US Customs and Border Protection (CBP) has made a final determination in its Enforce and Protect Act (EAPA) investigations into the illegal transshipment of Chinese Oil Country Tubular Goods (OCTG) by Thai companies, specifically Petroleum Equipment (Thailand) Co., Ltd. and Thai Oil Pipe Co., Ltd. The investigation, which was prompted by allegations from the US OCTG Manufacturers Association (USOMA), revealed that these Thai companies had falsely declared Chinese-origin OCTG as being of Thai origin. This move was designed to evade significant anti-dumping (AD) and countervailing duties (CVD) levied on Chinese OCTG products by the US government.
Background of the Case
The US OCTG Manufacturers Association (USOMA) has long argued that Chinese OCTG products have been sold at unfairly low prices in the US market, leading to the imposition of anti-dumping and countervailing duties on these imports. These duties, aimed at protecting US manufacturers from unfair trade practices, have been critical in ensuring the competitiveness of the domestic OCTG market. However, in recent years, there have been concerns about the evasion of these duties through transshipment schemes.
The Investigation and Discovery
The CBP investigation focused on a period from February 2023 to February 2025, during which it identified ten US importers who were receiving transshipped OCTG from Thailand. Despite the products being Chinese-origin, the Thai companies falsely labeled the goods as originating from Thailand in an attempt to circumvent the anti-dumping and countervailing duties.
The investigation revealed that these companies were actively participating in fraudulent schemes to misdeclare the origin of the products, thus evading over US$250 million in duties. The transshipment of Chinese OCTG through Thailand not only circumvented the duties but also placed US manufacturers at a severe disadvantage in terms of market pricing.
The Outcome of the Investigation
As a result of the EAPA investigations, CBP has now confirmed that the companies involved were indeed using deceptive practices to avoid paying the applicable duties on their Chinese OCTG imports. The total value of the illegal transshipment was significant, with USOMA estimating that CBP could recover at least US$310 million in duties through the enforcement of its EAPA actions.
Moreover, the investigation also uncovered widespread evasion, suggesting that the total amount of duties evaded could be even higher than initially estimated. The final determination underscores the importance of effective enforcement mechanisms to prevent illegal trade practices that undermine the integrity of international trade and the fair competition of US manufacturers.
The Importance of the EAPA
The Enforce and Protect Act (EAPA) is a critical tool used by CBP to address trade violations such as transshipment, which can undermine the effectiveness of anti-dumping and countervailing duties. Through EAPA investigations, CBP is empowered to take decisive actions against companies found to be circumventing trade laws, ensuring that US industries remain competitive and protected against unfair foreign competition.
This investigation and its outcome highlight the vital role of organizations like USOMA, which actively monitor illegal transshipment activities and bring them to the attention of regulatory authorities. The successful enforcement of EAPA actions demonstrates the US government’s commitment to protecting domestic industries from unfair practices that could harm the economy and manufacturing sector.
Key Takeaways:
• Illegal Transshipment Revealed: Thai companies Petroleum Equipment (Thailand) Co., Ltd. and Thai Oil Pipe Co., Ltd. were found to be evading US anti-dumping and countervailing duties on Chinese OCTG products.
• US Customs and Border Protection (CBP): CBP’s EAPA investigations uncovered the false declaration of Chinese-origin OCTG as Thai-origin, a move to avoid over US$250 million in duties.
• Recovery of Duties: USOMA estimates that at least US$310 million could be recovered in duties through the EAPA enforcement actions, with potential for even more due to widespread evasion tactics.
• Widespread Evasion: The investigation revealed significant evasion activities, affecting multiple US importers between February 2023 and February 2025.
• EAPA’s Role: The Enforce and Protect Act (EAPA) is a vital tool for preventing transshipment schemes and ensuring the enforcement of trade laws to protect US industries.
• US OCTG Industry Protection: The investigation underscores the importance of fair competition and the need to protect the US OCTG manufacturing sector from unfairly priced imports.
• USOMA’s Advocacy: The US OCTG Manufacturers Association (USOMA) played a crucial role in identifying the fraudulent practices and pushing for regulatory action.
As global trade dynamics continue to evolve, enforcement actions like those taken by CBP will remain pivotal in ensuring that US manufacturers can compete fairly in the market, free from the distortions caused by illegal practices like transshipment.
