AD/CVD Review Update: Shrimp, Steel, and Aluminum

AD/CVD administrative reviews can change import costs long after merchandise enters the United States. New results involving Vietnamese shrimp, Korean steel plate, and Chinese aluminum sheet require importers and customs brokers to update deposit rates, monitor liquidation, and distinguish ordinary customs duties from antidumping and countervailing duties.

Vietnam Shrimp Final Results Raise Duty Exposure

The final results of the 2024-2025 antidumping duty administrative review of frozen warmwater shrimp from Vietnam establish materially different rates across exporter groups. The period of review covers February 1, 2024, through January 31, 2025, under case A-552-802.

Fimex Group received a final weighted-average dumping margin of 10.71 percent. Soc Trang Seafood Joint Stock Company, commonly identified as STAPIMEX, received a 6.36 percent margin. The non-examined companies qualifying for a separate rate received 7.59 percent, while the Vietnam-wide entity remains subject to a 25.76 percent rate.

These results affect both future cash deposits and the eventual assessment of duties on review-period entries. Importers should not treat the published margin as merely a prospective cost adjustment. The review also determines how Commerce generally instructs U.S. Customs and Border Protection to assess antidumping duties on covered entries from the review period.

Deposit Rates and Entry Controls

New cash deposit rates apply to subject entries made on or after the publication date, scheduled for November 6, 2026. Brokers and importers should update classification and entry systems promptly so that entries are not filed using outdated deposit rates.

Assessment instructions are expected no earlier than 35 days after publication. That interval gives affected parties time to evaluate litigation options, but it should not be treated as a guaranteed liquidation date. Importers should identify entries by exporter, producer, importer of record, and entry date, then verify that the correct rate category applies. Companies relying on separate-rate treatment should also confirm that their suppliers are included within the applicable group rather than assuming that every Vietnamese exporter receives the 7.59 percent rate.

Korea Steel Plate Rate Changes After Court Review

The amended final results for the 2021 countervailing duty review of carbon and alloy steel cut-to-length plate from Korea illustrate how judicial review can alter historical duty liability without changing current cash deposit requirements. The affected proceeding is C-580-888 and concerns entries associated with POSCO during the 2021 review period.

Following remand proceedings, the Court of International Trade sustained Commerce's revised analysis on October 27, 2026. POSCO's amended subsidy rate for the 2021 review is 0.80 percent. The result incorporates a finding involving additional Korean emissions trading permits, which contributed 0.61 percentage points to the total subsidy rate.

The amended rate matters for the ultimate assessment of duties on covered 2021 entries. However, it does not change POSCO's current cash deposit rate because a later administrative review established a superseding rate. Importers must therefore separate historical liquidation exposure from the deposit rate applied to new entries.

Injunctions, Appeals, and Liquidation Timing

Liquidation of covered 2021 entries remains enjoined while the appeal period and any subsequent appellate proceedings remain unresolved. Importers should avoid closing reserves or treating the 0.80 percent rate as a completed cash event until liquidation instructions become effective.

Entry-level monitoring is especially important in this situation. Trade compliance teams should maintain records connecting purchase orders, entry summaries, supplier identities, deposited CVD amounts, and the entries covered by the injunction. Customs brokers should also avoid applying the amended historical rate to current transactions when a later review controls the operative cash deposit rate. The distinction between assessment rates and cash deposit rates is central to accurate AD/CVD administration.

China Aluminum Sheet Results Remain Preliminary

The preliminary results of the 2025-2026 antidumping duty administrative review of common alloy aluminum sheet from China cover the period from February 1, 2025, through January 31, 2026. The proceeding, A-570-073, currently assigns the sole company under review to the China-wide entity at 59.72 percent.

The company did not demonstrate eligibility for a separate rate. In non-market economy proceedings, exporters generally must establish independence from government control to receive a company-specific or separate rate. When that showing is not made, Commerce may treat the exporter as part of the country-wide entity.

For importers, the 59.72 percent preliminary rate creates significant potential exposure, but it is not yet a final assessment result. Preliminary calculations may change after comments, rebuttal arguments, corrections, or further agency analysis. Importers should model the preliminary result while preserving the distinction between estimated exposure and a final liability.

Deadlines and Commercial Planning

Case briefs are due 21 days after publication, and hearing requests must generally be submitted within 30 days. Interested companies should coordinate quickly with trade counsel because the factual record and legal arguments developed during this stage may shape the final results.

Importers should also examine whether purchase agreements address AD/CVD risk, reimbursement, price adjustments, and supplier cooperation. A high country-wide rate can affect landed cost, inventory valuation, margin planning, and sourcing decisions even before final results are issued. Brokers should verify exporter and producer combinations carefully because a supplier's commercial name may not align cleanly with the legal entity evaluated during the review.

Any projected liability should remain visible in internal reporting. Treating a preliminary result as irrelevant until it becomes final can leave finance and compliance teams unprepared for a substantial assessment change.

Compliance, Reconciliation, and Drawback Priorities

The three proceedings call for different operational responses. Vietnamese shrimp importers face new cash deposit rates and impending assessment instructions. Korean steel plate importers must monitor an injunction and possible appeal before liquidation. Chinese aluminum sheet importers face a preliminary rate that may change before the review becomes final.

A disciplined response begins with entry-level data. Importers should map each affected entry to the exporter, producer, country of origin, case number, entry date, entered value, ordinary customs duty, and AD/CVD deposit. Brokers should ensure that automated entry profiles do not apply a single rate across suppliers with different legal statuses.

Recommended Importer and Broker Actions

Trade compliance teams should prioritize the following actions:

1. Update Vietnam shrimp cash deposit rates for entries made on or after publication.
2. Compare deposits on review-period shrimp entries with the rates and assessment methodology applicable to each exporter group.
3. Flag covered 2021 POSCO steel plate entries and monitor the appeal window, injunction, and eventual liquidation instructions.
4. Model potential exposure on Chinese aluminum sheet using the 59.72 percent preliminary China-wide rate without presenting it as final liability.
5. Preserve entry records and supplier documentation needed to support post-entry reviews, protests, litigation monitoring, and accounting reserves.

Keeping AD/CVD Out of Drawback Claims

Antidumping and countervailing duties are not eligible for drawback under 19 U.S.C. 1677h. Ordinary customs duties paid on the same entries may still qualify when the merchandise is exported or destroyed, or when qualifying imported merchandise is used to manufacture exported goods, provided the claim satisfies the applicable drawback requirements.

Drawback filers should therefore maintain separate data fields for ordinary customs duties and AD/CVD amounts. Combining them into a single duty value can overstate the potential refund and create avoidable claim risk. Brokers managing both entry filing and drawback should establish controls that prevent antidumping and countervailing duty deposits from flowing into eligible-duty calculations.

Frequently Asked Questions

When do the new Vietnam shrimp cash deposit rates apply?

The new rates apply to subject entries made on or after publication of the final results, scheduled for November 6, 2026. Entries should be matched to the correct exporter category, including Fimex Group, STAPIMEX, qualifying separate-rate companies, or the Vietnam-wide entity.

Does the amended POSCO rate change current deposits?

No. The amended 0.80 percent rate applies to the reviewed 2021 period, but a later administrative review established a superseding cash deposit rate. The amendment affects historical assessment exposure rather than the rate generally deposited on current entries.

Is the 59.72 percent China aluminum sheet rate final?

No. It is a preliminary result for the 2025-2026 review. Interested parties may submit case briefs and request a hearing within the applicable deadlines. Commerce may modify its analysis or calculations before issuing final results.

Can importers recover AD/CVD through duty drawback?

No. Antidumping and countervailing duties are excluded from drawback. However, ordinary customs duties paid on the same entry may be eligible if the merchandise and subsequent exportation, destruction, or manufacturing activity satisfy the applicable drawback requirements.

Why can assessment rates differ from cash deposit rates?

Cash deposit rates are security collected on current entries, while assessment rates determine the final AD/CVD liability for entries covered by a completed review. Later reviews, court decisions, injunctions, and liquidation instructions can create different rates for different entry periods.

How Stable Software Can Help

AD/CVD reviews make accurate duty segregation essential for drawback filers. Ordinary customs duties may support a refund claim, but antidumping and countervailing duties must remain outside the eligible amount.

Broker-Controlled Duty Drawback Software

DrawbackAI is flat-license duty drawback software that U.S. customs brokers 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. Brokers evaluating drawback opportunities for entries that also carry AD/CVD can use a broker-controlled platform while maintaining the necessary distinction between potentially eligible ordinary duties and ineligible trade remedy duties.

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