China Common Alloy Aluminum Sheet CVD Review Rescinded

Commerce has rescinded the 2025 countervailing duty review of common alloy aluminum sheet from China in its entirety. Although the decision does not change cash deposit rates, it has direct consequences for assessment, liquidation forecasting, duty accounting, and drawback calculations involving 2025 entries.

What the Rescission Means for the 2025 Review Period

Why Commerce Ended the Review

The rescinded CVD administrative review covered common alloy aluminum sheet, commonly called CAAS, entered from January 1 through December 31, 2025. The proceeding involved entries potentially associated with Alcha International Holdings Limited, Jiangsu Alcha Aluminum Co., Ltd., Yantai Jintai International Trade Co., Ltd., and Yinbang Clad Material Co., Ltd.

CBP entry data identified suspended entries associated only with Yantai Jintai and Yinbang. The request involving Yantai Jintai was withdrawn on May 29, 2026, while the petitioner withdrew its request involving Yinbang on June 29, 2026. Alcha International and Jiangsu Alcha had no reviewable suspended entries during the period.

With the applicable requests withdrawn and no reviewable entries remaining for the other companies, Commerce rescinded the proceeding in full. The outcome closes the company-specific review process for the 2025 period without calculating new CVD assessment rates for the covered entries.

This distinction is important. Rescission does not revoke the underlying CVD order, eliminate existing cash deposit requirements, or establish a zero rate. It simply means that the administrative review will not produce revised company-specific rates for the period. The CVD order covering common alloy aluminum sheet from China remains active, and importers must continue applying the appropriate deposit requirements to covered merchandise.

The rescission is scheduled for publication on October 26, 2026. Commerce generally issues assessment instructions after the applicable waiting period, with instructions in this matter expected no earlier than November 30, 2026.

Assessment, Liquidation, and Importer Accounting

Entries Should Generally Be Assessed at Deposit Rates

Because the review ended without final calculated rates, covered 2025 entries will generally be assessed at the cash deposit rate required at the time of entry. Cash deposit rates also remain unchanged for prospective entries unless Commerce separately modifies them through another proceeding.

Importers should not treat the rescission as an immediate liquidation event. Commerce must issue assessment instructions to CBP, and CBP must then process those instructions against the affected suspended entries. Actual liquidation dates may vary by port, entry, importer, and internal processing conditions.

Brokers and trade compliance teams should build an entry-level population for the 2025 period and compare each entry against the rate required when it was filed. The review should include:

• Entry number and entry date
• Exporter, producer, and supplier identity
• Entered value and applicable case number
• CVD cash deposit rate used at entry
• Deposit amount actually paid
• Current liquidation status
• Any protests, corrections, disclosures, or other pending activity

Reconcile Expected and Actual Liquidation Results

An operational reconciliation should compare the expected assessment amount with the amount ultimately shown in CBP liquidation data. This internal process is separate from the formal CBP Reconciliation program unless the entries were specifically flagged for reconciliation.

Differences can arise from incorrect rates, case numbers, manufacturer identification, value adjustments, or scope treatment. Importers should also confirm that their financial reserves align with the expected assessment outcome. A rescinded review may reduce uncertainty because no new review rate will be calculated, but it does not cure filing errors or resolve unrelated scope questions.

Post-liquidation review remains essential. Once CBP liquidates an entry, the importer generally has a limited period to challenge errors through the appropriate administrative process. Companies should therefore monitor liquidation notices rather than relying solely on estimates prepared before assessment instructions were issued.

Broader CAAS Compliance and Drawback Considerations

Scope Developments Remain Separate From the Rescission

The end of the 2025 CVD review does not settle every compliance issue involving aluminum products from China. Scope and circumvention proceedings operate separately from administrative reviews and can affect whether particular products are subject to antidumping and countervailing duty orders.

Commerce initiated a circumvention inquiry in October 2026 involving certain aluminum composite panels produced in China. The inquiry concerns panels constructed with a low-density polyethylene core between thin aluminum sheets and may lead to suspension of liquidation or additional cash deposit requirements for merchandise determined to fall within the inquiry.

Certain aluminum can stock meeting detailed physical, temper, gauge, and lubricant specifications has also been partially removed from the CAAS orders. Eligibility depends on the complete written product description, not merely the declared tariff classification. Importers should maintain technical specifications, mill certificates, drawings, purchase records, and product literature supporting any claimed exclusion.

These developments make product-level controls especially important. A broker cannot determine CAAS scope treatment reliably from an HTS number alone. Importers remain responsible for providing accurate composition, thickness, alloy, temper, coating, core material, and end-use information.

Keep AD/CVD Separate From Drawback-Eligible Duty

Antidumping and countervailing duties are not eligible for drawback under 19 U.S.C. 1677h. The rescission does not change that treatment. Any CVD amount assessed on the CAAS entries must remain excluded from drawback calculations.

Ordinary customs duties paid on the same entries 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 satisfies the applicable requirements. Importers and drawback filers should separate ordinary duty, merchandise processing fees, antidumping duties, and countervailing duties at the entry-line level.

This separation prevents ineligible AD/CVD amounts from being included in a refund claim while preserving potentially recoverable ordinary duties. It also creates a clearer audit trail connecting import entries, inventory records, exports, destruction activity, and claimed duty amounts.

Frequently Asked Questions

Does the Rescission Eliminate CVD on CAAS From China?

No. The rescission ends the 2025 administrative review, not the underlying CVD order. Covered imports remain subject to the order, and applicable cash deposit requirements continue unless Commerce changes them through a separate proceeding.

Will Importers Receive Refunds Because the Review Was Rescinded?

Not automatically. Entries are generally expected to be assessed at the cash deposit rate required at the time of entry. A refund or additional bill could still result if the amount deposited differed from the amount properly assessable because of a filing, valuation, rate, or case-number issue.

When Will the Affected Entries Liquidate?

Commerce is expected to issue assessment instructions no earlier than 35 days after the October 26, 2026 publication date, which is November 30, 2026. CBP liquidation may occur later because processing times vary. Importers should monitor entry status directly rather than assuming liquidation on the instruction date.

Are CVD Payments Eligible for Duty Drawback?

No. Countervailing duties and antidumping duties are excluded from drawback. However, ordinary customs duties paid on the same entries may qualify when the statutory and documentary requirements for an export, destruction, or manufacturing drawback claim are met.

Does the Rescission Resolve Scope Questions for Composite Panels?

No. Scope and circumvention inquiries are separate proceedings. Importers of aluminum composite panels and other processed aluminum products should evaluate the written scope language, physical specifications, producer identity, entry dates, and any applicable suspension instructions.

What Records Should Importers and Brokers Retain?

Relevant records generally include entry summaries, commercial invoices, packing lists, mill certificates, product specifications, cash deposit calculations, payment data, liquidation records, export documentation, and inventory movement records. Drawback files should clearly distinguish ordinary customs duties from ineligible AD/CVD amounts.

How Stable Software Can Help

Support Defensible Drawback Calculations

The CAAS review rescission reinforces the need to separate drawback-eligible ordinary customs duties from ineligible antidumping and countervailing duties. Entry-level duty data, liquidation changes, exports, and claim calculations must remain aligned throughout the drawback process.

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 codes. Stable Software charges a flat software license and never takes a percentage of the importer’s refund. Customs brokers evaluating how to expand drawback services while retaining control of client relationships and filings can explore the platform for a more structured approach to drawback operations.

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