The Italian fluid end blocks antidumping duty landscape has shifted for historical Lucchini entries. A court-sustained recalculation raises the producer's 2020-2021 dumping margin from 2.97% to 7.55%, requiring importers and customs brokers to distinguish potential assessment exposure from current cash deposit obligations.
Why Lucchini's Antidumping Margin Increased
The Court Decision and Amended Results
The U.S. Court of International Trade issued its final judgment on October 2, 2026, sustaining the Department of Commerce's remand redetermination involving forged steel fluid end blocks from Italy. Commerce subsequently published amended final results on October 15, 2026, with an applicability date of October 12, 2026.
The affected period of review runs from July 23, 2020, through December 31, 2021. Commerce's original final results assigned Lucchini Mame Forge S.p.A. a weighted-average dumping margin of 2.97%. Following the remand analysis and court judgment, that margin increased to 7.55%.
The change is significant because antidumping duty liability is generally determined through retrospective assessment. The margin associated with a completed review can therefore affect entries made years earlier, even when an importer currently deposits duties at a different rate.
Constructed Value and Major Input Revisions
Two methodological changes drove the higher result. First, Commerce excluded the financial statements of Cogne and Ciscato from the constructed value profit calculation after reconsidering whether those companies produced merchandise identical to the subject fluid end blocks.
Second, Commerce revised the benchmark used in its major input analysis for stainless steel ingots. It selected Company A's U.S. ingot purchases as the market-price benchmark. Commerce also rejected adjustment information submitted by Lucchini in February 2023 because it treated the material as untimely new factual information.
These changes illustrate how constructed value profit and major input methodologies can materially alter a dumping calculation. Importers should not assume that an originally published review rate will remain final while judicial proceedings and remand determinations are pending.
Assessment Exposure, Cash Deposits, and Liquidation
The 7.55% Rate Applies to Historical Entries
The amended 7.55% margin concerns Lucchini-produced or exported merchandise entered, or withdrawn from warehouse for consumption, from July 23, 2020, through December 31, 2021. Those entries remain enjoined from liquidation while appeal rights are unresolved.
If the judgment is not appealed, or if it is upheld after an appeal, Commerce intends to instruct U.S. Customs and Border Protection to assess antidumping duties on applicable unliquidated entries under the normal importer-specific assessment process. The final amount may depend on the assessment instructions and entry-level data, but the 7.55% amended margin provides an important basis for financial planning.
Importers should identify the affected entries, confirm that liquidation remains suspended, and compare existing reserves with the potential exposure. A reserve based solely on the former 2.97% margin may understate the expected liability.
Current Cash Deposits Do Not Change
The amended results do not create a new cash deposit rate for current Lucchini entries. Lucchini is already subject to a superseding rate established through a later administrative review, so Commerce will not issue revised cash deposit instructions based on the 7.55% amendment.
This distinction is critical. Cash deposits generally secure estimated duties on current imports, while assessment instructions determine the final antidumping duties owed on entries covered by a completed review. A change to a historical assessment margin does not necessarily alter the deposit rate applied to new shipments.
Customs brokers should avoid replacing the current deposit rate with 7.55% in entry systems. Instead, they should maintain the superseding rate for current entries while separately flagging the 2020-2021 entries for monitoring. Importers should also reconcile broker records, internal import data, and contingent liability schedules to ensure the two rate concepts are not combined.
Compliance and Drawback Controls for Affected Importers
Immediate Entry Review Priorities
Importers of Lucchini forged steel fluid end blocks should build a complete population of entries from the review period. Relevant data generally includes entry numbers, entry dates, manufacturer and exporter identifiers, entered values, antidumping case numbers, deposited amounts, liquidation status, and any prior notices concerning suspension or injunctions.
The entry population should then be tested against CBP records. Entries that appear liquidated despite an applicable injunction require prompt investigation. Entries that remain suspended should be included in financial exposure models using the amended 7.55% margin as an appropriate planning reference, subject to final assessment instructions.
Brokers should preserve the original entry documentation and maintain clear communication with importers regarding liquidation messages. Oil and gas equipment buyers should also review purchase agreements, indemnification provisions, and vendor duty clauses. Contractual responsibility for additional antidumping duties may differ from the importer of record's legal responsibility to CBP.
Keep Antidumping Duties Out of Drawback Calculations
Antidumping and countervailing duties are not eligible for drawback under 19 U.S.C. 1677h. An export or destruction does not convert those trade remedy duties into recoverable drawback. Claim calculations should therefore exclude both deposited and finally assessed antidumping duty amounts.
Ordinary customs duties paid on the same entries may still qualify for drawback when the merchandise is subsequently exported or destroyed and the claim otherwise satisfies the applicable requirements. This creates a need for precise duty segregation at the entry-line and accounting levels.
A strong control framework keeps ordinary duties, antidumping duties, countervailing duties, fees, and other charges in distinct data fields. It also preserves links between imported merchandise and qualifying exports or destructions without treating the full payment to CBP as drawback-eligible duty.
For entries subject to unresolved antidumping litigation, drawback teams should coordinate with trade counsel, customs brokers, and finance personnel. The potential assessment increase may affect accruals, but it should not inflate the recoverable ordinary-duty amount included in a drawback claim.
- On October 2, 2026, the U.S. Court of International Trade (Judge Timothy Reif) issued its final judgment in Ellwood City Forge Company v. United States (Court No. 23-00191), sustaining Commerce's July 2026 remand redetermination.* This raised Lucchini Mame Forge S.p.A.'s weighted-average dumping margin for the July 23, 2020-December 31, 2021 POR from 2.97 percent to 7.55 percent. No parties commented on the remand results.
- On October 15, 2026, Commerce published a Timken notice and amended final results (91 FR 65527, FR Doc. 2026-21044), applicable October 12, 2026.* The increase followed Commerce reversing its original findings: it excluded Cogne and Ciscato financial statements from Lucchini's constructed value profit calculation (concluding they do not produce identical merchandise to subject FEBs) and switched the major-input (stainless steel ingots) market-price benchmark to Company A's U.S. purchases while rejecting Lucchini's February 2023 data as untimely.
- Cash deposit instructions to CBP will not be revised, as Lucchini has superseding rates from later reviews (such as 11.71 percent from the 2023 administrative review).* Entries of Lucchini-produced/exported merchandise from the 2020-2021 POR remain enjoined from liquidation. If the CIT ruling is not appealed or is upheld, Commerce will instruct CBP to assess duties at the 7.55 percent rate.
- Trade Law Daily covered the CIT sustainment (October 5, 2026) and the underlying July 27, 2026 remand filing that produced the 7.55 percent rate.* A related CVD administrative review for 2024 (published September 22, 2026) assigned Lucchini a 15.94 percent net subsidy rate, but this is a separate proceeding.
- No relevant practitioner discussions on X were identified in the past 30 days.
Frequently Asked Questions
What Is Lucchini's Amended Antidumping Margin?
Lucchini Mame Forge S.p.A.'s amended weighted-average dumping margin is 7.55% for the period from July 23, 2020, through December 31, 2021. The original final results assigned a 2.97% margin for that period.
Does the 7.55% Margin Apply to New Imports?
Not as the current cash deposit rate. Lucchini has a superseding deposit rate from a later review. The 7.55% margin relates to assessment exposure for covered 2020-2021 entries, subject to the outcome of any appeal and subsequent Commerce instructions to CBP.
When Will the Affected Entries Liquidate?
The affected Lucchini entries remain enjoined during the appeal period and any resulting appellate proceedings. If the judgment becomes final, Commerce generally will issue liquidation and assessment instructions to CBP. Importers and brokers should continue monitoring entry status until those instructions are implemented.
Can Antidumping Duties Be Recovered Through Drawback?
No. Antidumping and countervailing duties are not eligible for drawback. Ordinary customs duties paid on the same merchandise may remain eligible when all statutory and procedural requirements are met, but the trade remedy amounts must be excluded from the claim.
What Should Importers Do Now?
Importers should identify affected entries, verify the injunction and liquidation status, reassess financial reserves, and monitor potential appellate activity. They should keep using Lucchini's superseding cash deposit rate for current entries and maintain separate accounting for ordinary duties and antidumping duties.
How Stable Software Can Help
Strengthen Drawback Duty Segregation
Historical antidumping changes reinforce the importance of separating recoverable ordinary customs duties from ineligible AD/CVD amounts. 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 codes.
Stable Software charges a flat software license and never takes a percentage of the refund. Customs brokers evaluating how to support importer drawback programs can explore DrawbackAI as part of a structured approach to managing eligible duty recovery while keeping antidumping and countervailing duty amounts outside claim calculations.
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