The Brazil aluminum foil antidumping duty landscape has changed for importers purchasing merchandise produced by Companhia Brasileira de Alumínio. The final 13.65% margin affects new cash deposits, historical entry liquidation, reimbursement certifications, and the separation of antidumping duties from drawback-eligible ordinary customs duties.
What the Final 13.65% Antidumping Margin Means
CBA received a lower final margin
The Commerce Department assigned a final weighted-average dumping margin of 13.65% to Companhia Brasileira de Alumínio and CBA Itapissuma Ltda., collectively CBA, for the administrative review covering November 1, 2023, through October 31, 2024. Commerce continued to treat the two companies as a single entity.
The final result is lower than the 16.61% margin calculated at the preliminary stage. The change followed consideration of issues involving the treatment of the CBA entities, taxes associated with billing adjustments, and the deduction of insurance expenses from export price.
The 13.65% rate becomes the cash deposit rate for qualifying CBA merchandise entered, or withdrawn from warehouse for consumption, on or after October 30, 2026. Customs brokers and importers should update broker instructions, product databases, landed-cost models, and entry review procedures accordingly.
The all-others rate remains relevant
The all-others rate established in the original investigation remains 13.93%. That rate may apply when the producer or exporter does not qualify for a company-specific rate or when reseller-policy rules direct liquidation at the all-others rate.
Accurate identification of the producer, exporter, seller, and intermediate reseller is therefore essential. A commercial invoice that merely identifies Brazil as the country of origin may not provide enough information to determine the correct antidumping case rate. Importers should retain mill certificates, producer declarations, purchase orders, and supply-chain records that connect the entered foil to the appropriate manufacturer and exporter.
The underlying antidumping duty order has been in place since November 2021. The new administrative review result does not remove the order or narrow its scope. It changes the rate applicable to CBA for prospective cash deposits and establishes the basis for assessing reviewed entries.
Cash Deposits, Assessments, and Liquidation Controls
Prospective deposits differ from retrospective liability
Antidumping administration separates cash deposits from final duty assessment. The 13.65% rate generally governs deposits on qualifying CBA entries made on or after the publication date. It does not automatically determine the final duty owed on every entry made during the 2023-2024 review period.
For reviewed entries, Commerce will calculate importer-specific assessment rates. Those rates are used to instruct U.S. Customs and Border Protection on liquidation. An importer-specific rate below 0.5% is generally treated as de minimis, allowing the affected entries to liquidate without antidumping duties. Other reviewed entries may liquidate with additional duty due or with a refund, depending on the final assessment calculation and the deposits previously paid.
Importers should compare entry-level deposit data with the expected assessment treatment before liquidation. This comparison is an internal duty reconciliation exercise and should not be confused with participation in CBP's formal Reconciliation program.
Assessment instructions require active monitoring
Commerce intends to issue assessment instructions no earlier than 35 days after publication, which places the earliest expected instruction date around December 4, 2026. If a timely summons is filed with the U.S. Court of International Trade, liquidation instructions generally wait until the applicable statutory injunction period has passed.
Customs brokers and compliance teams should monitor liquidation status rather than assuming that all entries will liquidate immediately after the 35-day period. Protest rights, judicial challenges, suspension status, and CBP processing may affect the practical timeline.
The reseller policy creates an additional exposure point. Unreviewed entries of CBA-produced merchandise may liquidate at the 13.93% all-others rate when no rate applies to the intermediate company involved. Importers using distributors or trading companies should map each transaction chain and verify whether the exporter or reseller was covered by the review. Producer identity alone may not resolve the applicable assessment treatment.
Managing Total Duty Exposure and Drawback Eligibility
Multiple tariff programs may apply to the same entry
The 13.65% antidumping margin should not be evaluated in isolation. Brazilian aluminum foil may also be subject to ordinary customs duties and, depending on classification, scope, exclusions, and entry date, additional tariffs under Section 232 or Section 301. These measures are legally distinct and may apply cumulatively.
A landed-cost model should identify each duty component separately. Combining all tariffs into a single percentage can obscure the governing authority, payment status, refund potential, and accounting treatment. Separate data fields for ordinary duty, antidumping duty, countervailing duty, Section 232 duty, Section 301 duty, merchandise processing fees, and other charges provide a more defensible audit trail.
Importers should also validate that the merchandise falls within the antidumping order's scope. Classification is relevant but is not always conclusive. Physical characteristics, product specifications, thickness, form, and other scope language generally determine whether merchandise is covered.
Antidumping duties cannot be included in drawback
Antidumping and countervailing duties are not eligible for duty drawback. An importer cannot include the 13.65% CBA antidumping deposit or a final assessed antidumping amount in a drawback refund calculation.
Ordinary customs duties paid on the same entry may still qualify for drawback when the merchandise is exported, destroyed, or used to manufacture an exported article and all other statutory requirements are satisfied. Eligibility for Section 232 or Section 301 duties requires separate analysis based on the applicable drawback treatment and transaction facts.
Drawback programs should therefore preserve duty amounts by type at the entry-line level. If antidumping duty is blended with ordinary duty in an enterprise resource planning system or broker data feed, the resulting claim may overstate the refundable amount. Clear segregation also helps customs brokers explain why the total duties paid do not equal the amount requested in a drawback claim.
Importers should retain entry summaries, payment records, commercial documents, export evidence, inventory records, and manufacturing records as applicable. Strong data lineage allows eligible duties to be claimed without inadvertently including prohibited AD or CVD amounts.
- - On October 1, 2026, the U.S. International Trade Commission instituted five-year sunset reviews of the antidumping duty order on certain aluminum foil from Brazil (A-351-856), along with related orders covering Armenia, Oman, Russia, and Turkey. Interested parties must submit responses by November 2, 2026, to help determine if revocation would likely lead to continuation or recurrence of material injury.
- The Commerce Department published preliminary results of the 2023-2024 AD administrative review on May 7, 2026, assigning a 16.61 percent dumping margin to Companhia Brasileira de Alumínio and CBA Itapissuma (treated as a single entity). Final results addressing comments on entity treatment, billing adjustment taxes, and insurance expense deductions are scheduled for Federal Register publication on October 30, 2026.
- Trade reports published in late October 2026 confirm that the 25 percent Section 301 tariff on most imports from Brazil, effective July 22, 2026, continues to apply in addition to existing antidumping duties on aluminum foil.
- An October 22, 2026 industry update states that Section 232 tariffs of 50 percent apply to aluminum articles including foil from Brazil, stacking with AD duties. No specific practitioner discussions on X were identified regarding the 2023-2024 review in the past 30 days.
Frequently Asked Questions
What is the final CBA antidumping rate for Brazilian aluminum foil?
The final weighted-average dumping margin is 13.65% for Companhia Brasileira de Alumínio and CBA Itapissuma Ltda., treated collectively as CBA. The rate resulted from the administrative review covering entries from November 1, 2023, through October 31, 2024. The all-others rate remains 13.93%.
When does the new 13.65% cash deposit rate apply?
The new rate generally applies to qualifying CBA merchandise entered, or withdrawn from warehouse for consumption, on or after October 30, 2026. Entries made before that date remain subject to the deposit requirements in effect when they were entered, although final assessment may differ for entries covered by the review.
Will every reviewed CBA entry liquidate at 13.65%?
Not necessarily. Commerce calculates importer-specific assessment rates for reviewed entries. The 13.65% weighted-average margin is important, but it is not automatically the liquidation rate for every importer. Importer-specific rates below 0.5% are generally treated as de minimis and liquidated without antidumping duties.
What reimbursement certification is required?
Importers must generally submit a certificate addressing whether the exporter or producer reimbursed the importer for antidumping duties. The certificate required under 19 CFR 351.402(f)(2) should be filed before liquidation. Failure to provide it can create a presumption of reimbursement and may result in additional duty exposure.
Can antidumping duties be recovered through duty drawback?
No. Antidumping and countervailing duties are excluded from drawback. However, ordinary customs duties paid on the same imported merchandise may remain eligible if the export, destruction, substitution, manufacturing, and recordkeeping requirements for the selected drawback provision are met.
What should importers and brokers do now?
They should update the CBA cash deposit rate, identify entries within the review period, verify producer and reseller relationships, monitor liquidation status, prepare the reimbursement certificate, and separate antidumping amounts from potentially drawback-eligible duties. Landed-cost systems should also account for other tariffs that may apply cumulatively.
How Stable Software Can Help
Keep eligible duty recovery separate from AD exposure
Antidumping reviews create a data challenge because importers must distinguish nonrefundable AD duties from ordinary customs duties that may qualify for drawback. Customs brokers also need reliable entry, export, inventory, and duty-type records when preparing claims for importer clients.
DrawbackAI is flat-license duty drawback software that U.S. customs brokers can white-label for their 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. Brokers evaluating recovery opportunities on aluminum foil entries can use a structured drawback process while keeping antidumping and countervailing duty amounts outside the claim calculation.
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