CBP Posts Updated Guidance on Reimbursement Certificates
On January 15, 2012, U.S. Customs and Border Protection (CBP) posted on their website an updated document with Antidumping Reimbursement Certificate instructions, which provides clarification in regards to multiple requirements including certificates through the Automated Commercial Environment (ACE) and for Protest purposes.

In the memorandum, CBP reminds the public that regulations by the Department of Commerce (DOC) require that importers must file a certificate advising whether the importer has entered into an agreement, or otherwise has received reimbursement of AD duties, prior to liquidation of the entry.

The document also clarifies that Non-Reimbursement Statements in electronic form can be made through ACE at the line level for entry summaries filed in ACE, or blanket statements at the importer account lever for summaries filed in ACE or in the legacy system, the Automated Commercial System (ACS). The electronic version of the certificate fulfills the same purpose of the paper version.

For the purpose of Protests, CBP notes that reimbursement certificates may be submitted as part of a protest "in order to rebut the presumption of reimbursement." CBP also provides more details in regards to individual and blanket certificates, countervailing cases, and the process for when importers are no longer in business.

The full text of the Reimbursement Certificate guide can be found online here.