Skip to content

U.S. Paper Receipts Association Applauds CBP’s Importer Duties Evasion Decisions

PRCA Blog Cover 5.22

U.S. Paper Receipts Association Applauds CBP’s Importer Duties Evasion Decisions

Springfield, Mass., May 23, 2023 — The Paper Receipts Converting Association (PRCA) today announced key decisions by the Department of Homeland Security’s Customs and Border Protection (CBP) in three investigations under Title IV, Section 421 of the Trade Facilitation and Trade Enforcement Act of 2015, commonly known as the Enforce and Protect Act (EAPA). These decisions reflect significant progress in the PRCA’s efforts to combat evasion of duties on imports of thermal receipt paper by U.S. importers.

On May 1, 2023, CBP issued an affirmative final determination regarding evasion of the antidumping (AD) and countervailing duty (CVD) orders on thermal receipt rolls imported by WHP Associates, a U.S. company purchasing rolls for online sale by ThermalKing. CBP found that there was substantial evidence that WHP Associates entered thermal paper covered by AD and CVD duties on China, Korea, and Germany through evasion by transshipping the merchandise through Actan in Malaysia. In light of this determination, imports by WHP Associates during the investigation period will be subject to the duties applicable to the countries covered by the AD/CVD orders on thermal paper. Going forward, WHP Associates will continue to be subject to continuous bonds and applicable AD/CVD duties.

On May 9, 2023, CBP issued a determination finding that there is a reasonable suspicion of evasion of AD/CVD duties by three importers of thermal receipt rolls: Lollicup USA Inc., Exquis Inc., and Sanster Corporation. CBP found that available information indicates that these importers are evading AD/CVD duties on thermal paper by transshipping Chinese thermal paper through Mega Thermal in Taiwan. As a result of these determinations, CBP will extend the liquidation if any unliquidated entries that entered the U.S. before February 1, 2023, and will suspend liquidation of any entries after February 1, 2023. In addition, CBP will require “live” entries for all imports of covered merchandise from Taiwan, and will not allow release of the merchandise unless duty deposits are paid. The applicable duty rate for all entries will be the “China-wide” rate of 154%. CBP will continue its investigation of evasion on imports of thermal paper from Taiwan.

On May 12, 2023, CBP issued an affirmative final determination regarding evasion of the AD orders on thermal receipt rolls imported by Gorilla Paper, Inc. and Gorilla Paper Supply (Gorilla Paper). CBP found that there was substantial evidence that Gorilla Paper had imported thermal receipt paper from Turkish producers, Dor Etiket, Engin Kagit, and Umur Basim, that was made from thermal paper produced in Germany and Korea. CBP also found that Gorilla Paper had misclassified thermal paper of Korean origin as carbon paper. As a result of CBP’s findings, Gorilla Paper will have to pay the applicable duties on all imports during the investigation period, and going forward, will continue to be subject to continuous bonds and applicable AD/CVD duties.

Importantly, the evasion determinations by CBP do not preclude the agency from pursuing additional enforcement actions or penalties.

“PRCA is fully committed to ensuring that importers pay all the AD and CVD duties applicable to imports of thermal point-of-sale rolls,” said Mike Rapier, President of PRCA. “When PRCA learns that importers are evading the duties, we will not hesitate to take action.”

Bryan Eovaldi, Vice President of PRCA, added, “PRCA has now successfully prosecuted three EAPA cases covering thermal rolls from Malaysia and Turkey. Other investigations regarding imports from Mexico and Taiwan are ongoing, and we are confident we will be successful in these cases, as well.”

Tina Howard, Vice President of Sales for the Converting and Specialty Channel at Domtar Corporation, said, “We appreciate the significant efforts of the CBP analysts that investigate these cases, and hope that CBP will take all possible actions to put a stop to the evasion of the duties that the U.S. government has determined to be necessary and appropriate.” Domtar Corporation produces thermal paper that it supplies to POS converters in the United States.

In addition to supporting aggressive enforcement of antidumping and countervailing duty orders, PRCA maintains that the use of Good Manufacturing Practices (GMPs) is essential to ensuring that purchasers receive precisely what they have ordered. The association believes that imported converted rolls are often shorter than advertised and/or may be manufactured with improperly identified paper. PRCA has developed a set of GMPs to which its members subscribe precisely to address this issue.

To learn more about PRCA and their contributions to the U.S. thermal paper industry, visit


PRCA is a nonprofit trade association representing the manufacturers of paper receipts. The organization promotes the value of paper receipts; encourages the use of best manufacturing practices throughout the industry; and works with legislators and governmental agencies to promote the industry’s well-being.


Why Join/Membership

The PRCA seal is your supplier’s promise of quality.

Now is the time to band together and secure the future of paper receipts.