China Tissue Paper and Magnesium AD Reviews

China antidumping duty reviews now place two longstanding orders under renewed scrutiny while a related circumvention inquiry creates immediate sourcing risk. Importers of tissue paper and alloy magnesium should treat the proceedings as active compliance events, not routine administrative exercises, because future duty exposure may depend on participation, supply chain evidence, and entry-level controls.

What the Fourth Sunset Reviews Mean for Importers

The U.S. International Trade Commission and the Department of Commerce opened fourth five-year reviews of the antidumping duty orders covering certain tissue paper products and alloy magnesium from China on October 1, 2026. The tissue paper proceeding is associated with order A-570-894, while the alloy magnesium proceeding is associated with order A-570-896.

Both orders have remained in place for more than two decades. The tissue paper order dates to March 30, 2005 and was continued following prior reviews in 2010, 2016, and 2021. The alloy magnesium order dates to April 15, 2005 and was continued following reviews in 2011, 2016, and 2021. That history may indicate durable domestic industry concerns, but it does not predetermine the current results.

Commerce and ITC Examine Different Questions

Commerce generally evaluates whether dumping would be likely to continue or recur if an order were revoked. The ITC generally considers whether revocation would be likely to lead to continuation or recurrence of material injury within a reasonably foreseeable time. An order typically remains in place when both agencies reach the findings required for continuation.

The ITC set November 2, 2026 as the deadline for interested party responses and December 8, 2026 for comments on response adequacy. Commerce required domestic interested parties to submit notices of intent to participate within 15 days of publication, making October 16 the relevant date, and substantive responses are due November 2 after weekend deadline adjustments.

Importers are not passive observers. Their purchasing patterns, supplier relationships, market data, and participation decisions can affect how the administrative record develops. Companies should coordinate with trade counsel before submitting information because sunset review responses generally involve formal standing, factual support, certifications, and strict filing requirements.

Vietnam Tissue Paper Faces Separate Circumvention Risk

A country-wide circumvention inquiry is examining tissue paper completed in Vietnam using jumbo rolls manufactured in China. The inquiry applies to covered merchandise exported from Vietnam to the United States and has been active since August 6, 2026. It is separate from the sunset review, even though both proceedings concern the scope and enforcement of the China tissue paper antidumping duty order.

The central issue is not simply the country from which the finished product was shipped. Commerce is evaluating whether processing Chinese jumbo rolls in Vietnam results in merchandise that should be treated as subject to the China order. Importers relying solely on Vietnamese invoices, certificates of origin, or final processing locations may therefore have an incomplete compliance record.

Country of Export Is Not Enough

Importers should be able to trace jumbo rolls and other relevant inputs back through the production chain. Useful documentation typically includes mill records, purchase orders, production logs, inventory movement reports, bills of materials, supplier affidavits, transportation records, and payment evidence. Records should connect specific imported shipments to the jumbo rolls used in Vietnam rather than merely describe the supplier's general sourcing practices.

Commerce is continuing suspension for entries already suspended and requiring deposits as if the merchandise were covered. An affirmative determination could also produce additional suspension instructions and potentially affect earlier unliquidated entries, depending on the final findings and applicable instructions. Importers should not assume that entries remain protected merely because liquidation has not yet been suspended.

A preliminary determination is generally expected within 150 days of initiation, with a final determination within 300 days. Those dates may be extended or the inquiry may be rescinded. Companies should monitor entry status and preserve supporting records rather than build compliance plans around an assumed January 2027 or June 2027 outcome.

Building an Entry-Level Compliance Response

The sunset reviews and circumvention inquiry require different legal analyses, but they create a common operational need: reliable entry-level data. Importers should identify all potentially affected entries, confirm product descriptions and tariff classifications, map suppliers to manufacturers, and separate ordinary customs duties from antidumping and countervailing duty deposits.

For tissue paper, the review should include merchandise imported directly from China and tissue completed in Vietnam. For magnesium, compliance teams should examine chemical composition, physical form, product specifications, supplier representations, and scope language. Commercial labels are not always sufficient to establish whether merchandise falls within an order.

Prioritize Origin and Scope Evidence

A practical control framework should assign responsibility across sourcing, logistics, customs, finance, and legal teams. Procurement personnel may hold the best information about raw material origins. Customs teams may control entry summaries and broker instructions. Finance may hold payment records and deposit data. Legal and trade compliance personnel should reconcile those records before making scope or participation decisions.

Importers should also review whether purchase contracts allocate responsibility for additional antidumping duties. Reimbursement arrangements can create separate compliance concerns and should be examined with counsel. Brokers, meanwhile, should avoid substituting supplier assurances for importer instructions or documentary evidence.

Duty drawback calculations require another important separation. Antidumping and countervailing duties are not eligible for drawback. Ordinary customs duties paid on the same entries may still qualify when the merchandise is subsequently exported or destroyed, or used to manufacture exported goods, provided the claim otherwise satisfies applicable requirements.

Accordingly, drawback records should not treat the total amount paid at entry as a single recoverable duty figure. AD/CVD cash deposits must be excluded from eligible duty calculations, while ordinary duties should remain separately identifiable. This distinction becomes especially important when high antidumping deposits materially exceed the underlying customs duty.

Frequently Asked Questions

What Is a Five-Year Sunset Review?

A five-year sunset review determines whether an antidumping or countervailing duty order should remain in effect. Commerce generally examines the likelihood of continued or recurring dumping, while the ITC evaluates the likelihood of continued or recurring material injury. If the required findings support continuation, the order typically remains active for another review cycle.

Sunset reviews are not automatic revocation proceedings. An existing order continues during the review, and importers must keep depositing estimated antidumping duties at applicable rates unless official instructions change the treatment of entries.

Are the China Tissue Paper and Magnesium Orders Still Active?

Yes. The initiation of a sunset review does not suspend, reduce, or terminate an order. Importers should continue applying the existing cash deposit and entry requirements to covered merchandise. Any change generally depends on final agency determinations and subsequent customs instructions.

The fact that both orders survived three earlier review cycles may be relevant background, but companies should not assume the fourth reviews will reach the same result. Each proceeding is evaluated on its current administrative record.

Does Vietnamese Origin Keep Tissue Paper Outside the China Order?

Not necessarily. The open circumvention inquiry focuses on tissue paper completed in Vietnam using Chinese jumbo rolls. A Vietnamese country-of-origin claim or shipment route does not, by itself, resolve whether merchandise may be treated as covered by the China antidumping duty order.

Importers should obtain transaction-specific evidence identifying the producer and origin of jumbo rolls. They should also evaluate whether their suppliers can connect raw material records to the finished goods exported to the United States. General origin statements may provide limited protection when the underlying production documentation is unavailable.

Can Importers Claim Drawback on Antidumping Duties?

No. Antidumping and countervailing duties are not eligible for duty drawback. They should be excluded from drawback claim calculations even when paid on an entry that otherwise supports an eligible export or destruction claim.

Ordinary customs duties paid on that same entry may still qualify for drawback if all statutory and operational requirements are met. Importers and brokers should therefore maintain separate duty fields for ordinary customs duties, antidumping deposits, countervailing deposits, taxes, and fees.

What Should Importers Do While the Proceedings Remain Open?

Importers should identify affected entries, preserve supporting documents, confirm supplier and manufacturer relationships, and monitor liquidation status. Tissue paper importers should place particular emphasis on the origin of jumbo rolls used in Vietnam. Magnesium importers should validate product specifications against the applicable scope.

Companies considering participation in the sunset reviews should consult trade counsel promptly. Filing deadlines are strict, and substantive responses generally require more than a basic statement of commercial interest. Importers should also avoid forecasting duty savings or pricing merchandise based on an assumed revocation or negative circumvention finding.

How Stable Software Can Help

Keep Drawback Calculations Separate From AD/CVD Exposure

Stable Software's DrawbackAI gives U.S. customs brokers a flat-license duty drawback software option that they can white-label for importer clients. Brokers file claims under their own filer codes, retain control of the client relationship, and pay a flat software license rather than a percentage of the refund.

That model is relevant when entries contain both ordinary customs duties and ineligible antidumping or countervailing duty amounts. Brokers evaluating drawback opportunities can use a dedicated platform while maintaining the required distinction between recoverable ordinary duties and nonrecoverable AD/CVD payments. Customs brokers seeking to expand importer services without surrendering a share of client refunds can explore DrawbackAI as part of their drawback practice.

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