The China shrimp antidumping review for February 1, 2025, through January 31, 2026, has been rescinded because Commerce found no reviewable suspended entries. Importers and customs brokers must now prepare for liquidation at the cash deposit rates required when the affected merchandise entered or was withdrawn from warehouse.
What the Rescission Means for the China Shrimp AD Order
No New Administrative Review Rates Will Be Calculated
Commerce initiated the 2025-2026 administrative review of the antidumping duty order on certain frozen warmwater shrimp from China on March 31, 2026. CBP entry data subsequently showed no reviewable suspended entries during the period of review. With no interested-party comments challenging that finding, Commerce rescinded the review in its entirety under 19 CFR 351.213(d)(3).
The practical consequence is that Commerce will not calculate new exporter-specific assessment rates through this review. Instead, covered entries are generally assessed at the cash deposit rate required at the time of entry or withdrawal from warehouse under 19 CFR 351.212(c)(1)(i).
The appendix associated with the proceeding identifies 198 exporters and producers. Their inclusion in the review initiation did not establish that reviewable entries existed. Administrative reviews are based on suspended entries that can be examined and liquidated at a newly determined assessment rate. When CBP data identifies no such entries, Commerce generally has no transaction base on which to conduct the review.
The Underlying Antidumping Duty Order Remains Relevant
Rescission of an administrative review does not, by itself, revoke the underlying antidumping duty order. It ends the review for the specified period without calculating new rates. Importers should therefore distinguish between the status of the review and the continuing application of the order to merchandise within its scope.
That distinction is especially important for China-origin frozen warmwater shrimp because separate trade remedy developments may affect product scope or future duty exposure. Each entry must be evaluated using the order scope, exporter and producer information, entry date, and applicable instructions rather than broad assumptions about the product category.
Liquidation and Financial Exposure for Affected Entries
Cash Deposit Rates Become the Central Reference Point
For the affected review period, liquidation is expected to occur at the cash deposit rate required when each entry was made or when the merchandise was withdrawn from warehouse for consumption. The importer’s historical entry data therefore becomes the primary record for forecasting final antidumping duty liability.
Commerce intends to issue assessment instructions to CBP no earlier than 35 days after publication. Based on an October 29, 2026 publication date, the earliest corresponding date is December 3, 2026. That date should be treated as an earliest potential instruction date, not a guarantee that every affected entry will liquidate immediately.
Importers and customs brokers should identify entries associated with the covered exporters and producers, confirm that they fall within the February 1, 2025, through January 31, 2026 period, and compare the deposited antidumping duty amount against the rate required at entry. Relevant records generally include entry summaries, commercial invoices, manufacturer affidavits, case numbers, deposit rate references, and ACE liquidation data.
Rescission Does Not Eliminate Entry-Level Risk
A no-entry rescission can appear to reduce uncertainty because no newly calculated assessment rate will apply. It does not eliminate the possibility of data discrepancies, classification issues, scope questions, or mismatches among exporter, producer, and case information.
For example, an entry may have been declared under an incorrect case number, associated with the wrong producer combination, or excluded from the review population because it was not suspended as expected. Those issues require separate analysis. The rescission does not automatically validate the original entry declaration.
Trade compliance teams should also monitor the actual liquidation status of each entry. A forecast based on the deposit rate is useful for accruals, but final accounting should generally wait for CBP liquidation data and any resulting bills, refunds, or interest calculations.
Compliance Priorities for Importers and Customs Brokers
Build a Review-Period Entry Population
The first operational step is to create a complete entry population for China-origin frozen warmwater shrimp entered during the review period. The data set should capture the entry number, entry date, importer of record, exporter, producer, manufacturer identification code, tariff classification, antidumping case number, entered value, quantity, deposit rate, and deposited amount.
That population should then be compared with the entities covered by the rescinded review. Entity names often appear in multiple formats across invoices, entry records, and government systems. Compliance personnel should account for abbreviations, translated names, punctuation differences, and known trade names before concluding that an exporter or producer is unrelated.
Brokers should communicate clearly with importer clients about the limited effect of the rescission. It means that no new rate will be calculated through this administrative review. It does not necessarily mean the entries were free from antidumping duties or that deposits will be returned.
Reconcile Deposits, Instructions, and Liquidation Results
A disciplined post-entry process should compare three separate elements. These are the cash deposit rate required at entry, the amount actually deposited, and the amount ultimately assessed at liquidation. Differences can arise from entry corrections, value changes, rate selection errors, or CBP processing.
Importers should also preserve documentation supporting scope determinations and exporter-producer combinations. Frozen seafood supply chains can involve processors, trading companies, cold-storage operators, and intermediaries. The seller shown on the commercial invoice may not be the producer relevant to the antidumping duty rate.
Parallel trade remedy activity must be tracked separately. A countervailing duty investigation, a scope-related change, or a partial revocation does not automatically produce the same treatment as this administrative review rescission. Compliance systems should maintain separate case numbers, deposit types, effective dates, and legal bases for each measure. Combining them into a single generic duty field can create inaccurate accruals and defective refund calculations.
Duty Drawback Treatment for Shrimp Imports
Antidumping Duties Must Be Excluded
Antidumping and countervailing duties are not eligible for duty drawback under 19 U.S.C. 1677h. Accordingly, an importer cannot recover the antidumping duty assessed on China-origin frozen warmwater shrimp merely because the shrimp, substituted merchandise, or a manufactured article is later exported or destroyed.
This restriction makes accurate duty-type separation essential. Entry records should distinguish antidumping and countervailing duty deposits from ordinary customs duties, merchandise processing fees, harbor maintenance fees, and other amounts. A drawback calculation that treats the total payment on an entry as potentially recoverable can overstate the claim and create avoidable compliance exposure.
The rescission does not change the drawback prohibition for antidumping duties. Even when entries liquidate at the original cash deposit rate, the final antidumping duty amount remains outside the eligible drawback calculation.
Ordinary Customs Duties May Still Support Drawback
Ordinary customs duties paid on the same entries may still qualify for drawback when the merchandise is exported, destroyed, or used to manufacture exported goods and all applicable drawback requirements are satisfied. Eligibility generally depends on the drawback provision used, the relationship between imported and exported merchandise, required time limits, possession or transfer records, and the quality of supporting data.
Importers and brokers should therefore avoid excluding an entire entry merely because it includes antidumping duties. The better approach is to separate eligible ordinary customs duties from ineligible trade remedy duties at the line and duty-type level.
For seafood importers, this can require careful matching among import quantities, inventory movements, processing records, exports, and destruction documentation. Product descriptions, species, presentation, packaging, and quantity units should remain consistent enough to support the chosen drawback methodology. A clean separation between eligible and ineligible amounts also helps brokers prepare claims under their own filer codes without incorporating prohibited antidumping duty refunds.
- On October 29, 2026, Commerce rescinded the full administrative review of the AD order on frozen warmwater shrimp from China (A-570-893) covering February 1, 2025, through January 31, 2026.* The review, initiated March 31, 2026, showed no reviewable suspended entries per CBP data released April 10, 2026. No parties commented, so the review ended under 19 CFR 351.213(d)(3). Entries will be liquidated at the cash deposit rate in effect at the time of entry.
- On October 28, 2026, Commerce issued a partial revocation of the AD orders on Chinese frozen warmwater shrimp and diamond sawblades to implement a WTO Dispute Settlement Body ruling.* This follows prior Section 129 determinations and affects the scope of the longstanding China shrimp AD order originally published in 2005.
- On October 27, 2026, Commerce initiated CVD investigations on frozen shrimp from seven countries, including China.* This new subsidy probe runs parallel to existing AD measures and could lead to additional duties if subsidies are found.
- No recent practitioner discussions on X were identified* in the past 30 days regarding the China shrimp AD review rescission or related order changes. Similar prior-year rescissions (e.g., 2023-2024 and 2024-2025 periods) followed the same no-entry pattern.
Frequently Asked Questions
Why Was the China Shrimp Antidumping Review Rescinded?
Commerce rescinded the review because CBP data showed no reviewable suspended entries for the February 1, 2025, through January 31, 2026 period. Without suspended entries available for assessment at newly calculated rates, Commerce had no transaction population on which to conduct the administrative review.
Does Rescission Mean the Antidumping Duty Order Was Terminated?
No. Rescission ends this specific administrative review. It does not, by itself, terminate the underlying antidumping duty order on certain frozen warmwater shrimp from China. Importers must continue to evaluate scope, entry dates, exporter-producer combinations, and applicable cash deposit requirements.
At What Rate Will Affected Entries Liquidate?
Affected entries are generally expected to liquidate at the cash deposit rate required at the time of entry or withdrawal from warehouse. Importers should confirm the rate recorded on each entry and monitor CBP data for the actual liquidation date and assessed amount.
When Could Assessment Instructions Be Issued?
Commerce intends to issue assessment instructions no earlier than 35 days after publication. With publication on October 29, 2026, the earliest corresponding date is December 3, 2026. Actual liquidation timing may vary after CBP receives and processes those instructions.
Can Antidumping Duties on the Shrimp Entries Be Recovered Through Drawback?
No. Antidumping and countervailing duties are not eligible for drawback under 19 U.S.C. 1677h. However, ordinary customs duties paid on the same entries may still qualify if the merchandise and subsequent exportation, destruction, or manufacturing activity satisfy the applicable drawback requirements.
What Records Should Customs Brokers Review?
Brokers should review entry summaries, invoices, exporter and producer identities, manufacturer identification codes, case numbers, deposit rates, deposited amounts, scope documentation, and liquidation status. They should also keep ordinary customs duties separate from antidumping and countervailing duty amounts in any drawback data set.
How Stable Software Can Help
Separate Eligible Duties From Ineligible AD/CVD Amounts
Customs brokers managing drawback for seafood importers need reliable separation between ordinary customs duties and ineligible antidumping or countervailing duties. DrawbackAI is flat-license duty drawback software that U.S. customs brokers can white-label for importer clients while filing claims under their own filer codes.
Stable Software charges a flat software license and never takes a percentage of the refund. This model allows brokers to retain control of client relationships, filing responsibilities, and drawback economics while keeping prohibited AD/CVD amounts outside claim calculations. Brokers evaluating drawback opportunities on shrimp entries can use DrawbackAI as part of a structured process for preparing compliant claims involving eligible ordinary customs duties.
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