DOTP Antidumping Orders: Corrected Gap Dates

The corrected DOTP antidumping duties timeline changes which 2025 entries fall outside suspension of liquidation. Importers and customs brokers should isolate entries made from May 4 through May 14, confirm liquidation treatment, and separate ordinary customs duty from antidumping amounts before pursuing refunds or duty drawback.

The Corrected DOTP Liquidation Gap

Provisional measures ended on May 3, 2025

The antidumping duty orders covering dioctyl terephthalate, commonly called DOTP, from Malaysia, Poland, Taiwan, and Türkiye initially identified the wrong ending date for provisional measures. The corrected timeline establishes that the six-month provisional measures period ended on May 3, 2025, not May 4.

That one-day adjustment moves the beginning of the liquidation gap from May 5 to May 4, 2025. The corrected gap therefore covers entries made from May 4 through May 14, 2025. Suspension of liquidation and antidumping cash deposit requirements resumed on May 15, 2025, when the final injury determinations were published.

The relevant timeline is:

• November 5, 2024: Preliminary determinations were published, beginning the provisional measures period.
• May 3, 2025: The extended six-month provisional measures period ended.
• May 4-14, 2025: Entries fall within the corrected liquidation gap.
• May 15, 2025: Suspension of liquidation and cash deposit requirements resumed.

Why the additional day matters

Entries during the May 4-14 gap generally liquidate without regard to antidumping duties. As a result, a DOTP entry made on May 4 must be treated differently from an entry made on May 3 or May 15, even when the supplier, product, tariff classification, and commercial terms are identical.

This distinction can affect deposited amounts, liquidation instructions, entry audit findings, and potential refund opportunities. Importers should not assume that a customs system or historical entry report reflects the corrected date automatically. Brokers and compliance teams should identify May 4 entries directly, examine whether antidumping cash deposits were collected, and determine the entry's current liquidation status before selecting a corrective procedure.

Rates, Scope, and Product Classification

Cash deposit rates remain company-specific

The date correction does not change the antidumping cash deposit rates stated in the original DOTP orders. The rates applicable when suspension resumed were:

• Malaysia: UPC Chemicals (Malaysia) Sdn Bhd, 7.50 percent. All others, 7.50 percent.
• Poland: Grupa Azoty Zaklady Azotowy, 57.88 percent. All others, 57.88 percent.
• Taiwan: Nan Ya Plastics Corporation, 18.73 percent. Oxyde Chemicals Singapore Pte. Ltd., 32.94 percent. Fortune Chemical Corp., Ltd., 32.94 percent. All others, 18.73 percent.
• Türkiye: By Petrokimya Sanayi Ve Ticaret A.S., 80.71 percent. All others, 61.61 percent.

These rates should not be treated as permanently current. Later administrative reviews, new shipper reviews, scope proceedings, court decisions, or other completed segments may change the rate applicable to a particular producer-exporter combination. Entry reviews should therefore compare the entry date and parties to the most recent completed segment applicable at that time.

Importer and broker teams should also verify whether the commercial invoice identifies the producer, exporter, and seller clearly enough to support the claimed rate. Using an exporter-specific rate without confirming the producer-exporter relationship can create substantial exposure, particularly where the all-others rate differs materially.

The written scope controls coverage

DOTP is currently classified under HTSUS 2917.39.2000 and may also enter under HTSUS 2917.39.7000 or 3812.20.1000. These tariff numbers are useful screening tools, but they do not conclusively determine whether merchandise is covered by an antidumping order. The written scope is dispositive.

This matters for plasticizer users, PVC compounders, flooring manufacturers, and wire and cable manufacturers because product descriptions, blends, formulations, and declared tariff classifications may vary. A reliable review should compare the merchandise's technical characteristics and supporting product documentation against the written scope. Purchase orders, technical data sheets, safety data sheets, bills of materials, certificates of analysis, and supplier declarations may all assist that analysis.

Entry Review and Drawback Implications

Importers should isolate entries by actual entry date

The immediate compliance priority is to pull every potentially covered DOTP entry dated May 4, 2025. A broader review should include the entire May 4-14 gap to confirm that entries were handled consistently and without antidumping duties. Useful data fields generally include entry number, entry date, country of origin, manufacturer, exporter, tariff classification, entered value, antidumping case number, cash deposit rate, deposit amount, and liquidation status.

Each identified entry should be tested against three questions:

1. Does the merchandise fall within the written scope of a DOTP order?
2. Was the entry made during the corrected May 4-14 liquidation gap?
3. Were antidumping cash deposits collected, refunded, or retained despite the corrected timeline?

The appropriate next step will depend on whether the entry remains unliquidated, has liquidated, or is subject to another administrative action. Importers should coordinate with their customs broker and trade counsel as appropriate because procedural options and deadlines can differ based on entry status. The correction itself does not eliminate the need to monitor liquidation activity or preserve available rights.

Antidumping duties must remain separate from drawback

Antidumping and countervailing duties are not eligible for duty drawback under 19 U.S.C. 1677h. Ordinary customs duties paid on the same entries may still qualify when the merchandise is exported or destroyed, or when it is used to manufacture exported goods, provided the claim otherwise satisfies applicable drawback requirements.

This distinction should be built into entry data, accounting records, and claim calculations. A drawback program should not treat total duty paid as a single recoverable amount when an entry includes both ordinary customs duty and AD/CVD deposits or assessments.

For entries within the corrected gap, the absence of antidumping liability does not automatically establish drawback eligibility. It simply removes antidumping duties from the liquidation treatment for that period. Any ordinary customs duties must still be evaluated under the applicable drawback provision, including requirements involving import records, export or destruction evidence, merchandise matching, manufacturing records where relevant, and statutory time limits.

Customs brokers managing both AD/CVD activity and drawback claims should maintain clear data separation. Doing so reduces the risk of overstating potential drawback, improves reconciliation with liquidation records, and gives importer clients a more accurate view of recoverable ordinary duties.

Frequently Asked Questions

What is the corrected DOTP liquidation gap?

The corrected gap runs from May 4 through May 14, 2025. Covered DOTP entries from Malaysia, Poland, Taiwan, and Türkiye made during that period generally liquidate without regard to antidumping duties. Suspension of liquidation and cash deposit requirements resumed on May 15, 2025.

Does the correction change DOTP cash deposit rates?

No. The correction changes the provisional measures dates, not the rates stated in the antidumping orders. However, later completed administrative reviews or other proceedings may have changed company-specific rates. Importers should verify the rate applicable to the relevant producer, exporter, and entry date.

Are HTSUS numbers enough to determine scope coverage?

No. HTSUS classifications help identify potentially affected entries, but the written scope controls. Merchandise entered under HTSUS 2917.39.2000, 2917.39.7000, or 3812.20.1000 may warrant review, although classification under one of those provisions does not by itself establish coverage.

Can antidumping duties be recovered through duty drawback?

No. Antidumping and countervailing duties are not eligible for drawback. Ordinary customs duties paid on the same import entry may still qualify if the merchandise is exported, destroyed, or used in qualifying manufacturing activity and all other drawback requirements are met.

What should an importer do about a May 4 entry?

The importer should confirm scope coverage, review whether antidumping cash deposits were collected, determine the entry's liquidation status, and consult its customs broker about the appropriate action. Any available procedure will typically depend on whether the entry remains unliquidated or has already liquidated.

How Stable Software Can Help

Keep eligible duty separate from AD/CVD amounts

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. This model can support brokers that need to manage ordinary customs duty recovery without treating ineligible antidumping or countervailing duties as drawback-eligible amounts.

Stable Software charges a flat software license and never takes a percentage of the importer's refund. Brokers reviewing DOTP entries and other AD/CVD-sensitive transactions can explore DrawbackAI as part of a controlled, broker-led drawback program.

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