Valuation · CBLE study guide

AD/CVD & trade remedies

AD/CVD deposits and liquidation, EAPA, Section 301/232 and Chapter 99.

58past questions in CBLE Pass
≈3questions on a typical 80-question exam
19 CFR Parts 165, 351; HTSUS Ch. 99where the rules live

Common traps

Wrong answers on past exams cluster around a few beliefs. Here is each one, and what the rule actually says.

AD/CVD deposits by origin and value

“Use the foreign purchase price, the exporter's country, or percentages as whole numbers.”

The rule: Apply the AD/CVD rate for the goods' country of origin to the entered value (price paid by the U.S. buyer), converting percentages to decimals (257.06% = 2.5706).

Remember: Origin decides the case; rate% ÷ 100.

19 CFR 159.41-159.47

EAPA interim measures timing and standard

“Interim measures come within 15 days or require substantial evidence.”

The rule: No later than 90 calendar days after initiating an EAPA investigation, CBP takes interim measures if there is reasonable suspicion of evasion.

Remember: 90 days, reasonable suspicion.

19 CFR 165.24(a)

EAPA allegation contents

“An allegation must explain the importer-alleger relationship.”

The rule: Allegations include the alleger's name and agent, how it is an interested party, the importer's name and address, the covered merchandise, the AD/CVD orders, and supporting information.

Remember: No relationship explanation needed.

19 CFR 165.11(b)

What EAPA covers

“EAPA covers IPR, AD rate calculations or de minimis.”

The rule: EAPA (19 U.S.C. 1517; 19 CFR part 165) sets formal procedures for submitting and investigating allegations that importers evaded AD/CVD orders. CBP decides interim measures within 90 days of initiation and the evasion determination within 300 days.

Remember: EAPA = AD/CVD evasion.

19 CFR 165.1 · 19 CFR 165.24 · 19 CFR 165.22

AD/CVD proceeding types

“Dumping, subsidy, scope and sunset proceedings are interchangeable.”

The rule: Antidumping investigations address sales at less than fair value; countervailing duty investigations address subsidies; sunset reviews (at least every 5 years) ask whether dumping or subsidies would continue if an order were revoked; scope rulings decide coverage.

Remember: LTFV = AD; subsidy = CVD; 5-year look = sunset.

19 CFR Part 351 · 19 CFR 351.218

Choosing the AD/CVD case number

“Exporter or manufacturer exclusions apply regardless of combination.”

The rule: AD/CVD case numbers apply to exporter/producer combinations; when the combination isn't specifically covered, the all-others rate (e.g., -000) applies (ACE BRPD v12 ch. 9).

Remember: Match the exact combination.

ACE BRPD v12 ch. 9

Try a past question

October 2026 CBLE, question 67

CBP received an allegation on July 1, 2026, from a member of the public against Star Merchant (Star) for the evasion of antidumping duties (AD) on steel products that were made on August 30, 2025, and began an investigation consistent with Enforce and Protect Act (EAPA) orders. CBP has imposed interim measures to protect revenue and issued a Request for Information (RFI) to Star, demanding a description of the covered merchandise as well as operations data, including detailed production records, supply chain maps, and pricing agreements. Star is a client of Gotham Brokers (Gotham), who is authorized to conduct customs business on behalf of Star under a power of attorney with unlimited authority. Star notifies Gotham that it considers all of the information CBP requested to be highly confidential trade secrets and instructs Gotham to redact all documents provided in response to the RFI. Of the four choices below, what is the best advice for Gotham to give Star to prepare a response to the RFI in compliance with CBP regulations?

AGotham advises Star to clearly mark the requested documents with a cover page, stating that the submission contains confidential information, and to enclose the covered merchandise descriptions and operations data within brackets and replace the bracketed information with a sufficiently detailed summary that maintains the confidentiality of Star's trade secrets.

BGotham advises Star to request that CBP treat its entire submission in response to the RFI as business confidential. Gotham also provides Star with instructions to prepare both a confidential and a public version of the requested documents.

CGotham advises Star that descriptions of covered merchandise may not be redacted or otherwise treated as "business confidential," but Star may request that CBP treat its operations data as business confidential. Gotham also provides Star with instructions to prepare business confidential and public versions of the requested documents.

DGotham advises Star that no response to the RFI is required because the allegation was not timely made.

Show the answer and why

A. Incorrect. The description of covered merchandise cannot be treated as confidential.

B. Incorrect. Not the entire submission: the merchandise description must be public (19 CFR 165.4(c)).

C. Correct. Descriptions of covered merchandise are public (19 CFR 165.4(c)); operations data may be claimed as business confidential, with confidential and public versions prepared (165.4(a)).

D. Incorrect. The entries were made within 1 year before the allegation, so they are covered (19 CFR 165.2).

19 CFR 165.2 · 19 CFR 165.4 · law as of 2026-11-09

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