Commerce’s AD/CVD administrative review rescission across 22 proceedings creates an immediate liquidation and recordkeeping issue for importers and customs brokers. With assessment expected at entry-date cash deposit rates, affected parties should identify suspended entries, complete required reimbursement certifications, and separate AD/CVD from potentially eligible ordinary customs duties.
Scope of the 22 Rescinded Administrative Reviews
Commerce rescinded 13 antidumping duty administrative reviews and nine countervailing duty administrative reviews after all review requests were withdrawn within 90 days of initiation. Rescission under 19 CFR 351.213(d)(1) generally ends the administrative review without calculating new company-specific assessment rates for the covered period.
That distinction is critical. A rescinded review does not ordinarily revoke the underlying AD or CVD order. It also does not eliminate cash deposit requirements on future entries. Instead, the action determines how suspended entries from the applicable period of review will generally move toward liquidation.
Antidumping Duty Proceedings
The 13 rescinded AD reviews cover a broad mix of manufactured goods, consumer products, chemicals, and food ingredients. They include common alloy aluminum sheet from Croatia, Serbia, and Slovenia, as well as cut-to-length plate from France.
Mattress proceedings are affected for Malaysia, Turkiye, Vietnam, and Thailand. The remaining AD reviews involve brass rod from Mexico, dioctyl terephthalate from Turkiye, paper plates from Vietnam, prestressed concrete steel wire strand from Thailand, and vanillin from China.
Importers should not rely solely on general product descriptions when identifying exposure. Entry-level analysis should typically consider the case number, country of origin, producer, exporter, entry date, entered merchandise description, and period of review.
Countervailing Duty Proceedings
The nine rescinded CVD reviews include carbazole violet pigment 23, non-refillable steel cylinders, and high chrome cast iron grinding media from India. They also include phosphate fertilizers from Morocco and Russia, paper plates from Vietnam, and chassis and subassemblies, mattresses, and stainless steel flanges from China.
Several products are subject to overlapping trade remedy activity. Compliance teams should therefore distinguish administrative review rescission from sunset review determinations, scope proceedings, changed circumstances reviews, and separate reviews involving another country or duty type.
Liquidation and Cash Deposit Rate Consequences
When an administrative review is fully rescinded, CBP will generally assess duties on covered entries at the cash deposit rate required at the time of entry. That outcome can produce different assessment amounts across entries involving the same product because applicable deposit rates may depend on entry date, exporter, producer, and case-specific instructions.
The deposit amount recorded in an importer’s financial system is not always enough to establish the final liability. Brokers and importers should reconcile the entry summary, payment records, case number, exporter and producer combination, and applicable rate before treating the expected liquidation amount as final.
Expected Assessment Instructions
Commerce intends to issue assessment instructions no earlier than 35 days after the October 28, 2026 publication date. December 2, 2026 is therefore the earliest expected instruction date for most of the affected proceedings.
For orders involving Canada or Mexico, instructions generally will not be issued earlier than 41 days after publication. That timing applies to the brass rod review involving Mexico, making December 8, 2026 the earliest expected instruction date for that proceeding.
These dates concern the earliest issuance of assessment instructions, not necessarily the date each entry will liquidate. CBP processing, injunctions, corrections, protests, or case-specific circumstances can affect the actual liquidation timeline.
Why Entry-Level Reconciliation Matters
Importers should build a population of potentially affected entries before liquidation begins. Useful fields generally include the entry number, line number, entry date, importer of record, manufacturer identification code, producer, exporter, case number, deposit rate, deposited amount, and liquidation status.
The importer should then compare customs records against broker data and internal accounts payable records. Discrepancies involving supplier identity, case applicability, origin, or deposit rate should be escalated promptly. Waiting for a liquidation notice can leave too little time to investigate errors and determine whether a protest or other corrective action may be appropriate.
Brokers should also avoid assuming that every entry associated with a named product falls within the rescinded review. Scope coverage, producer and exporter identity, and period-of-review dates remain essential to an accurate entry population.
Importer Compliance and Drawback Priorities
The rescissions create three immediate priorities for affected importers. They should identify suspended entries, prepare for liquidation at the applicable deposit rates, and confirm that required antidumping duty reimbursement certificates are filed before liquidation.
Trade compliance teams should assign responsibility for each task and preserve evidence of completion. Centralized tracking is especially important for importers that use multiple brokers, import through several ports, or have undergone supplier changes during a period of review.
File Reimbursement Certificates Before Liquidation
For entries subject to antidumping duties, importers generally must file the reimbursement certificate required by 19 CFR 351.402(f)(2) before liquidation. The certificate addresses whether the foreign producer, exporter, or another party reimbursed the importer for antidumping duties.
Failure to file can create a presumption that reimbursement occurred. That presumption may result in the assessment of doubled antidumping duties. The financial exposure makes certificate management more than a routine documentation exercise.
Importers should confirm that certificates cover the correct entries and periods. They should also retain supporting communications, contractual provisions, payment records, and broker filing evidence. CVD entries require their own case-specific review, but the antidumping reimbursement certificate requirement should not be incorrectly applied as a generic certificate for every customs duty.
Keep AD/CVD Separate From Drawback-Eligible Duty
Antidumping and countervailing duties are not eligible for duty drawback under 19 U.S.C. 1677h. Exporting or destroying merchandise does not convert those trade remedy duties into refundable duties.
Ordinary customs duties paid on the same entries may still qualify for drawback when the merchandise is exported or destroyed, or when imported merchandise is used to manufacture exported articles, provided the claim satisfies the applicable requirements. Importers and drawback filers should therefore maintain separate accounting for ordinary customs duty, AD, CVD, merchandise processing fees, and any other assessments.
This separation should extend into broker reports, enterprise resource planning data, drawback calculations, and supporting workpapers. A claim methodology that treats the total duty paid on an AD/CVD entry as eligible can overstate the refund and create avoidable compliance risk.
The rescission also reinforces the value of linking import entries to downstream exports or destruction records before liquidation data becomes fragmented. Although liquidation affects the final treatment of the entry, drawback teams still need complete import, inventory, manufacturing, and export records to calculate eligible ordinary duty accurately.
- Commerce published the batch rescission notice on October 28, 2026 (public inspection October 27), covering 13 AD and 9 CVD administrative reviews after all requests were withdrawn within 90 days of initiation.* Affected AD cases include common alloy aluminum sheet from Croatia, Serbia, and Slovenia; mattresses from Malaysia, Turkiye, Vietnam, and Thailand; brass rod from Mexico; and others such as vanillin from China. CVD cases include phosphate fertilizers from Morocco and Russia, mattresses and stainless steel flanges from China, and several from India. CBP will liquidate entries at the cash deposit rates in effect at the time of entry.
- On October 26, 2026, Commerce separately rescinded the full 2025 CVD administrative review of common alloy aluminum sheet from China (C-570-074) because remaining companies had no reviewable suspended entries after other requests were withdrawn.* Cash deposit rates remain unchanged.
- The ITC completed expedited five-year sunset reviews on October 22, 2026, determining that revocation of the CVD order on mattresses from China and AD orders from Cambodia, Malaysia, Serbia, Thailand, Turkey, and Vietnam would likely lead to continuation or recurrence of material injury.* The orders remain in place.
- ITC scheduled full (not expedited) five-year sunset reviews of the CVD orders on phosphate fertilizers from Morocco and Russia, with a notice around October 9, 2026, and proceedings extending into spring 2027 due to complexity.* Commerce had already issued preliminary sunset findings pointing toward continuation.
- Practitioner coverage in trade publications (such as STR reports around October 27, 2026) noted overlapping earlier rescissions involving mattresses from China, prestressed concrete steel wire strand from Thailand, paper plates, and related aluminum sheet cases, with instructions to CBP for assessment at cash deposit rates.* Recent X posts on similar AD/CVD rescissions were limited and mostly automated or focused on unrelated PORs (such as shrimp or pigment reviews).
Frequently Asked Questions
Does Rescission Cancel the Underlying AD/CVD Order?
No. Rescission of an administrative review generally ends that specific review for the relevant period. It does not, by itself, revoke the underlying antidumping or countervailing duty order. Cash deposit requirements may continue for future entries, and other proceedings involving the same merchandise can remain active.
At What Rate Will CBP Assess Duties?
CBP will generally assess covered entries at the cash deposit rate required at the time of entry. Because rates can vary by exporter, producer, and entry date, importers should validate the rate at the individual entry-line level rather than applying one rate across an entire product category.
When Will the Affected Entries Liquidate?
Assessment instructions are expected no earlier than December 2, 2026 for most proceedings and no earlier than December 8, 2026 for the brass rod proceeding involving Mexico. Actual liquidation can occur later depending on CBP processing and case-specific circumstances. Importers should monitor entry status rather than treating the earliest instruction date as a guaranteed liquidation date.
Who Must File an Antidumping Reimbursement Certificate?
Importers with entries subject to antidumping duties generally must provide the required certification before liquidation. Customs brokers may assist with submission, but the importer should maintain oversight and supporting records. Failure to comply can lead to a presumption of reimbursement and potentially doubled antidumping duty assessments.
Can AD/CVD Payments Be Included in a Drawback Claim?
No. Antidumping and countervailing duties are not eligible for drawback. Ordinary customs duties paid on the same entry may remain eligible if the associated exports, destruction, or manufacturing activity satisfies the applicable drawback requirements. Claim calculations should clearly exclude all AD/CVD amounts.
How Stable Software Can Help
Support Accurate Drawback Calculations
The rescission of administrative reviews highlights why customs brokers and importers need clear separation between non-drawback AD/CVD and potentially refundable ordinary customs duty. Stable Software’s DrawbackAI helps U.S. customs brokers provide white-labeled duty drawback software to importer clients while filing claims under the broker’s own filer code.
Stable Software charges a flat software license and never takes a percentage of the importer’s refund. Brokers evaluating drawback opportunities connected to entries carrying AD/CVD can use a software-led process while retaining control of the client relationship and filing activity. Importers and brokers should still confirm eligibility, supporting records, and exclusion of all antidumping and countervailing duty amounts before submitting a claim.
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