With the news that U.S. Customs did, in fact, reverse itself in the Enforce and Protect Act (EAPA) petitions filed against Kingtom, it seems as though the EAPA program is in jeopardy .  When the EAPA program was initiated, the Federal Government intended to blend the best aspects of the Department of Commerce and U.S. Customs and Border Protection’s fight against illegal trade.  Suspected circumvention/transshipment activity would be handled in a transparent way with critical deadlines to ensure the investigation stayed on course.  Furthermore, the evidence required needed to meet a “preponderance of the evidence” standard versus “beyond a reasonable doubt” standard.  Because of these changes, the AEC and many other U.S. industries in trade disputes, embraced the EAPA program and has filed more than 10 EAPA claims since its inception.  Our success rate has been very high, and we believe it did affect trade activity and benefitted the domestic industry. However, Customs recent voluntary