The final CVP-23 CVD rate for Navpad Pigments is 2.81 percent ad valorem, creating immediate classification, deposit, and liquidation control points for U.S. importers. The result also reinforces a critical drawback distinction: countervailing duties are excluded, while eligible ordinary customs duties on the same entries may remain recoverable.
What the Final CVP-23 CVD Rate Changes
The final results cover the countervailing duty administrative review of carbazole violet pigment 23 from India for the period January 1 through December 31, 2023. Navpad Pigments Private Limited received a final net countervailable subsidy rate of 2.81 percent ad valorem.
This rate is lower than the preliminary rate of 3.38 percent. The 0.57 percentage point reduction resulted from a corrected calculation involving India's Emergency Credit Line Guarantee Scheme. For affected importers, the final rate determines the basis Commerce will generally use when directing U.S. Customs and Border Protection to assess countervailing duties on eligible Navpad entries from the review period.
Cash Deposit and Supplier Controls
The final results are scheduled for publication on October 26, 2026. The notice establishes a 2.81 percent cash deposit rate for subject Navpad merchandise entered, or withdrawn from warehouse for consumption, on or after publication, to the extent a deposit remains applicable under the governing order and CBP instructions.
Companies not individually reviewed generally retain their latest company-specific rate or the applicable all-others rate. Importers should therefore avoid applying Navpad's 2.81 percent rate across every Indian supplier of CVP-23. Manufacturer, exporter, country of origin, scope status, entry date, and applicable deposit instructions must be evaluated at the line level.
The underlying CVD order was revoked effective for entries on or after June 15, 2026. That revocation does not erase historical liability for entries covered by the 2023 administrative review. Because the final review notice includes standard prospective deposit language, importers should reconcile that language with the effective date of revocation and current CBP instructions before changing post-revocation deposit practices.
Assessment and Liquidation Risks for 2023 Entries
The most significant financial impact concerns entries made during 2023. Commerce intends to issue assessment instructions to CBP no earlier than 35 days after publication, which would be no earlier than November 30, 2026. Importers should use this interval to validate the population of potentially affected entries and compare estimated deposits with expected final assessments.
A 2.81 percent final rate does not necessarily mean every entry will produce an additional payment. The outcome depends on the countervailing duty deposited at entry, the final entered value, corrections made before liquidation, and the assessment method reflected in CBP's instructions. Some entries may generate additional duty, while others may produce a refund if deposits exceeded the final liability.
Sudarshan Entries Require Separate Treatment
The review was rescinded for Sudarshan Chemical Industries Limited because there were no reviewable entries for which liquidation remained suspended. Its relevant entries are generally assessed at the cash deposit rate required when the merchandise entered. Sudarshan transactions should not be included in a Navpad-specific recalculation simply because both companies supplied merchandise potentially covered by the same order.
Importers should create separate entry populations for Navpad, Sudarshan, and any other suppliers. Each population should capture entry number, line number, entry date, manufacturer, exporter, entered value, ordinary duty, CVD deposit, liquidation status, and protest deadline where applicable.
Scope review is equally important. Commercial descriptions such as violet pigment, pigment preparation, ink colorant, or plastics additive do not by themselves establish coverage. Importers should compare product specifications, physical form, chemical identity, country of origin, and any relevant scope determinations before treating merchandise as subject CVP-23. Classification and trade remedy scope are related compliance functions, but one does not automatically resolve the other.
Duty Drawback Treatment for CVP-23 Imports
Countervailing duties assessed on CVP-23 are not eligible for duty drawback under 19 U.S.C. 1677h. The same exclusion generally applies to antidumping duties. Importers and customs brokers should therefore prevent CVD amounts from entering the recoverable duty pool used to calculate drawback claims.
That exclusion does not necessarily eliminate all drawback opportunity associated with an entry. Ordinary customs duties paid on the same imported merchandise may remain eligible when the goods are subsequently exported or destroyed, or when they are used in manufacturing exported articles, provided the claim satisfies the applicable drawback requirements.
Separate Ordinary Duty From Trade Remedy Duty
The strongest control is to preserve each duty component separately at the entry-line level. A drawback data set should distinguish ordinary customs duty, merchandise processing fee, harbor maintenance fee where relevant, antidumping duty, countervailing duty, and any other special assessment. Only legally eligible amounts should flow into the potential refund calculation.
Importers should also retain the commercial and operational records needed to connect imports with exports or destruction. Depending on the drawback provision, these records may include entry data, purchase records, inventory movements, bills of material, manufacturing records, export documentation, destruction evidence, and certificates of delivery or manufacture.
Liquidation changes can affect the amount available for drawback. If the ordinary duty amount changes through reconciliation, correction, reliquidation, protest, or another post-entry process, the drawback calculation may also require adjustment. Conversely, a refund of excess CVD deposits should not be treated as an increase or decrease in drawback-eligible ordinary duty.
For customs brokers administering drawback programs, automated exclusions should be paired with exception reporting. A claim should be reviewed when source data combines ordinary duty and CVD, lacks line-level duty detail, or cannot reliably identify the imported merchandise. This separation protects claim accuracy while preserving legitimate recovery opportunities.
- Commerce published the final CVD administrative review results for carbazole violet pigment 23 from India (C-533-839) covering January 1 to December 31, 2023, in the Federal Register on October 26, 2026 (public inspection October 23).* Navpad Pigments Private Limited received a final net countervailable subsidy rate of 2.81 percent ad valorem.
- The rate was lowered from the June 23, 2026, preliminary determination of 3.38 percent after Commerce corrected a calculation error in the Emergency Credit Line Guarantee (ECLG) Scheme based on one comment received.* The review was rescinded in part for Sudarshan Chemical Industries Limited, which had no reviewable suspended entries; its entries will be assessed at the cash deposit rate in effect at the time of entry.
- Cash deposit requirements of 2.81 percent ad valorem apply to Navpad for subject merchandise entered or withdrawn from warehouse for consumption on or after October 26, 2026.* Non-reviewed companies retain their most recent company-specific or all-others rate. Commerce intends to issue assessment instructions to CBP no earlier than 35 days after publication.
- No significant industry news, additional regulatory updates, or practitioner discussions on X were identified in the past 30 days regarding this specific determination. The CVD order itself was separately revoked in August 2026 (effective for entries on or after June 15, 2026) due to lack of domestic industry participation in the sunset review, but this administrative review applies to the historical 2023 period.
Frequently Asked Questions
What is the final CVP-23 CVD rate for Navpad Pigments?
The final net countervailable subsidy rate is 2.81 percent ad valorem for Navpad Pigments Private Limited. It applies to the 2023 review period for assessment purposes and appears in the final results scheduled for publication on October 26, 2026.
Why did the rate change from the preliminary results?
The preliminary rate was 3.38 percent. The final rate decreased after a calculation error involving the Emergency Credit Line Guarantee Scheme was corrected. Importers should use the final rate when estimating assessment exposure for covered Navpad entries.
What happens to Sudarshan Chemical entries?
The review was rescinded for Sudarshan because there were no reviewable entries with suspended liquidation. Relevant entries are generally assessed using the cash deposit rate required at the time of entry, rather than Navpad's final 2.81 percent rate.
Can an importer claim drawback on the CVD paid?
No. Countervailing duties are not eligible for drawback. However, ordinary customs duties paid on the same entry may still qualify if the merchandise is exported, destroyed, or used in qualifying manufacturing and all other drawback requirements are met.
Does revocation of the order eliminate 2023 liability?
No. Revocation effective for entries on or after June 15, 2026 does not generally cancel historical assessments for the 2023 review period. Importers should continue monitoring liquidation and assessment instructions for their covered 2023 entries.
When could assessment instructions be issued?
Commerce intends to issue assessment instructions no earlier than 35 days after publication. Based on the scheduled October 26, 2026 publication date, instructions would generally not be issued before November 30, 2026.
How Stable Software Can Help
Keep Eligible Duty Separate and Traceable
Stable Software's DrawbackAI helps U.S. customs brokers administer duty drawback programs for importer clients under the broker's own filer code. Brokers can white-label the software while maintaining control over filing relationships and client service.
For entries involving ordinary customs duty and non-drawback-eligible CVD, disciplined duty separation is essential to accurate claim calculations. DrawbackAI is offered through a flat software license, and Stable Software never takes a percentage of the client's refund. Customs brokers evaluating how to scale drawback services can explore the platform and determine whether it fits their compliance and operational model.
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