The Bahrain aluminum sheet antidumping duty landscape changed materially on November 16, 2026. A final 10.90 percent margin for GARMCO now affects cash deposits on new entries, while importers and customs brokers must separately prepare for liquidation of entries from the 2024-2025 review period.
What the Final Antidumping Review Changed
The final administrative review covers common alloy aluminum sheet from Bahrain entered during the period from April 1, 2024, through March 31, 2025. Commerce determined that Gulf Aluminium Rolling Mill B.S.C., commonly known as GARMCO, sold subject merchandise in the United States at less than normal value and assigned a final weighted-average dumping margin of 10.90 percent.
The Final Margin Increased From the Preliminary Rate
The final 10.90 percent margin represents a significant increase from the preliminary rate of 6.25 percent. Commerce revised its calculations after considering comments concerning major input adjustments, a cost of production offset, and the treatment of general and administrative and interest expense ratios.
For importers, the difference is commercially meaningful. A higher final margin can increase the eventual antidumping duty liability associated with entries made during the review period. However, the published weighted-average margin should not automatically be treated as the exact assessment rate for every importer. Assessment calculations are generally importer-specific and depend on the reviewed sales associated with each importer.
New Cash Deposit Requirements Apply Prospectively
For subject merchandise produced and exported by GARMCO, the 10.90 percent cash deposit rate applies to entries made on or after November 16, 2026. The all-others rate remains 4.83 percent for producers and exporters that do not have another applicable company-specific rate.
Customs brokers should verify the complete producer and exporter combination before applying a deposit rate. Supplier names, invoicing parties, and intermediary sellers do not always establish the correct antidumping duty treatment. Product descriptions and tariff classifications also support screening, but the legal scope of the order generally controls whether merchandise is subject to the case.
Cash Deposits and Final Assessments Require Separate Controls
Cash deposits and antidumping duty assessments serve different purposes. The deposit collected at entry is security against potential liability, while the final assessment determines the amount ultimately owed on entries covered by the completed administrative review.
Review-Period Entries Face Importer-Specific Assessment
Entries of GARMCO common alloy aluminum sheet made from April 1, 2024, through March 31, 2025, are generally subject to assessment based on importer-specific calculations. This means an importer should not assume that every review-period entry will liquidate at precisely 10.90 percent. The final company margin reflects GARMCO's aggregate reviewed results, while assessment instructions may translate those results into rates calculated for individual importers.
Commerce intends to issue assessment instructions to U.S. Customs and Border Protection no earlier than 35 days after publication. Actual liquidation timing can extend beyond that point because CBP must receive and process the instructions, and litigation or other administrative developments may affect particular entries.
For certain intermediary sales in which GARMCO did not know that the merchandise was destined for the United States, automatic assessment procedures generally apply. The 4.83 percent all-others rate is relevant to those transactions when no other company-specific rate governs.
Post-Publication Entries Use the New Deposit Rate
Entries on or after November 16, 2026, move into a different compliance track. GARMCO merchandise subject to the order generally requires a 10.90 percent cash deposit at entry, but that deposit is not necessarily the final liability. A future administrative review could maintain, increase, or decrease the assessment rate for those entries.
Broker and importer systems should therefore preserve both the entry-date rate and the review-period exposure. Combining prospective deposits and retrospective assessments into one rate field can create accrual errors, landed-cost distortions, and reconciliation problems.
Compliance Priorities for Importers and Customs Brokers
The final results require more than a rate-table update. Importers, service centers, and brokers should coordinate purchasing data, entry records, producer identity, and financial accruals so that the higher GARMCO rate is reflected consistently across customs and accounting processes.
Update Entry Controls and Supplier Master Data
Broker instructions should identify November 16, 2026, as the effective date for the 10.90 percent GARMCO cash deposit rate. Automated and manual controls should distinguish GARMCO from other Bahraini producers and should account for transactions involving exporters, trading companies, or resellers.
Importers should also confirm that product master data accurately identifies common alloy aluminum sheet potentially covered by the order. Classification alone is not conclusive, so technical specifications, alloy composition, dimensions, heat treatment, and other relevant product characteristics may need review against the scope language. Uncertainty should be resolved before entry whenever possible.
Quantify Historical Exposure Before Liquidation
Finance and compliance teams should build an entry-level population for the April 1, 2024, through March 31, 2025 review period. Useful data includes entry numbers, line values, entered antidumping deposits, producer and exporter identities, importer of record numbers, and liquidation status.
The analysis should compare existing accruals with the potential effect of importer-specific assessment. It should also identify entries that have already liquidated, entries remaining unliquidated, and transactions potentially affected by automatic assessment procedures. Service centers with high volumes may need to connect customs exposure to inventory and customer pricing records.
Keep Antidumping Duties Separate From Drawback Planning
Antidumping and countervailing duties generally cannot be recovered through duty drawback. Importers should not include the GARMCO antidumping deposit or final assessment in projected drawback refunds.
Other eligible customs duties paid on imported aluminum products may still qualify for drawback when the statutory requirements for exportation or destruction, matching, documentation, and filing are satisfied. Maintaining separate duty categories is therefore essential. It prevents overstated refund forecasts while allowing companies to evaluate legitimate drawback opportunities associated with eligible ordinary customs duties.
- On November 16, 2026, the Department of Commerce published the final results of the 2024-2025 antidumping duty administrative review of common alloy aluminum sheet from Bahrain (A-525-001), covering April 1, 2024, through March 31, 2025. GARMCO received a weighted-average dumping margin of 10.90 percent.
- The margin increased from the 6.25 percent preliminary rate published July 13, 2026. Commerce made changes after comments on major input adjustments, a cost of production offset, and general and administrative and interest expense ratios.
- The 10.90 percent rate becomes the cash deposit requirement for GARMCO on entries on or after November 16, 2026. The all-others rate remains 4.83 percent from the original investigation. Commerce intends to issue CBP assessment instructions no earlier than 35 days after publication.
- In related CIT litigation over the prior 2023-2024 review, the U.S. government filed a response brief on October 13, 2026, defending Commerce's third-country market selection, major input rule application, and date-of-sale methodology. Domestic aluminum producers filed a supporting brief on October 28, 2026.
- On November 12, 2026, industry reports noted GARMCO completed a hot rolling mill modernization project with SMS group, replacing motors and drives to restore and boost capacity. No significant practitioner discussions of the new final results appeared on X in the period.
Frequently Asked Questions
What Is the Final GARMCO Antidumping Margin?
The final weighted-average dumping margin for GARMCO is 10.90 percent. It applies as the cash deposit rate for subject entries on or after November 16, 2026, unless a different legally applicable instruction governs a particular transaction.
Does 10.90 Percent Apply to Every 2024-2025 Entry?
Not necessarily. The 10.90 percent figure is GARMCO's final weighted-average margin. Entries made during the reviewed period are generally assessed using importer-specific rates calculated from reviewed sales. The actual assessment may therefore differ by importer.
What Is the Rate for Other Bahraini Producers or Exporters?
The all-others rate remains 4.83 percent. However, companies with an existing producer-specific or exporter-specific rate may continue to use that rate. Brokers should evaluate the complete producer and exporter combination rather than relying only on country of origin.
When Will CBP Receive Assessment Instructions?
Commerce intends to issue assessment instructions no earlier than 35 days after the November 16, 2026 publication date. Liquidation may occur later because CBP processing, litigation, or other case-specific developments can affect timing.
Can the Antidumping Duties Be Recovered Through Drawback?
Antidumping and countervailing duties generally are not eligible for drawback. Importers may still evaluate ordinary customs duties and other eligible amounts separately, provided the underlying transactions satisfy applicable drawback requirements.
How Stable Software Can Help
Separate Eligible Drawback From AD Exposure
The Bahrain review reinforces the importance of separating antidumping liability from duties that may qualify for drawback. Stable Software makes DrawbackAI, flat-license duty drawback software that U.S. customs brokers can white-label for importer clients and use to file under their own filer codes.
Stable Software charges a flat software license and never takes a percentage of the refund. Customs brokers evaluating aluminum import activity can use a structured drawback program to pursue eligible ordinary customs duties without incorrectly treating antidumping or countervailing duties as recoverable. DrawbackAI offers brokers a way to provide that service directly to importer clients while retaining control of the filing relationship.
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