CBP Finds Duty Evasion Through Mexico and Thailand—Now Comes the Harder Test

CBP issued affirmative EAPA determinations involving Chinese products entering through Mexico and Thailand. It found that XCMG North America evaded duties on mobile access equipment shipped through Mexico, with likely combined duties of 69.31% on affected entries. In a separate case, CBP found evasion involving Chinese seamless steel pipe routed through Thailand. Neither announcement established how much money has been recovered.

These are meaningful enforcement findings, but they do not themselves establish criminal fraud or guarantee collection. CBP can take steps to assess and secure duties; contested collection can require DOJ civil litigation, while criminal charges follow a separate investigation.

Our EAPA (AD/CVD) Enforcement Tool Kit explains the process and where it can stall. The next test is whether DOJ has the prosecutors and specialized trade-fraud expertise to turn findings into financial consequences and, where warranted, criminal accountability.