Mattress AD/CVD Orders Remain in Force

The mattress AD/CVD orders covering seven countries are set to remain in force following affirmative five-year sunset determinations. Mattress importers, retailers, e-commerce sellers, and customs brokers must continue accounting for substantial trade remedy exposure while maintaining disciplined origin, scope, entry, and duty drawback controls.

What the Sunset Determinations Mean for Mattress Imports

The Existing Orders Are Not Being Revoked

The U.S. International Trade Commission determined that revoking the countervailing duty order on mattresses from China and the antidumping duty orders on mattresses from Cambodia, Malaysia, Serbia, Thailand, Turkey, and Vietnam would likely lead to the continuation or recurrence of material injury to the domestic industry within a reasonably foreseeable period.

These affirmative sunset determinations mean the orders are not revoked as a result of the five-year review. The Department of Commerce generally completes the process by publishing a separate notice formally continuing the orders. Importers and customs brokers should monitor that notice, but they should not treat the period between the Commission's determination and Commerce's continuation notice as a suspension of existing obligations.

The reviews were instituted on April 1, 2026, and later designated for expedited review. The determinations were filed on October 22, 2026, with publication scheduled for October 27, 2026. The expedited process does not reduce the compliance significance of the result. Covered imports generally remain subject to the applicable cash deposit requirements and administrative procedures.

Cash Deposits Remain a Core Landed Cost Component

Importers should continue incorporating AD/CVD cash deposits into landed cost forecasts, purchasing decisions, and working capital planning. Deposit rates may depend on the exporter, producer, applicable review results, and Commerce instructions in effect at entry. A rate associated with one supplier should not automatically be applied to another supplier or sourcing arrangement.

Cash deposits also should not be treated as the final duty liability. Final assessments can change through administrative reviews and liquidation instructions, creating additional liability or potential refunds after entry. Finance and compliance teams therefore need a shared process for tracking both deposited amounts and unresolved exposure.

Compliance Priorities for Importers and Customs Brokers

Confirm Scope, Classification, and Country of Origin

A mattress shipment's tariff classification is only one part of the AD/CVD analysis. Importers must also determine whether the merchandise falls within the written scope of the applicable order. Product construction, dimensions, component materials, packaging, intended use, and other technical characteristics may affect the analysis.

Country of export is not necessarily the same as country of origin. Routing a mattress through a third country generally does not change its origin. Importers should examine where production occurred, what manufacturing operations were performed, and whether any claimed transformation is supported by reliable records. Heightened scrutiny is appropriate when production is split among multiple countries or when a supplier changes its manufacturing location shortly after trade measures take effect.

Supplier declarations alone may not provide sufficient support. A defensible file typically includes purchase orders, bills of materials, production records, factory information, commercial invoices, packing lists, transportation documents, and payment records. The appropriate evidence depends on the transaction and the origin analysis.

Strengthen SKU-Level Entry Controls

Mattress importers often manage broad catalogs with similar descriptions but different constructions and sourcing histories. That creates a risk that scope or origin decisions made for one stock-keeping unit will be applied too broadly. Compliance teams should maintain a SKU-level matrix linking product specifications, suppliers, manufacturers, countries of origin, tariff classifications, scope conclusions, and applicable case information.

Customs brokers should obtain clear written instructions before filing and escalate incomplete or inconsistent data. Product descriptions such as “bed,” “sleep product,” or “foam article” may be commercially understandable but insufficient for trade remedy screening. Entry data should clearly identify the merchandise and support the importer's scope position.

Post-entry review is equally important. Importers should compare filed entries with purchase records, supplier documents, and deposit calculations. Errors involving case numbers, manufacturer identification, origin, entered value, or deposit rates can create material exposure. Corrections should generally be evaluated promptly because available mechanisms and deadlines vary according to entry status.

Landed Cost, Financial Exposure, and Duty Drawback

AD/CVD Exposure Requires Separate Accounting

Antidumping and countervailing duties can materially alter the economics of an import program. Procurement teams evaluating mattress suppliers should model the applicable deposits alongside ordinary customs duties, transportation, insurance, brokerage, harbor charges, storage, and other import costs. A sourcing decision that appears favorable based on unit price alone may become uneconomic after trade remedy exposure is included.

Importers also need to account for the timing difference between entry and final liquidation. Deposits can remain unresolved while administrative reviews determine final assessment rates. Contract terms should address responsibility for deposits, supplemental duty bills, refunds, documentation, and cooperation with review-related information requests. These provisions are especially important when purchasing through intermediaries rather than directly from the manufacturer.

Internal reporting should distinguish ordinary customs duties from antidumping and countervailing duty amounts. Combining all duty payments into a single account can obscure financial exposure and create problems when evaluating refunds, protests, post-entry corrections, or drawback claims.

AD/CVD Duties Are Not Eligible for Drawback

Federal law excludes antidumping and countervailing duties from duty drawback. Importers and drawback filers therefore cannot include those amounts in a claim, even if the associated mattress is later exported or destroyed under qualifying conditions.

Ordinary customs duties paid on the same entry may still qualify for drawback when the statutory and procedural requirements are satisfied. Depending on the facts, potential pathways may involve exported or destroyed merchandise, or imported merchandise used in manufacturing exported goods. Eligibility generally depends on the transaction structure, merchandise records, time limits, export evidence, and the selected drawback provision.

Drawback calculations must keep AD/CVD deposits and assessments separate from eligible ordinary duties. This separation should begin in the entry data and accounting records, not after a claim is assembled. Brokers filing drawback under their own filer codes need controls that prevent excluded trade remedy amounts from entering the claim value while preserving eligible ordinary duty data.

Frequently Asked Questions

Which Countries Are Covered by the Mattress Determinations?

The countervailing duty determination covers mattresses from China. The antidumping duty determinations cover mattresses from Cambodia, Malaysia, Serbia, Thailand, Turkey, and Vietnam. Importers should confirm the written scope and current instructions rather than relying solely on a product's commercial name or country of shipment.

Do Importers Still Need to Pay AD/CVD Cash Deposits?

Yes. The affirmative sunset determinations mean the orders are not revoked through these reviews. Importers should continue depositing estimated duties at the rates required by current Commerce and U.S. Customs and Border Protection instructions. Applicable rates can vary by exporter, producer, and review period.

Does Shipping Through Another Country Avoid the Orders?

Generally, no. Transshipment does not by itself change origin. Importers need evidence showing where the mattress was manufactured and whether operations in another country were sufficient to affect origin. Unexplained routing, incomplete factory records, or mismatched documentation can create significant enforcement risk.

Can Mattress Importers Claim Drawback on AD/CVD Payments?

No. Antidumping and countervailing duties are not eligible for drawback. However, ordinary customs duties paid on the same entries may qualify if the merchandise is exported, destroyed, or used in qualifying manufacturing and all other drawback requirements are met.

Why Can Final Liability Differ From the Cash Deposit?

Cash deposits are estimates collected at entry. Final liability may be determined later through administrative reviews and liquidation instructions. The final assessment rate can be higher or lower than the deposited rate, so importers should track open entries and retain sufficient reserves for potential additional duties.

How Stable Software Can Help

A Flat-License Drawback Option for Customs Brokers

Mattress entries subject to AD/CVD require careful separation between ineligible trade remedy duties and ordinary customs duties that may qualify for drawback. Customs brokers also need a commercially sustainable way to manage eligible drawback work for importer clients without surrendering a share of the recovery.

DrawbackAI is Stable Software's flat-license duty drawback software for U.S. customs brokers. Brokers can white-label the software for their importer clients and file claims under their own filer code. Stable Software charges a flat software license and never takes a percentage of the refund. Brokers evaluating how to expand or standardize their drawback services can explore whether DrawbackAI fits their operating model.

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