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What is Suspension of Liquidation?

A hold on CBP's final duty determination, typically during antidumping or countervailing duty investigations. In the context of U.S. customs and tariff recovery, understanding suspension of liquidation is essential for navigating the CAPE refund process and ensuring accurate duty assessment.

Definition

Suspension of liquidation is a CBP action that puts a hold on the final determination of duties owed on specific entries. Liquidation is most commonly suspended during antidumping or countervailing duty investigations (from the preliminary determination until the final order) and during certain trade-related litigation. While liquidation is suspended, entries remain 'unliquidated' — the duty assessment is not final, and the importer may be required to deposit estimated duties that are later adjusted. Suspension can last months or years depending on the proceeding.

How Suspension of Liquidation Relates to Tariff Refunds

Entries with suspended liquidation have uncertain duty amounts and may not be immediately CAPE-eligible. Once liquidation resumes and the entry is liquidated at the final rate, any IEEPA or Section 301 overpayment becomes calculable and potentially CAPE-eligible. Tariffi's analysis identifies entries with suspended liquidation and monitors them for resolution.

Example

The Department of Commerce initiates an antidumping investigation on Chinese steel imports. CBP suspends liquidation on all entries of the subject merchandise from the date of the preliminary determination. The importer continues paying estimated duties, but the final rate will not be determined until the investigation concludes — possibly 12-18 months later.

Frequently Asked Questions

How long can liquidation be suspended?
There is no fixed limit. AD/CVD suspensions can last years during administrative reviews. Entries remain unliquidated until the proceeding concludes or CBP lifts the suspension.
Am I still required to pay duties during suspension?
Yes. Importers must deposit estimated duties (cash deposits) during the suspension period. The final duty amount is determined when liquidation resumes.

Related Terms

LiquidationCBP's final determination of the correct rate of duty and total amount owed on an import entry.Antidumping DutyAdditional tariff imposed on imports sold below fair market value to protect domestic industry.Countervailing DutyAdditional tariff imposed to offset foreign government subsidies on exported goods, levied after ITC investigation.ProtestA formal objection filed with CBP within 180 days of liquidation to dispute duty assessments or classification decisions.EntryThe formal process of declaring imported goods to CBP, triggering duty assessment and release.

Legal References

  • 19 U.S.C. § 1673b(d) — Suspension During AD Investigation
  • 19 CFR § 351.210 — Suspension of Liquidation

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