The boltless steel shelving AD/CVD orders covering China will remain in force following their second sunset reviews. Importers must continue managing substantial cash deposit exposure while paying close attention to product scope, packaging configuration, alternative sourcing, and the separation of trade remedy duties from drawback-eligible ordinary customs duties.
What the Continuation Means for Importers
The Orders Remain Effective After the Second Sunset Reviews
The antidumping duty order A-570-018 and countervailing duty order C-570-019 remain in effect for boltless steel shelving units prepackaged for sale from China. The continuation became effective September 29, 2026, with the formal continuation notice published on October 14, 2026.
The orders were originally issued on October 21, 2015, and were previously continued in May 2021. During the second five-year sunset reviews, the U.S. Department of Commerce determined that revocation would likely lead to the continuation or recurrence of dumping and countervailable subsidization. The U.S. International Trade Commission separately determined that revocation would likely lead to the continuation or recurrence of material injury within a reasonably foreseeable time.
As a result, U.S. Customs and Border Protection will continue collecting antidumping and countervailing duty cash deposits at the applicable rates in effect when merchandise enters the United States. The continuation does not reset deposit rates or establish a uniform rate for all Chinese suppliers.
Importers should treat the orders as an ongoing landed-cost and compliance obligation, not a temporary measure approaching expiration. Although sunset reviews generally occur every five years, an order continues unless the agencies make the findings necessary for revocation. The next reviews are expected to be initiated no later than 30 days before the fifth anniversary of the latest injury determination.
For purchasing, finance, and trade compliance teams, this means that Chinese-origin shelving covered by the written scope will typically continue to carry both ordinary customs duties and potentially significant AD/CVD cash deposits.
Scope Analysis Is the First Compliance Priority
Packaging and Product Configuration Can Determine Coverage
The orders generally cover boltless steel shelving units prepackaged for sale, with or without decks. Covered merchandise also includes add-on kits designed to expand an existing shelving unit. The analysis should focus on the physical characteristics, packaging, and condition of the merchandise as imported rather than relying solely on marketing language or a commercial product name.
Several product categories are excluded. These generally include wall-mounted shelving, qualifying wire shelving units, bulk-packed parts or components, and made-to-order shelving systems. Distinguishing a prepackaged shelving kit from bulk-packed components can therefore be commercially significant. An importer should not assume that disassembled merchandise is outside the orders merely because the shelving is not assembled at entry.
Tariff Classification Does Not Control Scope
Relevant classifications include HTSUS 9403.20.0018, 9403.20.0020, 9403.20.0025, and 9403.20.0026. Certain merchandise may also enter under 9403.10.0040. These tariff numbers help identify potentially affected transactions, but the written scope language is dispositive.
A classification outside the listed subheadings does not necessarily remove merchandise from an AD/CVD order. Conversely, classification under a listed subheading does not automatically establish that every product is covered. Importers should examine specifications, assembly instructions, packaging lists, sales literature, component quantities, and intended installation.
Each SKU should be assigned a documented scope position. That review should identify whether the product is a complete prepackaged unit, an add-on kit, wire shelving, a wall-mounted system, bulk-packed parts, or a made-to-order installation. When facts remain ambiguous, importers should consider whether a formal scope ruling or other specialized legal analysis is appropriate before relying on an exclusion.
Sunset Rates Are Not New Cash Deposit Rates
Likely-to-Prevail Findings Serve a Different Purpose
Commerce found that dumping would likely continue or recur at weighted-average margins of up to 112.68 percent. In the countervailing duty review, Commerce identified likely-to-prevail subsidy rates of 12.40 percent for Ningbo ETDZ Huixing Trade Co., Ltd., 15.05 percent for Nanjing Topsun Racking Manufacturing Co., Ltd., 80.39 percent for fourteen named companies, and 13.73 percent for all other producers or exporters.
These sunset review figures are not new cash deposit rates. They are analytical findings used in the sunset review process and communicated for the injury analysis. Importers should not replace the rates in their entry systems, purchase models, or broker instructions with these figures solely because they appeared in the sunset determinations.
Deposit Exposure Requires Entry-Specific Review
The applicable cash deposit rate generally depends on the producer, exporter, combination of parties, and instructions in effect at the time of entry. Importers should confirm that supplier identities are complete and consistent across commercial invoices, entry documentation, manufacturer affidavits, and purchasing records.
AD/CVD deposits are also not necessarily the final duty liability. Administrative reviews can produce assessment rates that differ from amounts deposited at entry. Liquidation may occur well after importation, making accurate accruals and transaction-level records important for financial reporting.
Landed-cost models should therefore distinguish among ordinary customs duty, antidumping duty deposits, countervailing duty deposits, freight, brokerage, and other import charges. Combining these amounts into a single duty field can obscure exposure, interfere with post-entry analysis, and create errors in drawback calculations. Compliance teams should also coordinate with accounts payable and sourcing personnel so that a supplier change does not occur without a corresponding review of AD/CVD treatment.
Sourcing and Drawback Require Separate Analysis
Alternative Countries May Have Their Own Trade Remedies
Some importers may consider shifting production from China to another country to reduce AD/CVD exposure. That strategy requires more than changing the invoice country. Origin must reflect the actual manufacturing facts, and the importer should evaluate whether the same product from the alternative country is subject to a separate trade remedy proceeding or order.
Boltless steel shelving from Thailand, for example, is subject to its own antidumping duty order. Supplier-specific developments under that order do not eliminate the need to review coverage and applicable deposit instructions for each entry. Importers should evaluate alternative sourcing at the producer and product level rather than assuming that any non-China source is free from additional duties.
Country-of-origin documentation should be incorporated into vendor onboarding and periodic supplier reviews. Bills of materials, production records, factory information, and component sourcing may become important when a supply chain changes after an AD/CVD order continues.
AD/CVD Amounts Must Be Excluded From Drawback
Antidumping and countervailing duties are not eligible for duty drawback under 19 U.S.C. 1677h. Importers and drawback filers should therefore exclude both AD and CVD amounts from recoverable duty calculations.
Ordinary customs duties paid on the same entry may still qualify for drawback when the merchandise is exported or destroyed, or when it is used to manufacture an exported article, provided the claim otherwise satisfies the applicable requirements. The presence of AD/CVD liability does not automatically disqualify the ordinary duty portion.
Entry data should keep ordinary customs duty, AD deposits, and CVD deposits in separate fields. That separation supports accurate drawback calculations, reconciliation of broker data, audit review, and financial reporting. It also reduces the risk that a claim will inadvertently seek a refund of an ineligible trade remedy duty.
- Commerce continued the AD (A-570-018) and CVD (C-570-019) orders on boltless steel shelving units prepackaged for sale from China, effective September 29, 2026, after second sunset reviews.* The notice appeared in the Federal Register on October 14, 2026 (91 FR 65162). Both Commerce and the ITC found that revocation would likely lead to continuation or recurrence of dumping, subsidization, and material injury. CBP continues collecting cash deposits at the rates in effect at the time of entry.
- The ITC issued an affirmative injury determination in the second five-year reviews on September 15, 2026 (published in the Federal Register on September 29, 2026, 91 FR 61439).* Revocation of the orders would likely lead to continuation or recurrence of material injury within a reasonably foreseeable time. The reviews were expedited after the domestic interested party group response (from petitioner Edsal Manufacturing) was adequate and the respondent group response was inadequate. USITC Publication 5793 (September 2026) contains the views and data.
- On October 19, 2026, Commerce published preliminary results of the AD administrative review of boltless steel shelving from Thailand (a related 2024 order covering the same product type from other countries).* Fuding Industries Company Limited did not sell at less than normal value during the November 29, 2023-May 31, 2025 period of review. The review was rescinded for five other companies. Interested parties may comment.
- Chinese trade media reported the U.S. continuation on October 15, 2026.* Coverage noted the original 2015 orders, HTSUS subheadings (such as 9403.20.0018/0020/0025/0026), and that the orders remain in effect from September 29, 2026.
- Practitioner discussions on X in the past 30 days were limited and not focused on this sunset continuation.* Older Customs Updates posts covered automatic liquidation instructions for prior periods, with no notable recent commentary from trade lawyers, importers, or industry accounts on the October 2026 continuation or ITC findings.
Frequently Asked Questions
When Did the Continuation Become Effective?
The continuation of the antidumping and countervailing duty orders became effective September 29, 2026. Importers should continue applying the orders to covered entries based on the cash deposit instructions in effect at entry.
Do the Sunset Margins Become the New Deposit Rates?
No. The dumping margin of up to 112.68 percent and the identified subsidy rates are likely-to-prevail findings used during the sunset reviews. They do not, by themselves, replace existing company-specific or all-others cash deposit rates.
Are Bulk-Packed Shelving Parts Covered?
Bulk-packed parts or components are generally excluded, but the actual packaging and product configuration require careful review. Importers should document how components are packed, sold, shipped, and intended to be assembled. Labeling parts as bulk packed does not establish exclusion if the transaction otherwise meets the written scope.
Does an HTSUS Number Determine Whether Shelving Is Covered?
No. HTSUS classifications can help identify merchandise for review, but the written scope controls. A product may require scope analysis even if it enters under a classification not expressly listed in the order.
Can AD/CVD Deposits Be Recovered Through Duty Drawback?
No. Antidumping and countervailing duties are not drawback eligible. Ordinary customs duties paid on the same entries may still qualify when all drawback requirements are met. Claim calculations should isolate and exclude every AD/CVD amount.
Does Sourcing From Thailand Eliminate Trade Remedy Risk?
Not necessarily. Boltless steel shelving from Thailand is subject to a separate antidumping duty order. Importers should review the producer, merchandise, applicable deposit instructions, and current proceeding status before changing sourcing assumptions.
How Stable Software Can Help
Keep Eligible Duty Separate From AD/CVD Amounts
Customs brokers managing drawback for shelving importers need accurate transaction-level separation between eligible ordinary duties and ineligible AD/CVD amounts. DrawbackAI is Stable Software's flat-license duty drawback software for U.S. customs brokers. Brokers can white-label the software for importer clients and file claims under their own filer codes.
Stable Software charges a flat software license and never takes a percentage of the refund. For brokers building or expanding a drawback practice, this model helps preserve control of the client relationship while avoiding refund-based software fees. A review of current drawback workflows can help determine whether DrawbackAI fits the brokerage's filing model.
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