Preliminary AD/CVD administrative reviews can materially change an importer's eventual duty exposure without immediately changing cash deposits. The latest results for Chinese steel nails, Chinese light-walled rectangular pipe and tube, and Spanish ripe olives call for careful comparison of deposit rates, entry populations, supplier status, and potential liquidation outcomes.
What the Preliminary AD/CVD Rates Mean
Rates and Companies Covered by the Reviews
The antidumping duty review of certain steel nails from China covers entries made from August 1, 2024, through July 31, 2025. Yueda Nails, consisting of Shanghai Yueda Nails Co., Ltd. and Shanghai Yueda Nails (Chuzhou) Ltd., received a preliminary margin of 9.27 percent. The review was rescinded for nine companies.
The China-wide entity was not reviewed in the steel nails proceeding. Its rate therefore remains 118.04 percent. This distinction matters because an importer cannot assume that the 9.27 percent preliminary margin applies broadly to all Chinese suppliers of subject steel nails.
The review of light-walled rectangular pipe and tube from China covers the same August 1, 2024, through July 31, 2025 period. Hangzhou Ailong Metal Products Co., Ltd. did not apply for a separate rate and is preliminarily treated as part of the China-wide entity at 255.07 percent. The review was rescinded for 39 other companies.
For ripe olives from Spain, the countervailing duty review covers calendar year 2024. Agro Sevilla Aceitunas S.Coop And. received a preliminary rate of 4.57 percent. Angel Camacho Alimentacion, S.L. and its cross-owned affiliates also received a preliminary rate of 4.57 percent. The review was rescinded for Plasoliva, S.L. and three other companies.
Preliminary Results Do Not Immediately Change Deposits
These rates remain preliminary. They generally do not change current cash deposit requirements until final results are issued and implemented. Final results may retain, increase, or reduce the preliminary calculations.
Importers should distinguish between cash deposits collected when merchandise enters the United States and the final antidumping or countervailing duty liability assessed after review. A deposit is security against potential liability, not necessarily the final amount owed. Differences can produce additional bills or potential refunds after liquidation instructions are implemented.
How Importers Should Evaluate Financial Exposure
Compare Entry Deposits With Preliminary Rates
The first step is to identify entries associated with each reviewed producer or exporter and compare the preliminary rate with the cash deposit rate used at entry. That analysis should be completed at the entry-line level rather than through a broad supplier or product estimate.
For example, entries of Yueda Nails merchandise may warrant modeling at the preliminary 9.27 percent margin. Entries associated with a supplier that remains subject to the 118.04 percent China-wide steel nails rate require a very different reserve analysis. For light-walled rectangular pipe and tube, the preliminary 255.07 percent China-wide rate creates potentially significant exposure where the exporter did not establish separate-rate eligibility.
The calculation should use the applicable entered value, entry date, exporter, producer, case number, deposit rate, and review status. Importers should also verify whether each entry was suspended, liquidated, or otherwise affected by instructions applicable to the relevant order.
Account for Rescissions and Supplier Identity
A rescission does not mean the merchandise is free from AD/CVD. It generally means that the administrative review will not establish a new rate for the rescinded company during that review period. The ultimate treatment of affected entries depends on the company's existing status, applicable deposit or assessment instructions, and the facts of the proceeding.
Supplier identity must be validated carefully. Commercial names, related entities, factory names, and exporter names may differ across purchase orders, invoices, entry summaries, and government case records. A mismatch can cause an importer to model exposure using the wrong rate.
Importers should coordinate with customs brokers and trade counsel before the briefing deadlines. Case briefs are due 21 days after the November 4, 2026 publication date, which places the expected deadline on November 25, 2026. Rebuttal briefs are due five days later, and hearing requests are due within 30 days, expected on December 4, 2026. Parties should confirm the operative deadlines and account for any procedural changes, closures, or extensions.
Managing AD/CVD Data and Duty Drawback
Keep AD/CVD Separate From Ordinary Customs Duties
Antidumping and countervailing duties are not eligible for duty drawback under 19 U.S.C. 1677h. This exclusion applies even when the imported merchandise is later exported, destroyed, or used to manufacture an exported article. Importers and drawback filers should therefore exclude AD/CVD amounts from the recoverable duty pool.
Ordinary customs duties paid on the same entry may still qualify for drawback when the merchandise is exported or destroyed, or when qualifying imported merchandise is used to manufacture exported goods. The claim must independently satisfy the applicable drawback requirements, including requirements related to eligibility, matching, documentation, timing, and evidence of exportation or destruction.
This creates a critical accounting distinction. An entry can contain both nonrecoverable AD/CVD and potentially recoverable ordinary customs duties. Treating the entire payment as either eligible or ineligible can materially distort a drawback calculation.
Build Controls Around Entry-Line Duty Components
Effective controls generally begin with entry-line data. Importers and brokers should retain the ordinary duty amount, antidumping duty deposit, countervailing duty deposit, merchandise processing fee, entered value, classification, country of origin, producer, exporter, and AD/CVD case number as separate fields where available.
Drawback calculations should use only eligible duty components. If a review later changes the final AD/CVD assessment, the adjustment should remain outside the drawback value. Changes to ordinary customs duties, liquidation status, or other eligible amounts may require separate analysis.
The recordkeeping process should also connect import data to inventory, manufacturing, export, and destruction records. That linkage helps demonstrate that the claimed ordinary duties relate to qualifying merchandise while preventing prohibited AD/CVD amounts from entering the claim.
Customs brokers supporting importer clients should document this separation in operating procedures and claim review controls. Clear treatment of each duty type reduces overclaim risk and makes post-entry reconciliation, financial reserving, and drawback review more defensible.
- Commerce published three sets of preliminary administrative review results on November 4, 2026, covering the 2024-2025 periods; rates remain preliminary and do not affect cash deposits until finals issue.*
Frequently Asked Questions
Do the Preliminary Rates Change Current Cash Deposits?
Generally, no. Preliminary administrative review results do not immediately change cash deposit rates. Revised deposit requirements typically take effect after final results are issued and implemented. Importers should continue using the legally applicable deposit instructions while separately estimating potential final assessment exposure.
Does the 9.27 Percent Steel Nails Rate Apply to Every Chinese Exporter?
No. The 9.27 percent preliminary margin applies to Yueda Nails for the reviewed period. The China-wide entity was not under review and remains at 118.04 percent. Other exporters may have separate rates or different treatment depending on their status.
Why Is the Chinese Pipe Rate 255.07 Percent?
Hangzhou Ailong Metal Products Co., Ltd. did not apply for a separate rate and is preliminarily treated as part of the China-wide entity. The applicable preliminary China-wide rate is 255.07 percent. Importers should verify both exporter and producer identity before applying this rate to entry exposure models.
What Does a Review Rescission Mean for an Importer?
A rescission generally means that the review will not calculate a new company-specific rate for that party during the period. It does not remove the merchandise from the AD/CVD order. Entry treatment depends on the company's existing rate and applicable assessment instructions.
Can Antidumping or Countervailing Duties Be Recovered Through Drawback?
No. AD/CVD payments are excluded from drawback. Ordinary customs duties paid on the same entries may remain eligible if the merchandise is exported, destroyed, or used in qualifying manufacturing and all other drawback requirements are met.
What Records Should Importers Review Now?
Importers should review entry summaries, commercial invoices, producer and exporter names, case numbers, deposit rates, entered values, liquidation status, and duty-component details. They should also identify entries within the relevant review periods and compare recorded deposits with modeled preliminary assessments.
How Stable Software Can Help
Support Broker-Controlled Drawback Operations
AD/CVD reviews reinforce the importance of separating nonrecoverable trade-remedy duties from ordinary customs duties that may qualify for drawback. DrawbackAI is flat-license duty drawback software that U.S. customs brokers can white-label for importer clients and use to file under their own filer code.
Stable Software charges a flat software license and never takes a percentage of the refund. This structure allows brokers to maintain control of client relationships, filing operations, and drawback economics while supporting importer clients with a dedicated software platform. Brokers evaluating how to expand or standardize duty drawback services can explore DrawbackAI as part of a controlled, broker-led approach.
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