Korea Hot-Rolled Steel CVD Rates for 2023 Review

The Korea hot-rolled steel CVD review creates immediate compliance and cost implications for U.S. importers. Hyundai Steel now carries a 1.28% countervailing duty rate, while POSCO carries a 3.68% rate for qualifying entries made on or after October 9, 2026. ## Final Countervailing Duty Rates and Effective Date The Department of Commerce finalized its 2023 administrative review of the countervailing duty order covering certain hot-rolled steel flat products from the Republic of Korea. The review covers calendar year 2023 under case C-580-884 and establishes company-specific net subsidy rates for Hyundai Steel Company and POSCO. ### Producer-Specific Rates The final rates are: | Producer or exporter | Final CVD rate | |---|---:| | Hyundai Steel Company | 1.28% ad valorem | | POSCO | 3.68% ad valorem | These rates serve two distinct functions. They determine the assessment treatment for covered entries during the reviewed period, subject to Commerce's liquidation instructions, and establish new cash deposit rates for applicable entries made on or after October 9, 2026. Commerce found Hyundai Green Power Co. Ltd. cross-owned with Hyundai Steel. For POSCO, the reviewed corporate group includes POSCO Future M, POSCO Holdings, POSCO M-Tech, POSCO Nippon Steel RHF Joint Venture Co., Ltd., and POSCO Mobility Solutions. Subsidies associated with POSCO International are included in POSCO's rate. Importers should therefore evaluate both the producing mill and the exporter when assigning the proper deposit rate. Only POSCO's calculation changed following the preliminary results issued on April 10, 2026. The final analysis addressed subsidy issues involving electricity provided for more than adequate remuneration, Korea Emissions Trading System permits, KEXIM loan programs, and a workplace nursery program. Companies not individually reviewed generally retain their most recent company-specific rate or the applicable all-others rate. Import teams should not automatically apply the Hyundai Steel or POSCO rate to unrelated Korean producers. ## Cash Deposits, Assessments, and Liquidation Exposure The effective date for the new cash deposit rates is October 9, 2026. Entries of covered merchandise from Hyundai Steel or POSCO made on or after that date should reflect the new rates, provided the merchandise falls within the order and the identified producer-exporter relationship supports the rate claimed. ### Deposits Are Not Final Duty Liability A countervailing duty cash deposit is a security payment collected at entry. It is not necessarily the final duty amount. Administrative review results determine assessment treatment for entries during the period of review, which can create additional liability or a potential refund when compared with the deposits originally paid. Importers should build a 2023 entry population containing, at minimum, the entry number, entry date, liquidation status, manufacturer identification, exporter, entered value, deposit rate, and CVD amount paid. Comparing those records against the final company-specific rate provides an initial estimate of liquidation exposure. That estimate should also account for corrections, protests, prior disclosures, scope questions, and any suspended entries. Commerce generally transmits assessment instructions to U.S. Customs and Border Protection no earlier than 35 days after publication of the final results. A timely summons filed with the U.S. Court of International Trade can hold liquidation through the applicable 90-day injunction period. Importers should monitor entry status closely because liquidation can limit the available paths for correcting errors or recovering overpayments. The new rate should also be incorporated into purchasing, landed cost, and accrual systems. Accounts payable and finance teams may otherwise continue accruing at an obsolete rate even after the entry system has been updated. Customs brokers should verify that automated line calculations, customer profiles, and producer-specific instructions all use the October 9 effective date rather than applying the rate retroactively. ## Managing Scope, Producer, and Landed Cost Controls A Korean origin determination alone does not establish the applicable countervailing duty treatment. Importers must confirm that the product is within the scope of the hot-rolled steel order and identify the relevant producer and exporter. Product descriptions, dimensions, chemistry, processing history, and exclusions can all affect scope analysis. ### Validate the Complete Entry Data Chain A robust control begins with commercial documentation. Purchase orders, mill test certificates, invoices, packing lists, bills of lading, and entry records should consistently identify the producing mill. This is especially important when a trading company, service center, or related exporter appears as the seller while Hyundai Steel or POSCO manufactured the merchandise. POSCO International shipments require particular attention because subsidies associated with that entity are included in POSCO's final rate. Importers should not assume that an exporter's name changes the producer-specific treatment. The correct rate typically depends on the facts of the transaction and the instructions applicable to the producer-exporter combination. The CVD update should also be evaluated alongside any separate antidumping duty order. Antidumping and countervailing duties are independent trade remedies, and the same entry can generally be subject to both. Deposit rates should therefore be maintained as separate calculations rather than combined into a single generic trade remedy percentage. Downstream manufacturers should update standard costs and purchase forecasts for affected hot-rolled coil. Even a relatively small percentage change can materially affect high-value or high-volume steel programs. Procurement teams may need to evaluate supplier pricing, Incoterms, duty allocation clauses, and reimbursement provisions. Compliance teams should also confirm that vendors are not making unsupported assurances about scope exclusion, producer identity, or final duty exposure. ## Duty Drawback Treatment for Affected Steel Entries Countervailing duties and antidumping duties require separate treatment in duty drawback calculations. Under 19 U.S.C. 1677h, AD/CVD amounts are not eligible for drawback. Exporting or destroying merchandise that was subject to a trade remedy order does not make the associated antidumping or countervailing duties recoverable. ### Separate Recoverable and Nonrecoverable Duty Amounts Ordinary customs duties paid on the same entry may still qualify for drawback when the statutory and procedural requirements for the selected drawback provision are satisfied. Drawback filers should therefore preserve separate data fields for ordinary customs duty, countervailing duty, antidumping duty, merchandise processing fees, and any other duty or fee category. Combining all amounts into a single duty-paid field creates a significant claim risk. It can cause an ineligible CVD amount to be included in a drawback calculation, or it can cause a filer to exclude ordinary customs duties that may otherwise be recoverable. Both outcomes undermine claim accuracy. The entry-level data model should retain the manufacturer, exporter, case number, deposit rate, entered value, and duty type for every affected line. When the entry liquidates, the filer should capture any changes between the deposited amount and the final assessed amount without moving AD/CVD values into an eligible drawback category. Importers using substitution drawback should also maintain the classification, quantity, value, and applicable matching data required for their claims. The presence of nonrecoverable CVD does not necessarily eliminate drawback eligibility for ordinary duties, but it increases the need for precise allocation and reconciliation. Customs brokers that prepare claims for steel importers should document this treatment in client procedures. Review controls should specifically test whether trade remedy duties have been excluded while eligible ordinary duties remain available for calculation. ## Frequently Asked Questions ### What Are the Final CVD Rates for Korean Hot-Rolled Steel? The final 2023 review rates are 1.28% ad valorem for Hyundai Steel Company and 3.68% for POSCO. These rates apply as new cash deposit rates to qualifying entries made on or after October 9, 2026. Other producers generally retain their existing company-specific or all-others rate. ### Does the POSCO Rate Apply to POSCO International Shipments? POSCO International's subsidies are included in POSCO's rate. Importers should still verify the complete producer-exporter combination, scope coverage, and applicable entry instructions. The exporter's name alone should not be used to select a rate without confirming the manufacturer and transaction facts. ### When Will CBP Liquidate the Reviewed 2023 Entries? Assessment instructions are generally issued no earlier than 35 days after publication of the final results. A timely Court of International Trade summons can hold liquidation through the 90-day injunction window. Importers should monitor affected entries and coordinate promptly with trade counsel and their customs broker when litigation affects liquidation. ### Can Countervailing Duties Be Recovered Through Drawback? No. Countervailing duties and antidumping duties are not eligible for drawback under 19 U.S.C. 1677h. Ordinary customs duties paid on the same entry may remain eligible when the merchandise and claim satisfy the applicable drawback requirements. The amounts should be maintained separately in claim data. ### Could a Separate Antidumping Duty Apply to the Same Steel? Yes. An entry can generally be subject to both antidumping and countervailing duty orders. Importers should conduct separate scope and rate reviews for each case, calculate each deposit independently, and retain documentation supporting the producer, exporter, classification, entered value, and order applicability. ## How Stable Software Can Help ### Broker-Controlled Drawback Processing Korean steel entries can contain both recoverable ordinary customs duties and nonrecoverable AD/CVD amounts, making accurate duty separation essential. DrawbackAI is flat-license duty drawback software that U.S. customs brokers can white-label for importer clients. Brokers file under their own filer code and retain control of the client relationship and filing process. Stable Software charges a flat software license and never takes a percentage of the refund. Customs brokers seeking a structured way to support importer drawback programs can explore how DrawbackAI fits within their existing brokerage and compliance operations.

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