Common Alloy Aluminum Sheet AD/CVD Partial Revocation: A Guide for Can Stock Importers

A major change to the common alloy aluminum sheet AD/CVD orders creates meaningful duty relief for qualifying beverage can stock. Importers and customs brokers should now identify eligible unliquidated entries, validate product specifications against the revised exclusion, and monitor liquidation activity closely to protect potentially significant deposit refunds.

What the Partial Revocation Covers

The U.S. Department of Commerce has partially revoked the antidumping and countervailing duty orders on common alloy aluminum sheet from China, Bahrain, Brazil, Croatia, Egypt, Germany, India, Indonesia, Italy, Oman, Romania, Serbia, Slovenia, South Africa, Spain, Taiwan, and Türkiye. The partial revocation applies only to certain aluminum can stock; the broader AD/CVD orders remain in effect for merchandise that does not satisfy the exclusion.

The final action became applicable on September 24, 2026, following changed circumstances reviews supported by more than 85 percent of the domestic industry. No opposing comments were submitted. For importers, however, industry support is less operationally important than correctly determining whether a particular shipment falls within the revised written description.

Technical Requirements for the Can Stock Exclusion

Qualifying merchandise must be aluminum can stock suitable for manufacturing beverage cans, lids, or tabs. It must meet all of the following product characteristics:

• Gauge from 0.200 millimeters through 0.292 millimeters
• Temper H-19, H-41, H-48, H-39, or H-391
• Lubricant applied to the flat surfaces to facilitate movement through can-making machinery
• Suitability for aluminum beverage cans, lids, or tabs

The addition of H-39 aligns the exclusion language applicable to the China orders with the revised treatment of can stock from the other covered countries.

Qualifying products are generally classifiable under Harmonized Tariff Schedule of the United States subheadings 7606.12.3045 and 7606.12.3055. Those tariff classifications are informative, but they are not controlling. The written product description is dispositive regardless of the HTSUS number declared at entry. Importers therefore should not assume that classification under either subheading automatically establishes eligibility—or that classification elsewhere necessarily prevents it.

Retroactive Relief and AD/CVD Deposit Refunds

The partial revocation has retroactive effect for qualifying entries that remain unliquidated. This creates a potentially substantial recovery opportunity for importers that deposited antidumping or countervailing duties on covered can stock but have not yet received final liquidation from U.S. Customs and Border Protection.

CBP is expected to receive instructions directing it to liquidate eligible entries without regard to AD/CVD duties and refund the associated estimated deposits. Commerce indicated that it intended to issue those instructions within 15 days of publication, an expedited schedule compared with the waiting period generally used for liquidation instructions.

Relevant Entry Periods

The retroactive starting point depends on the exporting country and type of proceeding:

• China CVD entries: beginning April 23, 2018
• China AD entries: beginning June 22, 2018
• CVD entries from the other covered countries: beginning August 14, 2020
• AD entries from the other covered countries: beginning October 15, 2020

Only entries that remain unliquidated can generally benefit from the partial revocation through routine liquidation instructions. Importers should distinguish entries that are open, suspended, extended, liquidated, or subject to a pending protest. The appropriate recovery path may differ depending on the entry’s procedural status.

A refund review should reconcile entry numbers, countries of origin, manufacturers, exporters, invoice descriptions, gauges, tempers, lubricant specifications, and intended applications. Teams should also compare deposited AD/CVD amounts against ACE data and internal accounting records. This reconciliation can identify missing entries, incorrect case associations, and deposit discrepancies before liquidation occurs.

Importers should not treat AD/CVD deposits as ordinary customs duties for drawback planning. Antidumping and countervailing duties are generally outside the drawback framework. The practical recovery mechanism for qualifying open entries is liquidation without AD/CVD and the resulting refund of estimated deposits, rather than a conventional drawback claim.

Building a Defensible Can Stock Review Process

The commercial description “can stock” is not enough to establish that merchandise qualifies for the exclusion. A defensible determination should connect objective product specifications and intended use to each element of the written description. That requires coordination among trade compliance, procurement, engineering, customs brokerage, finance, and legal teams.

Documentation Importers Should Validate

Relevant supporting records typically include:

• Commercial invoices and purchase orders
• Mill test certificates and certificates of analysis
• Product data sheets showing gauge and temper
• Lubricant specifications or coating records
• Manufacturer certifications
• Customer specifications for cans, lids, or tabs
• Production or end-use documentation
• Entry summaries and AD/CVD case data
• Deposit calculations and payment records

The gauge range deserves particular attention. Product descriptions may use rounded values, nominal dimensions, or measurements expressed in inches rather than millimeters. Compliance teams should confirm actual specifications and retain transparent unit conversions. Similarly, temper codes should be documented rather than inferred from a general product family or customer application.

Lubricant is also a substantive criterion. Importers should preserve evidence that lubricant was applied to the flat surfaces and that it facilitates processing through can-making equipment. A generic statement that sheet is “coated” or “treated” may not establish the required characteristic.

ACE Monitoring and Broker Controls

Importers and brokers should create an entry-level watchlist for potentially eligible shipments. The watchlist should capture liquidation status, suspension status, AD/CVD case numbers, deposit amounts, expected instruction treatment, and refund status. ACE liquidation reports should be reviewed on a recurring schedule rather than only when a refund appears.

Broker instructions should clearly separate qualifying can stock from other common alloy aluminum sheet. Where documentation is incomplete, the entry should be flagged for additional review instead of automatically categorized as excluded. Because the broader orders remain active, overbroad treatment could create duty exposure, interest, penalties, or recordkeeping concerns.

Finance teams should also avoid recognizing expected refunds without accounting for entry status and product eligibility. A structured review provides a more reliable basis for estimating recoveries and investigating delayed or incomplete refunds.

Frequently Asked Questions

Does Every Aluminum Product Used to Make Cans Qualify?

No. The merchandise must satisfy the full written description, including the specified gauge range, an eligible temper, lubricant on the flat surfaces, and suitability for beverage cans, lids, or tabs. A can-related end use alone is generally insufficient.

Are HTSUS Subheadings 7606.12.3045 and 7606.12.3055 Required?

Not necessarily. Qualifying can stock is generally classified under those subheadings, but the written description controls regardless of HTSUS classification. Importers should analyze physical characteristics and supporting records rather than relying exclusively on the tariff number.

Which Entries May Receive AD/CVD Refunds?

Qualifying entries that remain unliquidated and fall within the applicable retroactive periods may be liquidated without AD/CVD duties. Eligibility depends on the merchandise, country, proceeding, entry date, and liquidation status. Already-liquidated entries may require separate procedural analysis.

Does the Partial Revocation End the Aluminum Sheet Orders?

No. It removes only qualifying can stock from the orders. Other common alloy aluminum sheet from the covered countries generally remains subject to the applicable AD/CVD requirements, including case reporting, cash deposits, and suspension of liquidation.

How Should Importers Handle Uncertain Product Records?

They should obtain specification-level evidence from the producer or supplier before claiming exclusion treatment. Mill certificates, lubricant records, engineering specifications, and end-use documentation are generally stronger than broad invoice descriptions. Unresolved entries should be escalated for compliance or legal review.

How Stable Software Can Help

Automating Entry and Refund Oversight

The partial revocation requires importers and customs brokers to connect technical product data with entry status, AD/CVD case information, deposits, and liquidation events. Manual spreadsheets can make that process difficult across multiple countries, suppliers, brokers, and years of open entries.

Stable Software helps trade teams centralize customs data, automate entry monitoring, identify exceptions, and maintain auditable compliance workflows. Importers can use structured data and alerts to track potentially eligible can stock entries, monitor ACE liquidation activity, reconcile expected refunds, and investigate discrepancies before deadlines are missed. The result is stronger refund control without weakening oversight of common alloy aluminum sheet that remains subject to AD/CVD orders.

Resources