Korea CORE AD/CVD Review: Preliminary Rates

The Korea CORE AD/CVD review has moved 2024 and 2025 entries into a consequential phase, with preliminary rates that could materially alter importer liability. Customs brokers, trade compliance teams, and finance leaders should now reconcile supplier identities, entry case numbers, deposits, and accruals before final results and liquidation instructions reshape exposure. ## Preliminary AD and CVD Results for Korean CORE The U.S. Department of Commerce published preliminary results on October 8, 2026, for separate antidumping duty and countervailing duty administrative reviews covering certain corrosion-resistant steel products from the Republic of Korea. The AD review under A-580-878 covers July 1, 2024, through June 30, 2025. The CVD review under C-580-879 covers January 1 through December 31, 2024. The preliminary AD margins are: | Company | Preliminary AD Margin | |---|---:| | KG Dongbu Steel Co., Ltd. | 23.40% | | Dongkuk Coated Metal Co., Ltd./Aju Steel Co., Ltd. | 19.43% |

| Companies not selected for individual review | 20.58% | The 20.58% non-selected rate applies preliminarily to Hyundai Steel Company, POSCO, POSCO International Corporation, SeAH Coated Metal, and SeAH Steel Corporation. Dongkuk Coated Metal and Aju Steel were treated as a collapsed single entity for the AD analysis. The preliminary CVD rates are: | Company | Preliminary CVD Rate | |---|---:| | Hyundai Steel Company | 0.58% | | KG Dongbu Steel Co., Ltd. | 4.82% | | Companies not selected for individual review | 2.22% | ### Entity Relationships and Partial Rescissions Matter For CVD purposes, Hyundai Steel's rate incorporates cross-owned Hyundai ITC and Hyundai Green Power. KG Dongbu's analysis includes cross-owned KG Eco Solution, while KG Steel was treated as the same entity. These relationships make precise manufacturer and exporter matching essential. Commerce preliminarily rescinded the AD review for Dongbu Incheon Steel, Dongkuk Steel Mill, POSCO Coated and Color Steel, and TCC Steel because there were no reviewable entries. The CVD review was rescinded for Dongkuk Coated Metal. A rescission does not remove merchandise from an order. It generally means that entries associated with the affected company will be handled under the applicable assessment and liquidation rules rather than receiving a newly calculated rate from that review. ## What the Preliminary Rates Mean for Current Entries Preliminary administrative review rates do not immediately replace existing AD/CVD cash deposit rates. Importers should continue depositing duties at the rates currently in effect until final results establish new prospective cash deposit requirements. Brokers should not substitute the preliminary percentages merely because they now appear in the administrative review record. This distinction separates three different financial concepts: 1. Cash deposits at entry: Estimated AD and CVD amounts paid when merchandise enters. 2. Final assessment liability: The amount ultimately assessed on entries covered by the review period. 3. Future cash deposit rates: Rates applied prospectively after publication of final results, subject to applicable instructions. A company with a current deposit rate below its preliminary review rate may face additional liability when covered entries liquidate. Conversely, a preliminary result below the deposited rate could indicate potential excess deposits, although repayment generally depends on final results, assessment instructions, liquidation, and any litigation. ### Brokers Must Validate Both AD and CVD Case Numbers Korean CORE can be subject to both A-580-878 and C-580-879 on the same entry. Entry review should confirm that both case numbers were declared when applicable and that the manufacturer, exporter, and supplier relationships support the rates used. Name matching should extend beyond commercial invoice descriptions. Trade teams should compare entry data against the legal names of reviewed entities, collapsed entities, cross-owned affiliates, and companies receiving the non-selected rate. Similar corporate names do not necessarily establish that two entities receive the same treatment. Importers should also retain documentation supporting country of origin, product scope analysis, manufacturer identity, exporter identity, and deposit calculations. Any apparent omission or incorrect case number should be escalated promptly through the broker and customs counsel, particularly if liquidation is approaching. ## Managing Accruals, Liquidation, and Compliance Risk Finance teams should use the preliminary results to update scenario-based accruals for entries made during the applicable periods of review. The most useful analysis compares deposited AD and CVD amounts with estimated liability under the preliminary rates, while preserving separate calculations for each case and supplier. For entries involving KG Dongbu during calendar year 2024, for example, potential exposure may include both the 23.40% preliminary AD margin and the 4.82% preliminary CVD rate. Those percentages should not simply be added to produce a final accounting conclusion. AD assessment calculations can be importer-specific, and the relevant entered value, adjustments, deposit history, and final instructions must be considered. The administrative schedule included shutdown-related tolling during the review process. Commerce will establish the case brief schedule separately. Rebuttal briefs are generally due five days after case briefs and must be submitted through ACCESS by 5:00 p.m. Eastern Time. Interested parties should coordinate factual, legal, and financial review well before those deadlines. ### Prepare Before Assessment Instructions Are Issued After final results, Commerce generally transmits assessment instructions no earlier than 35 days after publication. Similar timing considerations may apply to rescinded portions of a review. If a summons is filed with the U.S. Court of International Trade, liquidation can be held during the applicable 90-day period for seeking an injunction. Importers should typically complete the following actions before liquidation: - Reconcile reviewed suppliers to all affected entry lines.

• Compare deposits with preliminary AD and CVD exposure.
• Confirm that both case numbers were reported where required.
• Review unliquidated entry reports and liquidation dates.
• File required reimbursement certificates before liquidation.
• Preserve supporting entry, purchasing, and supplier records. Reimbursement certificates under 19 CFR 351.402(f) require particular attention. Failure to provide the required certification can generally lead to a presumption of reimbursement and potentially increased antidumping duty liability. AD and CVD amounts also must be segregated from ordinary customs duties in recovery models. Antidumping and countervailing duties are not eligible for duty drawback under 19 U.S.C. 1677h, even when the imported merchandise is later exported or destroyed. ## Frequently Asked Questions ### Do the Preliminary Korean CORE Rates Change Cash Deposits Now? No. Importers should continue using the AD and CVD cash deposit rates currently in effect. The preliminary results estimate potential outcomes for reviewed entries but do not establish new prospective deposit rates. Cash deposit changes generally follow publication of final results and the corresponding instructions. ### Which Periods Are Covered by the Reviews? The AD review under A-580-878 covers entries from July 1, 2024, through June 30, 2025. The CVD review under C-580-879 covers calendar year 2024. Entries made in 2024 may therefore fall within both reviews, depending on entry date, product scope, manufacturer, and exporter. ### Can Importers Claim Drawback on Korean CORE AD/CVD? No. Antidumping and countervailing duties are statutorily excluded from drawback. Importers may still have drawback opportunities involving other eligible customs duties, taxes, or fees, but AD and CVD amounts must be removed from any potential refund calculation. ### What Does a Review Rescission Mean for an Importer? A rescission generally means Commerce did not conduct a substantive review for that company, often because it found no reviewable entries. It does not revoke the underlying AD or CVD order. Importers should determine which assessment instructions and deposit rates apply to the affected entries rather than assuming no duties are owed. ### How Should Importers Estimate Liquidation Exposure? Importers should map each entry to its manufacturer, exporter, review period, deposited rate, entered value, and applicable preliminary result. AD and CVD exposure should be modeled separately. The calculation should also distinguish individually reviewed companies, non-selected companies, rescinded companies, and related entities. ## How Stable Software Can Help ### Separate Eligible Drawback From Excluded AD/CVD The Korean CORE reviews demonstrate why importers and customs brokers need to distinguish recoverable customs duties from AD/CVD amounts that cannot be refunded through drawback. Clear separation helps prevent excluded duties from entering a drawback claim while allowing eligible duty recovery opportunities to receive appropriate attention. Stable Software offers DrawbackAI, 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 broader duty recovery opportunities can explore whether DrawbackAI fits their client service model.

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