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Algeria Wire Rod CVD Order: Managing 73.33% Cash Deposits Without an ITC Injury Determination

Reis Renneker

Written by Reis Renneker

A 73.33% Algeria wire rod CVD rate now affects subject imports, requiring precise scope checks, deposit controls, and landed-cost planning.

Algeria Wire Rod CVD Order: Managing 73.33% Cash Deposits Without an ITC Injury Determination

The Algeria wire rod CVD order creates an immediate and substantial cost exposure for U.S. importers of subject steel products. With a 73.33% cash deposit rate and no separate ITC injury determination, importers and customs brokers must quickly align classification, scope, entry, and financial controls.

What the Algeria Wire Rod CVD Order Requires

The final affirmative countervailing duty determination and resulting order apply to subject carbon and alloy steel wire rod from Algeria. The order is identified as C-721-003 and became applicable on September 18, 2026, the date of publication.

Cash Deposit and Suspension Requirements

SPA Algerian Qatar Steel received a final subsidy rate of 73.33% based on facts available with adverse inferences. The All Others rate is also 73.33%, meaning the same cash deposit rate generally applies regardless of the Algerian producer or exporter identified on the entry.

For subject merchandise entered, or withdrawn from warehouse for consumption, on or after September 18, 2026, U.S. Customs and Border Protection requires a cash deposit equal to 73.33% of the applicable entered value. Suspension of liquidation, which began with the preliminary determination, continues for covered entries.

Importers should distinguish the cash deposit from final duty liability. A deposit secures estimated countervailing duties at entry, but the final amount owed may later change through an administrative review or other proceeding. This distinction matters for accruals, landed-cost estimates, purchase agreements, and post-entry financial reporting.

The rate also creates significant bond and cash-flow implications. At 73.33%, even a comparatively small shipment can produce a substantial deposit requirement. Importers should confirm that purchase orders, broker instructions, duty estimates, and financing arrangements account for the CVD exposure before cargo departs. Customs brokers should likewise ensure that case tables and automated entry validations reflect the correct case number, country, effective date, manufacturer, exporter, and deposit rate.

Determining Whether Imported Wire Rod Is Within Scope

Classification is an important screening tool, but the written physical description generally controls whether merchandise falls within an AD/CVD scope. Importers should therefore avoid treating an HTS code match—or the absence of one—as a conclusive scope determination.

Covered Products and Express Exclusions

The order generally covers hot-rolled products of carbon steel and alloy steel, in coils, with an approximately circular cross section and an actual solid cross-sectional diameter of less than 19.00 millimeters. The scope contains exclusions for stainless steel, tool steel, high-nickel steel, ball-bearing steel, concrete reinforcing bars and rods, and qualifying free-cutting steel.

The currently listed HTS classifications include:

  • 7213.91.3011, 7213.91.3015, 7213.91.3020, and 7213.91.3093
  • 7213.91.4500 and 7213.91.6000
  • 7213.99.0030
  • 7227.20.0030 and 7227.20.0080
  • 7227.90.6010, 7227.90.6020, 7227.90.6030, and 7227.90.6035

Products entered under 7213.90.0090 or 7227.90.6090 may also be covered when they satisfy the physical description. Conversely, merchandise entered under a listed tariff provision may fall outside the order if it meets an express exclusion or does not satisfy the controlling product description.

A defensible scope review should examine mill certificates, grade chemistry, diameter, cross-sectional shape, production method, coil form, end use, and technical specifications. Product descriptions on invoices should be sufficiently detailed to support the entry declaration. Generic terms such as “steel rod” or “alloy wire” generally provide too little information for reliable scope screening.

When uncertainty remains, importers should escalate the product for legal or technical review before entry. A classification ruling does not necessarily resolve AD/CVD scope, and informal commercial descriptions should not override the physical characteristics of the merchandise.

Why the No-ITC Process Changes Compliance Planning

Most trade professionals associate new AD/CVD orders with both a final Commerce determination and an affirmative material injury determination by the U.S. International Trade Commission. The Algeria wire rod proceeding followed a different path because Algeria is not treated as a Subsidies Agreement country for this purpose.

Immediate Issuance Without an Injury Determination

Under section 701(c)(1), an ITC material injury determination was not required. Commerce could therefore issue the countervailing duty order with its final affirmative determination rather than waiting for a separate injury phase. For operational teams, this shortened the transition between the final outcome and enforceable deposit requirements.

Compliance workflows should not assume that every CVD proceeding will include the same sequence of preliminary, final, injury, and order milestones. Country status can affect the process, making event-driven case monitoring essential. Importers and brokers should configure controls around the legally effective date of each instruction rather than relying on a standard investigation timeline.

The 73.33% deposit must also be analyzed alongside other duties that may apply to steel imports. Section 232 measures, ordinary customs duties, merchandise processing fees, and any other applicable trade remedies should be assessed separately. Importers should not assume that one measure replaces another or that a single tariff code determines the entire duty stack.

Drawback and Financial Estimate Hygiene

Countervailing and antidumping duties are generally not recoverable through drawback. Importers should therefore exclude AD/CVD cash deposits from drawback recovery assumptions and avoid overstating expected refunds in financial models or drawback pools.

Finance and compliance teams should maintain separate data fields for ordinary duties, Section 232 duties, AD/CVD deposits, and other fees. They should also retain deposit amounts by entry line and case number. This structure supports reconciliation, liquidation monitoring, administrative review analysis, and accurate contingent-liability reporting without contaminating drawback estimates.

Recent Developments
  • On September 18, 2026, the U.S. Department of Commerce published its final affirmative CVD determination and issued a CVD order (C-721-003) on carbon and alloy steel wire rod from Algeria (91 FR 59107), setting a 73.33% ad valorem subsidy rate (based on facts available with adverse inferences) for SPA Algerian Qatar Steel and All Others.* No ITC material injury determination was required under section 701(c)(1) because USTR previously determined Algeria is not a Subsidies Agreement country. Cash deposits of 73.33% apply to entries on or after the publication date.
  • CBP issued instructions (messages 6265425 on Sept. 22 and 6266401 on Sept. 23, 2026) directing continued suspension of liquidation and collection of 73.33% cash deposits for subject merchandise (certain hot-rolled carbon and alloy steel wire rod in coils under 19 mm diameter, excluding stainless, tool, high-nickel, ball bearing steel, and rebar) entered on or after Sept. 18, 2026.* Suspension had begun with the July 8, 2026 preliminary determination.
  • Industry publications including Steel Market Update (Sept. 18), International Trade Today (Sept. 16–17), and trade.gov (updated Sept. 25) reported the order’s issuance simultaneous with the final determination, noting the unusual lack of an ITC step and that annual administrative reviews can now be requested.* Petitioners were Charter Steel, CMC, Liberty Steel USA, Nucor, and Optimus Steel.
  • Algerian media (e.g., Sept. 19 reports) covered the 73.33% duty as a record tax on wire rod (following a similar rebar CVD), attributing the high AFA rate to non-participation by AQS and the Government of Algeria during the 2025 POI investigation.* Limited X discussion appeared, such as a Sept. 23 industry announcement of the final ruling.
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Frequently Asked Questions

What Is the CVD Cash Deposit Rate for Algerian Wire Rod?

The cash deposit rate is 73.33% for SPA Algerian Qatar Steel and 73.33% for All Others. The rate generally applies to subject merchandise entered, or withdrawn from warehouse for consumption, on or after September 18, 2026.

Why Was There No ITC Injury Determination?

An ITC material injury determination was not required because Algeria is not treated as a Subsidies Agreement country for this proceeding. Section 701(c)(1) permits issuance of the CVD order without the injury step under these circumstances.

Does an HTS Code Determine Whether Wire Rod Is Covered?

No. HTS classifications help identify potentially covered entries, but the written scope description generally controls. Importers must compare the product’s grade, chemistry, dimensions, cross section, form, and other physical characteristics with the scope and exclusions.

Is the 73.33% Deposit the Final Duty Amount?

Not necessarily. The deposit is an estimated amount collected at entry. Final countervailing duty liability may change through an administrative review or other proceeding, so importers should monitor both liquidation status and case developments.

Can CVD Deposits Be Recovered Through Drawback?

AD/CVD cash deposits and assessed duties are generally not eligible for drawback. Importers should keep these amounts outside projected drawback recoveries and maintain separate accounting records for ordinary customs duties and trade-remedy deposits.

How Should Importers Handle Section 232 Duties?

Section 232 applicability should be evaluated separately from the CVD order. Depending on the merchandise and entry circumstances, multiple duty measures may apply. A complete landed-cost model should calculate each measure independently and preserve line-level support for the resulting duty treatment.

How Stable Software Can Help

The Algeria wire rod CVD order demonstrates why steel importers and customs brokers need structured, auditable trade-remedy controls rather than spreadsheet-only case management.

Automating AD/CVD Compliance Controls

Stable Software helps trade teams centralize product data, case numbers, manufacturers, exporters, effective dates, deposit rates, and entry-line duty calculations. Automated validations can flag potential scope matches, missing product attributes, outdated rates, and inconsistent broker instructions before they create entry errors or unexpected liabilities. Stable also supports clearer segregation of AD/CVD deposits, Section 232 duties, ordinary customs duties, and drawback-eligible amounts. This gives compliance, brokerage, and finance teams a shared operational record for landed-cost forecasting, liquidation monitoring, and audit readiness.

Resources

TypeResource
Federal Register final CVD determination and order (FR Doc 2026-19107; 91 FR 59107; applicable September 18, 2026)federalregister.gov — carbon and alloy steel wire rod from algeria final affirmative countervailing duty determination and
ACCESSaccess.trade.gov

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