Chromium Trioxide AD/CVD Duties: Final Rates

Commerce has finalized chromium trioxide AD/CVD duties affecting imports from India and Türkiye, creating immediate deposit, entry management, and sourcing concerns. The rates are substantial, but antidumping and countervailing duty orders cannot issue unless the U.S. International Trade Commission reaches the required affirmative injury determinations. ## Final Chromium Trioxide Duty Rates The final determinations establish the rates Commerce calculated for the investigated producers and all other exporters. They do not, by themselves, complete the investigations. Importers and customs brokers should nevertheless use the final figures when assessing open-entry exposure, future landed costs, and potential order implementation. ### India Antidumping and Countervailing Duty Rates For the India antidumping investigation, case A-533-944, Commerce calculated a final dumping margin of 14.44 percent for Vishnu Chemicals Limited using adverse facts available. The all-others dumping margin is also 14.44 percent. The corresponding antidumping cash deposit rate is 11.82 percent for Vishnu and all other producers or exporters. This lower deposit rate reflects an adjustment for export subsidies. The period of investigation covered July 1, 2024 through June 30, 2025, and the final antidumping determination did not change the preliminary result. For the India countervailing duty investigation, case C-533-945, Commerce calculated a final subsidy rate of 29.35 percent ad valorem for Vishnu. The all-others rate is likewise 29.35 percent. The countervailing duty period of investigation covered January 1 through December 31, 2024. Importers should not simply add the published India antidumping margin and countervailing duty rate to predict the final combined cash deposit obligation. If the injury phase is affirmative for both investigations, Commerce will apply the required subsidy-related adjustments when establishing the applicable deposit rates. ### Türkiye Antidumping Duty Rate For Türkiye, Commerce calculated a final antidumping margin of 40.88 percent for Türkiye Sise ve Cam Fabrikalari A.S., commonly known as Sisecam. The 40.88 percent rate, based on adverse facts available, also applies to all other producers and exporters under case A-489-856. The investigation covered July 1, 2024 through June 30, 2025. ## Why the ITC Injury Phase Still Matters Final Commerce calculations do not automatically create permanent antidumping or countervailing duty orders. The ITC must separately determine whether the domestic industry is materially injured, threatened with material injury, or materially retarded because of the investigated imports. ### Orders Require Affirmative Injury Determinations If the ITC reaches an affirmative final injury determination, Commerce can issue the corresponding order and establish continuing cash deposit requirements. India is subject to separate antidumping and countervailing duty investigations, while Türkiye is subject to an antidumping investigation. The outcome can therefore differ by country and proceeding. A negative injury determination generally prevents an order from issuing for the affected investigation. Importers should not describe the final Commerce rates as established order rates while the injury phase remains pending. That distinction is important in customer communications, purchase contracts, landed cost forecasts, and financial reporting. No importer should assume a final ITC date or an order publication date until those procedural events occur. Compliance teams should instead monitor each case number and maintain scenarios for affirmative and negative outcomes. ### Suspension of Liquidation Requires Entry-Level Review The India countervailing duty investigation has an additional timing issue. Commerce directed CBP to discontinue suspension of liquidation for relevant entries made on or after September 11, 2026. Entries suspended before that date generally remain governed by the applicable instructions. This creates a period-specific compliance question. Importers and brokers should review entry dates, country of origin, manufacturer and exporter identity, deposit records, and liquidation status rather than applying one treatment across the entire entry population. An entry summary extract should distinguish entries before September 11, entries on or after that date, and future entries potentially affected by an order. ## Immediate Priorities for Importers and Brokers The final determinations warrant coordinated action across customs compliance, procurement, finance, and brokerage teams. Waiting for an eventual order can leave unresolved deposit discrepancies, underfunded liabilities, and inconsistent supplier data. ### Validate Case Numbers and Cash Deposits Brokers should confirm that entries within the investigated scope use the appropriate case numbers: - A-533-944 for chromium trioxide antidumping duties from India

• C-533-945 for chromium trioxide countervailing duties from India
• A-489-856 for chromium trioxide antidumping duties from Türkiye The review should compare the entered manufacturer and exporter against commercial invoices, purchase records, certificates of origin, and available supplier declarations. Product descriptions should also be tested against the investigation scope. Classification alone is generally not sufficient to resolve AD/CVD scope because written product characteristics and scope language control. Cash deposit validation should distinguish the dumping margin from the adjusted deposit rate. For India antidumping entries, the 14.44 percent margin and the 11.82 percent adjusted deposit rate serve different purposes. Using the unadjusted margin as the deposit rate could overstate expected cash requirements, while ignoring the countervailing duty proceeding could materially understate total exposure. ### Update Purchasing and Landed Cost Assumptions Importers should model multiple outcomes for pending purchase orders and contracts. These models should consider the 11.82 percent adjusted India antidumping deposit, the 29.35 percent India countervailing duty rate, and the 40.88 percent Türkiye antidumping rate, subject to the procedural status of each investigation. Procurement teams should review whether contracts allocate new trade remedy costs to the buyer or seller. They should also examine cancellation rights, price adjustment clauses, Incoterms, and origin representations. A supplier's commercial location does not determine origin, and routing goods through a third country generally does not change origin without substantial production that satisfies the applicable origin analysis. Finance teams may need to separate deposited amounts from final duty liability. AD/CVD cash deposits are estimates. Final liability can later change through administrative review, liquidation instructions, scope decisions, or other case developments. ## Duty Drawback and Cost Recovery Limitations The size of these chromium trioxide rates makes duty recovery strategy particularly important. However, antidumping and countervailing duties are specifically excluded from duty drawback, so importers cannot recover those amounts by exporting or destroying qualifying merchandise. ### AD/CVD Is a Non-Drawback Cost An importer that deposits India or Türkiye AD/CVD should generally treat those trade remedy duties as non-recoverable through drawback. The restriction applies even when the imported chromium trioxide is later exported, destroyed under customs supervision, or incorporated into an exported article. This limitation should be built directly into landed cost calculations. Forecasts that assume recovery of the entire customs payment through drawback can substantially overstate the economic benefit of an export program. AD/CVD deposits should be separated from ordinary customs duties, merchandise processing fees, and other amounts when evaluating potential recovery. ### Other Eligible Duties May Still Support Drawback The exclusion of AD/CVD does not necessarily eliminate every drawback opportunity associated with an import transaction. Depending on the facts and drawback provision used, other eligible duties, taxes, and fees may remain recoverable. Eligibility typically depends on the imported merchandise, export activity, inventory records, applicable substitution rules, and statutory timing requirements. Importers should therefore preserve complete entry, inventory, manufacturing, export, and destruction data even when AD/CVD represents the largest component of import cost. A properly segmented drawback analysis can exclude prohibited trade remedy duties while identifying other recoverable amounts. Customs brokers supporting both AD/CVD compliance and drawback should keep the workstreams distinct. Case-specific deposit data is necessary for entry compliance, while drawback calculations require eligible duty amounts and a documented connection between imports and qualifying exports or destruction. ## Frequently Asked Questions ### What Are the Final India Chromium Trioxide Rates? The final India antidumping margin is 14.44 percent for Vishnu Chemicals Limited and all others. The adjusted antidumping cash deposit rate is 11.82 percent. The final India countervailing duty rate is 29.35 percent for Vishnu and all others. ### What Is the Final Türkiye Antidumping Rate? The final Türkiye dumping margin is 40.88 percent for Sisecam and all other producers or exporters. The rate relies on adverse facts available and applies under antidumping case A-489-856. ### Are Chromium Trioxide AD/CVD Orders Already in Effect? Not yet. Commerce has reached final affirmative determinations, but the ITC must make the required affirmative injury determinations before corresponding orders can issue. Importers should continue monitoring each investigation rather than treating the final margins as permanent order rates. ### Can Chromium Trioxide AD/CVD Be Recovered Through Drawback? No. Antidumping and countervailing duties are not eligible for duty drawback. Other qualifying customs duties, taxes, or fees associated with the same transactions may still be recoverable if all applicable drawback requirements are satisfied. ### Why Is the India AD Deposit Rate Lower Than the Dumping Margin? The 11.82 percent India antidumping deposit rate reflects an adjustment for export subsidies, while the calculated dumping margin is 14.44 percent. Importers and brokers should use the rate applicable to the specific deposit instruction rather than assuming the unadjusted margin is the required deposit. ### Should Importers Add the India AD and CVD Rates Together? A simple addition can produce an inaccurate forecast because subsidy-related adjustments may affect the combined deposit treatment. Compliance teams should model the investigations separately and apply the rates and adjustments in effect for the entry date. ## How Stable Software Can Help ### Separate Recoverable Duties From AD/CVD Although chromium trioxide AD/CVD cannot be recovered through drawback, importers may still have eligible duties tied to qualifying exports or destruction. Accurate recovery requires separating prohibited trade remedy duties from potentially recoverable customs amounts and maintaining reliable transaction records. DrawbackAI is flat-license duty drawback software that U.S. customs brokers can white-label for 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 drawback opportunities can use this structure to support importer recovery programs while keeping AD/CVD outside the drawback claim.

Resources