The India PET film AD and CVD review preliminary results create distinct exposure paths for SRF Limited and other Indian producers. Importers and customs brokers must separate estimated assessment liability, current cash deposits, liquidation planning, and drawback treatment rather than treating the announced rates as an immediate deposit change.
Preliminary AD and CVD Results for SRF Limited
Antidumping Review Produces a 0.61% Preliminary Margin
The antidumping duty administrative review covers polyethylene terephthalate film, sheet, and strip from India entered during the July 1, 2024 through June 30, 2025 period of review. Commerce calculated a preliminary dumping margin of 0.61% for SRF Limited under case A-533-824.
That margin is above the generally applicable 0.50% de minimis threshold. If retained in the final results, it could support assessment of antidumping duties on covered SRF entries based on the final methodology and importer-specific calculations. The preliminary result does not, however, immediately replace the cash deposit rate currently applied to new entries.
Polyplex Corporation Ltd. and SRF were initially selected as mandatory respondents. Following timely review withdrawals, the antidumping review was rescinded for Cosmo, Chiripal, Ester, Garware, Vacmet, and Polyplex Corporation. SRF is therefore the only company remaining subject to the review. The antidumping all-others rate remains 5.71%, although the rate applicable to a particular entry depends on the producer, exporter, entry documentation, and deposit instructions in effect.
Countervailing Review Produces a 3.98% Preliminary Rate
The countervailing duty review covers calendar year 2024 under case C-533-825. Commerce assigned SRF a preliminary net countervailable subsidy rate of 3.98% ad valorem, relying in part on adverse facts available.
The CVD review was rescinded for Chiripal Poly Films Limited, Cosmo First Ltd., Ester Industries Limited, Garware Hi-Tech Films Limited, Garware Polyester Ltd., Jindal Poly Films Ltd., JPFL Films Private Limited, Polyplex Corporation Ltd., and Vacmet India Ltd. As with the AD review, SRF remains the only reviewed company.
Cash Deposits, Assessments, and Liquidation Exposure
Preliminary Rates Do Not Immediately Change Deposits
The 0.61% AD margin and 3.98% CVD rate are preliminary results, not new cash deposit instructions. Importers should continue depositing duties at the rates currently required by U.S. Customs and Border Protection until final results are published and corresponding instructions take effect.
This distinction is critical for accrual accounting. Cash deposits are security paid at entry, while the final assessment liability is determined through the administrative review process. A preliminary rate can support an exposure estimate, but it should not be posted automatically as a new entry deposit rate or treated as a finalized payable.
For directional modeling, the two preliminary SRF rates total 4.59 percentage points when applied to the same entered value. That simple addition can provide an initial scenario, but it is not a substitute for entry-level analysis. Trade teams should account for the relevant period of review, existing deposits, scope status, importer-specific assessment calculations, value adjustments, and any difference between AD and CVD treatment.
Rescinded Companies Follow a Different Path
Entries associated with companies for which a review was rescinded are generally expected to be assessed at the cash deposit rate in effect at the time of entry. Assessment instructions are expected no earlier than 35 days after publication of the respective preliminary rescission information.
Importers should verify that each entry identifies the correct producer and exporter combination. Similar company names, historic corporate names, related entities, and invoicing through trading companies can complicate rate assignment. The merchandise manufacturer alone may not always determine the applicable deposit or assessment rate.
Liquidation monitoring is particularly important because rescission removes those companies from the substantive rate calculation. Brokers and importers should retain entry summaries, commercial invoices, manufacturer affidavits where appropriate, deposit records, and scope documentation. Antidumping reimbursement certificates should also be filed before liquidation when required. Failure to address reimbursement certification can create additional antidumping duty consequences even when the underlying rate is otherwise understood.
Compliance Deadlines and Importer Action Plan
Briefing and Final Results Timeline
For the antidumping review carrying an October 19, 2026 publication date, case briefs are due within 21 days, currently calculated as November 9, 2026. Hearing requests are due within 30 days, currently calculated as November 18, 2026. Final results are generally intended within 120 days unless extended, placing the anticipated date around February 16, 2027.
For the countervailing duty results published October 14, 2026, case briefs are due within 21 days, currently calculated as November 4, 2026. Hearing requests are due within 30 days, currently calculated as November 13, 2026. Final results are generally intended within 120 days unless extended, producing an anticipated date around February 11, 2027.
Parties should confirm procedural deadlines through the applicable case record, particularly if deadline extensions, corrected filings, or closure-related tolling affect the schedule. Both proceedings incorporated tolling associated with the 2025 government shutdown and subsequent extensions.
Recommended Controls for Importers and Brokers
Importers of SRF PET film should build entry-level models comparing deposits paid with potential liability under the preliminary AD and CVD rates. The model should separate antidumping duty, countervailing duty, ordinary customs duty, merchandise processing fees, and other charges.
Importers using rescinded producers should identify unliquidated entries and confirm the cash deposit rate that was in effect on each entry date. They should not assume that SRF's preliminary rates apply across all Indian PET film producers.
Customs brokers should maintain separate review calendars for the AD and CVD proceedings. Although the merchandise and respondent overlap, the periods of review, preliminary rates, briefing deadlines, assessment instructions, and final publication dates differ.
Duty drawback calculations require an additional control. Antidumping and countervailing duties are not eligible for drawback under 19 U.S.C. 1677h. Ordinary customs duties paid on the same entries may still qualify when the merchandise is subsequently exported or destroyed and all applicable drawback requirements are satisfied. Drawback records should therefore isolate AD and CVD amounts from potentially recoverable ordinary duties.
- Commerce published the CVD preliminary results on October 14, 2026 (91 FR 65169, C-533-825), assigning SRF Limited a 3.98 percent ad valorem subsidy rate for the January 1, 2024-December 31, 2024 POR.* The rate relies in part on adverse facts available. The review was rescinded for nine other companies after timely withdrawal requests. Cash deposit rates remain unchanged until the final results. Interested parties may file case briefs within 21 days of publication.
- On October 19, 2026 (91 FR 66095, A-533-824), Commerce issued the AD preliminary results for the July 1, 2024-June 30, 2025 POR, calculating a 0.61 percent dumping margin for SRF Limited.* Mandatory respondents initially included Polyplex Corporation Ltd. and SRF. After timely withdrawals, the review was rescinded for Cosmo, Chiripal, Ester, Garware, JPFL, Polyplex, and Vacmet, leaving only SRF under review. Deposits do not change until finals.
- Trade publications such as International Trade Today reported the notices, confirming liquidation as entered at existing cash deposit rates for non-reviewed companies (CBP messages issued).* Final results are due within 120 days of the prelims unless extended. No cash deposit changes take effect until then.
- No significant practitioner discussions on X were identified in the past 30 days specifically addressing these US AD/CVD prelims.* Related coverage focused on India's DGTR final findings (September 29, 2026) recommending AD duties on PET film imports from Bangladesh, China, and Thailand.
Frequently Asked Questions
What Are the Preliminary SRF Rates on PET Film From India?
SRF Limited received a preliminary antidumping margin of 0.61% for July 1, 2024 through June 30, 2025 and a preliminary countervailing duty rate of 3.98% for calendar year 2024. These rates remain subject to briefing, potential revisions, and final results.
Do Importers Start Depositing at 0.61% AD and 3.98% CVD Immediately?
No. Preliminary administrative review results generally do not change cash deposit requirements. Importers should continue using the rates required under existing CBP instructions until final results produce new deposit instructions.
What Happens to Entries From Companies Whose Reviews Were Rescinded?
Covered entries associated with rescinded companies are generally assessed at the cash deposit rate in effect at entry. Importers should verify the producer-exporter combination and monitor liquidation instructions rather than applying SRF's preliminary rates.
Can AD and CVD Paid on PET Film Be Recovered Through Drawback?
No. Antidumping and countervailing duties are not eligible for duty drawback. Ordinary customs duties paid on the same imported merchandise may still be eligible if the subsequent export or destruction and the claim satisfy the applicable requirements.
Why Must AD, CVD, and Ordinary Duty Be Tracked Separately?
Separate tracking supports accurate accruals, liquidation reviews, reimbursement certification, protests where appropriate, and drawback calculations. Combining all duties into one amount can cause an importer to overstate potential drawback or overlook additional AD and CVD exposure.
How Stable Software Can Help
Preserve Eligible Duty While Excluding AD and CVD
Indian PET film entries can contain ordinary customs duties that may qualify for drawback alongside AD and CVD amounts that are legally excluded. Accurate claim preparation depends on keeping those categories separate throughout the import, export, and accounting records.
DrawbackAI is flat-license duty drawback software that U.S. customs brokers can white-label for importer clients and use to file under their own filer code. Stable Software charges a flat software license and never takes a percentage of the refund. Brokers evaluating drawback opportunities for PET film and other imported products can consider whether a software-based process fits their client service model while preserving control of filing relationships and refund economics.
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