You received a notice of redelivery

What the notice demands, and what happens if you do nothing

19 CFR 134.54(a) sets out both halves. If within 30 days from the date of the notice of redelivery, or such additional period as the Center director may allow for good cause shown, the importer does not properly mark or redeliver all merchandise previously released to him, the port director shall demand payment of liquidated damages incurred under the bond in an amount equal to the entered value of the articles not properly marked or redelivered.

Read the amount again, because it surprises people. The liquidated damages are equal to the entered value of the goods. Not ten percent of it, not a flat figure. If you were released $180,000 of unmarked goods and you neither mark them nor bring them back, the claim is written for $180,000.

You have three ways out of that half of the problem: mark the goods properly, return them to CBP custody, or ask for more time for good cause before the window closes. The one route that does not exist is waiting quietly.

One thing to keep straight while you read your file, because these two get blurred constantly: there are two separate 30 day clocks here and they belong to different parties. CBP has 30 days to issue the marking demand in the first place, under 19 CFR 141.113(a)(2). Your 30 days to mark or redeliver runs from the notice, under 134.54(a). They are not the same clock, they do not run at the same time, and the only one on your calendar is the second one.

Two separate money problems, and only one is negotiable

This is where most summaries blur two things that behave completely differently, and the blur is expensive. The liquidated damages under the bond can be mitigated: 19 CFR 134.54(b) and (c) and Part 172 provide the relief route, the same petition machinery that applies to other bond claims.

The marking duty cannot. 19 USC 1304(i) says so about as forcefully as a statute can: there shall be levied, collected, and paid upon such article a duty of 10 per centum ad valorem, which shall be deemed to have accrued at the time of importation, shall not be construed to be penal, and shall not be remitted wholly or in part nor shall payment thereof be avoidable for any cause.

And the two are linked in one direction: depositing the marking duty is a precondition of relief from the liquidated damages. So the sequence matters. You do not negotiate the ten percent away and then argue the rest. You pay the ten percent, and that is what puts you in a position to ask for relief on the much larger number.

Depositing the marking duty is a precondition of relief from the liquidated damages, so the order of operations is not optional.

A citation trap worth knowing about

19 CFR 134.54(c) cites the marking duty as 19 USC 1304(f), and 19 CFR 134.53 carries the same reference. Both are stale. The marking duty was redesignated and now sits at 19 USC 1304(i), which is the citation we use above and the one you should use in any correspondence.

We mention it because you will see 1304(f) repeated by people copying the regulation's text without checking whether the pointer still lands. It is a small thing, but citing a dead subsection in a petition is the kind of detail that colors how the rest of your submission gets read.

The honest limit: the ten percent is not going away

There is no version of this where the marking duty gets waived. The statute says it shall not be remitted wholly or in part nor shall payment thereof be avoidable for any cause, and it means it. Anyone who offers to fight the ten percent for you is selling you time you do not have.

What is genuinely open is the large number. The liquidated damages equal to entered value can be avoided entirely by marking or redelivering within the window, and where that is impossible they can be mitigated on petition. That is where the effort belongs, and it is why the first move after receiving one of these is a call about logistics rather than a call about law: can the goods be marked in place, in time, and by whom.

What your notice and your inventory decide

Everything practical here depends on facts we cannot see: the date on the notice, the entered value of the merchandise involved, where the goods physically are now, whether any have already been sold, and whether the marking can be corrected where they sit. Goods still on the dock and goods already in a retailer's back room are two different projects with the same deadline.

That inventory picture is also what a request for additional time is built from, and a specific request made before the window closes reads very differently from a general one made after.