India Oleoresin Paprika AD and CVD Orders

Importers of Indian colorants now face a new layer of landed-cost and entry compliance risk. The oleoresin paprika antidumping duty and countervailing duty orders require careful scope analysis, company matching, cash deposit updates, and review of entries made during multiple provisional-measure periods. ## Scope and Effective Date of the New Orders The antidumping duty order A-533-938 and countervailing duty order C-533-939 took effect on October 8, 2026. The orders followed an affirmative material injury determination covering oleoresin paprika from India, allowing suspension of liquidation and cash deposit requirements to resume as of the publication date. ### Products Covered by the Scope The scope generally covers oleoresin paprika produced from Capsicum peppers and used as a coloring additive when the merchandise has either: - An American Spice Trade Association, or ASTA, color value of at least 500

• A color unit, or CU, value of at least 20,000 Importers should not rely solely on commercial descriptions such as paprika extract, natural color, food colorant, or spice oleoresin. Product specifications, laboratory data, concentration levels, manufacturing records, and intended use may all be relevant when evaluating whether merchandise falls within the written scope. The principal Harmonized Tariff Schedule classifications are 3203.00.8000 and 3301.90.1010. Merchandise may also enter under 1301.90.9190, 1302.19.9140, or 3205.00.0500. These tariff classifications are useful screening tools, but they do not replace the controlling product description. A product entered under another tariff number may still be subject if its physical characteristics satisfy the scope. ### Businesses Most Likely to Be Affected The orders directly affect importers, distributors, customs brokers, food manufacturers, and colorant manufacturers sourcing qualifying oleoresin paprika from India. Brokers should confirm that their admissibility and entry workflows identify both case numbers, while importers should review purchase contracts to determine which party bears unexpected AD and CVD costs. Because antidumping and countervailing duties are assessed separately, merchandise within scope may require both case numbers on the same entry. The existence of a zero AD cash deposit rate does not remove the need to report the antidumping case when the product is otherwise subject to the order. ## Company-Specific AD and CVD Cash Deposit Rates The financial effect of the orders depends heavily on the producer and exporter combination. Importers must establish the actual supply chain rather than selecting a rate based only on the seller named on the invoice. ### Antidumping Duty Rates The final dumping margins and adjusted AD cash deposit rates are: - Synthite Industries Pvt. Ltd.: 5.78 percent dumping margin and 0.00 percent cash deposit rate
• Mane Kancor Ingredients Private Ltd.: 4.24 percent dumping margin and 0.00 percent cash deposit rate
• All others: 5.08 percent dumping margin and 0.00 percent cash deposit rate The 0.00 percent AD cash deposit rates reflect adjustments for export-subsidy offsets. They should not be interpreted as an exclusion from A-533-938 or as assurance that final AD liability will remain zero. Cash deposits are estimates, while final liability is generally determined through the administrative review and liquidation process. Importers should continue to transmit the AD case number when required, even when the applicable deposit calculation produces no payment. Failure to declare the case may create entry corrections, liquidation problems, or compliance exposure. ### Countervailing Duty Rates The CVD cash deposit rates under C-533-939 are: - Mane Kancor Ingredients Private Limited: 18.67 percent
• Synthite Industries Pvt. Ltd.: 25.42 percent
• All others: 21.90 percent These CVD rates create the immediate landed-cost impact. Importers should verify manufacturer identity through purchase orders, invoices, packing lists, certificates of analysis, production records, and supplier declarations. Minor differences in company names should be investigated rather than resolved through assumption. A trading company or reseller does not necessarily qualify an entry for the rate assigned to the underlying manufacturer. The applicable rate generally depends on the producer-exporter facts and the instructions governing the order. When documentation cannot support a company-specific rate, the all-others rate may apply. ## Provisional Gaps, Critical Circumstances, and Entry Controls The orders involve different provisional-measure timelines for AD and CVD. Treating every 2026 entry the same would produce inaccurate duty accruals and potentially incorrect entry corrections. ### Antidumping Provisional-Measure Gap The six-month AD provisional period began with the preliminary less-than-fair-value determination on April 2, 2026, and ended on September 28, 2026. Qualifying entries made from September 29 through October 7, 2026, fall within the AD provisional gap. Entries during that gap generally liquidate without antidumping duties. Suspension of liquidation and AD cash deposit requirements resumed for subject entries made on or after October 8, 2026. Importers should distinguish the entry date from the purchase date, export date, arrival date, or invoice date when applying this timeline. ### Countervailing Duty Provisional-Measure Gap The four-month CVD provisional period ended on June 5, 2026. Entries made from June 6 through October 7, 2026, generally fall within the CVD provisional gap and liquidate without countervailing duties. CVD suspension and deposit requirements resumed on October 8, 2026. The longer CVD gap means a single shipment history may contain entries with significantly different treatment. Internal accruals should therefore be based on entry-level data rather than monthly purchasing totals. ### Synthite Critical-Circumstances Treatment Commerce initially found critical circumstances for Synthite in the CVD proceeding, but the final injury determination found that critical circumstances did not exist. As a result, qualifying Synthite entries covered by the retroactive critical-circumstances treatment should have suspension lifted and associated CVD deposits refunded. Importers should identify potentially affected entries, compare deposits against entry dates, and monitor liquidation status. Refund eligibility should be supported by the producer identity and entry record rather than inferred from the vendor name alone. ### Immediate Compliance Priorities Importers and brokers should: 1. Update AD and CVD case tables for entries on or after October 8, 2026.

2. Confirm the manufacturer, exporter, country of origin, ASTA value, and CU value.
3. Separate preliminary-period, gap-period, and post-order entries.
4. Review Synthite entries for critical-circumstances refunds.
5. Validate duty accruals against the correct company-specific CVD rate.
6. Preserve scope documentation and product specifications for audit support. This review is an internal entry reconciliation exercise and should not automatically be confused with the separate CBP reconciliation program. ## Frequently Asked Questions ### What Merchandise Is Subject to the Oleoresin Paprika Orders? The orders generally cover oleoresin paprika from India made from Capsicum peppers with an ASTA value of at least 500 or a CU value of at least 20,000. The written product description controls, so classification under an unlisted HTSUS number does not necessarily place merchandise outside the scope. ### Are Antidumping Duties Currently Payable? The listed AD cash deposit rates are currently 0.00 percent after export-subsidy offsets. Subject entries may still need to be declared under A-533-938, and final liability can differ from the deposit rate. A zero deposit is not the same as an exclusion from the order. ### Which Duties Create the Largest Immediate Cost? The CVD rates create the principal immediate deposit obligation. The rates are 18.67 percent for Mane Kancor, 25.42 percent for Synthite, and 21.90 percent for all others. The correct result depends on documented producer and exporter information. ### Do AD and CVD Apply During the Provisional Gaps? Generally, no. The AD gap covers September 29 through October 7, 2026. The CVD gap covers June 6 through October 7, 2026. Entries outside these periods require separate analysis based on the applicable preliminary or final measures. ### Can AD or CVD Be Recovered Through Duty Drawback? No. Antidumping and countervailing duties are not eligible for duty drawback under 19 U.S.C. 1677h. Importers may still have drawback opportunities for eligible ordinary customs duties, taxes, and fees associated with qualifying import and export activity, but AD and CVD amounts must be excluded. ### What Records Should Importers Retain? Importers should retain technical specifications, certificates of analysis, ASTA and CU test results, purchase orders, commercial invoices, manufacturer declarations, entry summaries, deposit calculations, and communications establishing the producer-exporter chain. These records support scope, rate, and refund decisions. ## How Stable Software Can Help ### Separate Eligible Drawback From AD and CVD The new oleoresin paprika orders reinforce the importance of separating recoverable ordinary customs duties from antidumping and countervailing duties that are legally ineligible for drawback. Customs brokers need consistent controls when evaluating importer data, identifying eligible duty, and excluding AD and CVD amounts from claims. Stable Software makes DrawbackAI for customs brokers, flat-license duty drawback software that U.S. customs brokers can white-label for importer clients and use to file under their own filer codes. Stable Software charges a flat software license and never takes a percentage of the refund. Brokers evaluating drawback opportunities for affected importers can use this model while preserving the required separation between eligible customs duties and nonrefundable AD and CVD assessments.

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