Commerce has fully rescinded the 2025 wood mouldings CVD review covering imports from China. The decision leaves cash deposit rates unchanged and generally directs 2025 entries toward assessment at the rates required when entered, making accurate entry-level controls essential for importers and customs brokers.
What the Full Rescission Means
The rescission covers the entire 2025 period of review, from January 1 through December 31, for the countervailing duty order on wood mouldings and millwork products from China. Commerce had initiated the administrative review for 34 companies and selected Bel Trade Wood Industrial Co. and Zhangzhou Wangjiamei Industry and Trade Co., Ltd. as mandatory respondents.
Because the review has been rescinded in full, Commerce will not calculate new company-specific CVD assessment rates through this proceeding. For affected entries, assessment will generally occur at the cash deposit rate required at the time of entry. That result differs significantly from a completed administrative review, which can produce revised assessment rates based on examined subsidy activity.
Two Separate Grounds Supported the Rescission
The review ended through two procedural paths. Review requests were withdrawn for 14 companies. Where all requests covering a company were withdrawn within the applicable process, Commerce rescinded the review for that company.
For the remaining 20 companies, U.S. Customs and Border Protection data showed no suspended entries during the 2025 review period. Without reviewable entries, Commerce rescinded the proceeding for those companies as well. Together, these determinations resulted in a complete rescission rather than a partial review involving a smaller respondent group.
Importers should not interpret rescission as cancellation of the underlying CVD order. Case C-570-118 remains active, and covered merchandise continues to be subject to the applicable countervailing duty requirements. The rescission affects the administrative review for the 2025 period, not the continued existence of the order or the obligation to deposit CVD on current covered entries.
Immediate Priorities for Importers and Customs Brokers
The operational impact should be evaluated at the entry line level. Importers should identify 2025 entries of Chinese wood mouldings and millwork that were declared under the order, then compare supplier names, manufacturer identities, exporter identities, case numbers, deposit rates, and entered values against entry documentation.
This review is particularly important when commercial invoices use shortened names, translated names, affiliated trading companies, or inconsistent manufacturer information. A company appearing on a rescission list does not eliminate the need to confirm which entity supplied or exported the merchandise on each entry.
Build an Entry-by-Entry Review File
A defensible review file should generally include entry summaries, commercial invoices, packing lists, purchase orders, bills of lading, manufacturer declarations, deposit calculations, and any scope-related documentation. Brokers and importers should also confirm whether post-summary corrections, protests, prior disclosures, or other changes affected the data originally transmitted to CBP.
Teams should distinguish an internal reconciliation of records from the formal CBP reconciliation program. Comparing accounting records with customs entries is a prudent compliance control, but it does not automatically require or authorize a formal reconciliation filing. The appropriate correction mechanism depends on entry status, issue type, timing, and eligibility.
Importers should also monitor liquidation activity after Commerce transmits assessment instructions. Commerce intends to issue those instructions no earlier than 35 days after the November 5, 2026 publication date. That timing is not a guarantee that every entry will liquidate immediately afterward. CBP processing, injunctions, entry-specific issues, or other administrative factors can affect liquidation timing.
Customs brokers should preserve clear client communications concerning expected assessments. They should avoid describing deposited amounts as final until CBP liquidates the entries and all relevant review or protest periods have been considered.
Assessment Rates, Cash Deposits, and Liquidation
The rescission does not establish new CVD cash deposit rates. Importers must continue depositing countervailing duties at the rates currently applicable to covered merchandise. Current entries should not be filed using a lower or alternative rate merely because the 2025 administrative review was rescinded.
For 2025 entries affected by the rescission, CBP will generally assess CVD at the cash deposit rate required at the time of entry. This automatic assessment approach can create different results across entries when deposit rates changed during the year or when different exporter and producer combinations were subject to different rates.
Assessment and Deposit Requirements Are Distinct
An assessment rate determines the final amount of duty applied to an entry after the relevant review process. A cash deposit rate determines the amount collected as security when merchandise enters the United States. Although the same rate may ultimately apply in this rescinded review, the two concepts remain legally and operationally distinct.
Importers should compare the deposit rate shown on each entry with the rate that should have applied to the specific exporter and producer combination. Potential issues include use of an incorrect company-specific rate, application of an all-others rate, manufacturer mismatches, missing case numbers, or deposits calculated against an incorrect entered value.
Companies should also evaluate whether their financial accruals remain appropriate. If accounting systems assumed that the administrative review would produce a different final rate, the full rescission may change the expected exposure. Compliance, finance, and customs teams should align their entry populations and assumptions before adjusting reserves.
Liquidation notices should be monitored carefully. An unexpected rate, incorrect company assignment, or missing entry may require prompt analysis because available corrective options are generally time-sensitive. Waiting until periodic financial close procedures may leave insufficient time to address a liquidation problem.
Duty Drawback Treatment of the Affected Entries
Countervailing duties assessed under the wood mouldings and millwork order are not eligible for duty drawback. The same exclusion generally applies to antidumping duties. Importers therefore cannot recover CVD deposits or final CVD assessments through a drawback claim, even when the imported merchandise is later exported or destroyed.
That restriction does not necessarily make the entire entry ineligible for drawback. Ordinary customs duties, taxes, and fees paid on the same entry may remain eligible when the transaction satisfies the requirements of 19 U.S.C. 1313 and the applicable drawback program.
Separate CVD From Drawback-Eligible Amounts
A sound drawback process should separate ordinary duties from antidumping and countervailing duty amounts at the entry line level. This prevents excluded CVD payments from entering the claimed duty pool while preserving potentially eligible ordinary duties.
Importers should not rely solely on a total duty amount from an accounts payable or enterprise resource planning system. Those totals may combine ordinary customs duties, merchandise processing fees, harbor maintenance fees, antidumping deposits, and countervailing duty deposits. Each component can have different drawback treatment.
For substituted merchandise, the claimant must also confirm that the relevant statutory and operational requirements are met. Classification, product characteristics, inventory records, export evidence, time limits, certificates of delivery, and chain-of-custody data may all affect claim eligibility. The presence of CVD on an entry does not remove these documentation obligations.
Customs brokers managing drawback for importer clients should configure claim preparation controls to exclude CVD automatically or through a documented review procedure. The assessment outcome from the rescinded review should also be reflected in the entry data used for drawback calculations. If ordinary duty values change through a correction or liquidation event, the eligible drawback amount may need to be updated independently of the nonrefundable CVD component.
- Commerce fully rescinded the 2025 CVD administrative review of wood mouldings and millwork products from China (C-570-118, POR January 1-December 31, 2025) in a Federal Register notice published November 5, 2026 (91 FR 69815), signed November 2, 2026 by Acting Deputy Assistant Secretary Scot Fullerton.* The original CVD order dates to February 16, 2021.
- The review was initiated March 31, 2026 covering 34 companies after requests from the Coalition of American Millwork Producers (CAMP) and five Chinese producers. CAMP and the producers withdrew requests (partially June 29, 2026, with an August 3, 2026 errata for full withdrawal), leading to rescission for 14 companies under 19 CFR 351.213(d)(1). CBP data showed no suspended entries for the remaining 20 companies, so Commerce rescinded those under 19 CFR 351.213(d)(3). The entire review was rescinded.
- Cash deposit rates are unchanged and remain in effect. Commerce will instruct CBP to assess CVD on 2025 entries at the cash deposit rates required at the time of entry, with assessment instructions expected no earlier than 35 days after publication.
- Trade publications including International Trade Today (November 4, 2026) and Lesprom (November 5, 2026) reported the full rescission, noting no rate changes and listing of originally covered companies in the notice attachments. No notable practitioner discussions of this specific rescission appeared on X in the past 30 days.
Frequently Asked Questions
Did Commerce Cancel the CVD Order on Chinese Wood Mouldings?
No. Commerce rescinded the 2025 administrative review, not the underlying countervailing duty order. Covered wood mouldings and millwork from China generally remain subject to CVD cash deposit requirements under case C-570-118. Importers must continue evaluating scope coverage and applying the appropriate deposit rate to current entries.
Will the Rescission Change Current Cash Deposit Rates?
No new cash deposit rates were established through this rescission. Current rates remain in effect until changed through another applicable Commerce action. Importers and brokers should continue using the rate associated with the relevant exporter and producer combination, or another applicable rate, based on the entry facts.
How Will 2025 Entries Be Assessed?
Affected 2025 entries will generally be assessed at the cash deposit rate required at the time of entry. Commerce intends to transmit assessment instructions to CBP no earlier than 35 days after publication. Actual liquidation timing can vary, so importers should continue monitoring CBP records rather than assuming liquidation will occur on a single date.
Why Were Some Companies Rescinded for Having No Entries?
CBP data showed no suspended entries during the period for 20 companies. An administrative review typically requires reviewable entries on which final duties can be assessed. When there are no suspended entries for a company during the review period, Commerce may rescind the review for that company.
Can CVD Paid on These Entries Be Recovered Through Drawback?
No. Countervailing duties are not eligible for drawback under 19 U.S.C. 1677h. However, ordinary customs duties paid on the same entries may still qualify if the merchandise, exports, records, timing, and claim structure satisfy the applicable requirements of 19 U.S.C. 1313.
What Should a Broker Verify Before Liquidation?
The broker should generally verify the importer, exporter, manufacturer, case number, entry date, entered value, deposit rate, and CVD amount for each affected entry. Any inconsistency should be evaluated promptly to determine whether an available correction process is appropriate before or after liquidation.
How Stable Software Can Help
Support Scalable Drawback Operations
The rescinded review reinforces the need to separate nonrefundable CVD from ordinary duties that may qualify for drawback. Stable Software's DrawbackAI platform gives U.S. customs brokers a duty drawback software option they can white-label for importer clients and use to file claims under their own filer code.
Stable Software charges a flat software license and never takes a percentage of the refund. That structure allows brokers to retain control of their client relationships, filing operations, and drawback economics. Brokers evaluating 2025 wood mouldings entries can use a disciplined drawback process to preserve eligible ordinary-duty recovery while excluding countervailing duties from claim calculations.
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