Key legal question
Whether the post-clearance customs claim for the 1999 imports was time-barred or forfeited because of delay, hearing rights, or legal certainty.
Extracted holding
The claim was neither time-barred nor forfeited; the customs authorities could still demand post-clearance payment.
Extracted reasoning
The applicable limitation period under administrative penal law was respected. No concrete procedural rule was violated, and the importer was informed once the verification became relevant. The delay did not create a legally protected reliance interest or a forfeiture based on legal certainty.