Customs and Border Protection (CBP) is evaluating continuous bond sufficiency using estimated duties, taxes and fees (DTFs), not the final duties determined after liquidation. This distinction has become increasingly important as many importers receive Consolidated Administration and Processing of Entries (CAPE) adjustments, post-summary corrections (PSCs) and other post-entry changes.
Key Takeaways
CBP calculates bond sufficiency based on the most recent major version of the entry summary submitted by the filer. These estimated duties remain the values used for bond monitoring, even if the final duty liability later changes.
Ascertained Duties Are Different
The ascertained duties, taxes and fees represent the final liability determined by CBP after processing activities such as:
- CAPE adjustments
- Post-summary corrections (where applicable)
- Rate advances
- Other CBP modifications
These amounts are used solely to determine:
- Liquidation bills
- Refunds
- Final duty liability
They do not replace the estimated duties used for bond sufficiency calculations.
Why This Matters
An importer may receive a substantial duty refund after liquidation while the original estimated duties continue to count toward continuous bond sufficiency. This means that CAPE refunds do not lower bond sufficiency.
Importers experiencing significant tariff fluctuations should continue monitoring their bond utilization even when refunds are expected.
