar panels and static converters, with an estimated $1.25 billion in tariff revenue avoided per country. The report also identifies Singapore and Thailand as alternative hubs, warning that cracking down on one route simply pushes evasion to others — a "whack-a-mole" dynamic that demands a broader enforcement strategy.
The Persistence of the China Shock
Harvard Kennedy School groundbreaking research examining the long-term effects of Chinese import competition on U.S. labor markets, analyzing how the initial trade shock continues to profoundly impact American workers and entire manufacturing communities many years after the initial disruption began. The study reveals that contrary to economic models predicting rapid adjustment, affected workers experienced permanently reduced earnings, diminished career prospects, and lasting regional economic decline. Research demonstrates how concentrated import exposure created persistent "scarring" effects that span generations in impacted communities. The analysis finds that workers displaced by Chinese imports never recovered their previous earnings trajectories, with losses compounding over time as career advancement opportunities evaporated and skills atrophied. The research provides compelling evidence that trade adjustment assistance programs and retraining initiatives failed to meaningfully mitigate these devastating long-term impacts, fundamentally challenging the assumption that free trade's benefits outweigh its costs when enforcement mechanisms fail to ensure fair competition.
University of Toronto Munk School Report
Rigorous academic research report from the Munk School of Global Affairs & Public Policy at the University of Toronto examining critical issues in international trade, comprehensive policy analysis, and global economic governance frameworks. The research provides scholarly perspectives on trade enforcement mechanisms, the effectiveness of current regulatory approaches, and recommendations for strengthening international cooperation on trade compliance and customs enforcement practices. The report draws on extensive empirical evidence and comparative analysis across multiple jurisdictions to identify best practices and policy gaps in the global trade enforcement architecture. It emphasizes the growing sophistication of evasion schemes and the urgent need for modernized enforcement tools and enhanced cross-border information sharing among customs authorities to maintain the integrity of international trade rules.
Reset, Prevent, Build: A Strategy to Win America's Economic Competition with the Chinese Communist Party
House Select Committee on the CCP comprehensive strategic report outlining detailed recommendations for economic competition with China. The three-pillar strategy addresses how to Reset existing economic relationships, Prevent further technology transfer and industrial espionage, and Build American economic resilience through strengthened trade enforcement, supply chain security, and domestic manufacturing capacity. The report provides actionable policy prescriptions for Congress and the executive branch to protect American economic interests and national security. The analysis details specific legislative initiatives needed to close enforcement gaps, establishes metrics for measuring progress in reducing strategic dependencies, and outlines investment priorities for rebuilding critical manufacturing sectors. It emphasizes the urgency of coordinated action across government agencies and between public and private sectors to counter China's coordinated state-directed economic strategy that systematically undermines fair competition through subsidies, forced technology transfer, and intellectual property theft.
How the US Lost the Solar Power Race to China
Bloomberg comprehensive interactive analysis examining how China came to completely dominate the global solar industry and the profound strategic implications for American energy independence and manufacturing capacity. The investigation traces how massive Chinese government subsidies, technology theft, forced technology transfers, and predatory pricing systematically destroyed American solar manufacturing while creating Chinese monopoly control over critical renewable energy supply chains. Analysis reveals national security vulnerabilities created by U.S. dependence on Chinese solar components for energy transition goals. The report documents how American solar companies that pioneered breakthrough technologies were driven out of business by Chinese competitors selling below cost, enabled by state subsidies exceeding $50 billion. It examines the geopolitical leverage China now wields over global clean energy transitions and details the immense challenges facing any effort to rebuild domestic solar manufacturing capacity after the complete dismantling of the American industry ecosystem.
Robert Lighthizer Testimony to House Select Committee on the CCP
Former U.S. Trade Representative Robert Lighthizer's authoritative testimony to the House Select Committee on the Strategic Competition Between the United States and the Chinese Communist Party, providing expert insights on trade policy and critical enforcement challenges. Lighthizer details the systematic failures in trade enforcement that enable Chinese circumvention of trade rules, advocates for strengthened enforcement mechanisms, and outlines necessary reforms to protect American manufacturing and workers from unfair trade practices. His testimony draws on extensive firsthand experience negotiating with China and implementing trade enforcement measures.
Did the US Bilateral Goods Deficit with China Increase or Decrease During the US-China Trade Conflict?
Federal Reserve Board comprehensive economic research note examining the unexpected trajectory of the U.S.-China bilateral trade deficit during the US-China trade conflict from 2018-2020. Despite aggressive tariff increases designed to reduce the deficit, the analysis reveals that through sophisticated measurement adjustments accounting for trade diversion and transshipment through third countries, the bilateral goods deficit actually remained persistently high or potentially increased. The research employs rigorous econometric methods to trace Chinese goods flowing through intermediary countries like Vietnam, Mexico, and Taiwan to circumvent tariffs, demonstrating how easily determined actors can evade enforcement through supply chain reconfiguration. The Federal Reserve analysis provides critical empirical evidence that tariffs alone, without robust enforcement mechanisms to detect and prevent evasion, fail to achieve their intended policy objectives. This research underscores the fundamental importance of enhanced customs enforcement, improved transshipment detection capabilities, and coordinated international cooperation to ensure trade policy effectiveness and prevent systematic circumvention of trade rules.
The China Shock: Learning from Labor-Market Adjustment to Large Changes in Trade
Seminal research paper by renowned economists David Autor, David Dorn, and Gordon Hanson examining the profound impact of rapidly rising Chinese import competition on U.S. local labor markets, meticulously documenting significant job losses and severe economic disruption in manufacturing communities across America. This groundbreaking study fundamentally challenged conventional economic theory by demonstrating that trade adjustment costs were far larger and more persistent than predicted, with concentrated import exposure causing lasting damage to regional economies, worker earnings, and social fabric of affected communities. The research employs sophisticated econometric techniques to establish causal relationships between Chinese import penetration and adverse labor market outcomes including manufacturing employment declines, reduced wages for non-college workers, increased uptake of government transfer programs, and declining labor force participation rates. This landmark study reshaped economic policy debates by providing rigorous empirical evidence that contradicted longstanding assumptions about the benefits of trade liberalization and workers' ability to adjust to import competition.