Mexico Corrosion-Resistant Steel AD Margins Amended

Importers of corrosion-resistant steel from Mexico face revised antidumping duty exposure following a Court of International Trade decision involving Galvasid. The amended margins affect cash deposit setup, entry validation, liquidation planning, and the separation of antidumping duties from ordinary customs duties in drawback calculations.

How the CIT Decision Changed the Antidumping Margins

The Commerce Department amended part of its final antidumping determination and order after the Court of International Trade sustained a recalculation of Galvasid S.A. de C.V.'s dumping margin. Galvasid's amended margin is 14.54 percent, while the rate for companies subject to the all-others rate is 14.29 percent. The amendment applies as of October 29, 2026.

The investigation covered entries during the period from July 1, 2023, through June 30, 2024. Commerce issued its original final determination in August 2025 and subsequently published an amended determination and order in December 2025. Galvasid's rate in that amended order was 24.09 percent, making the court-directed reduction operationally and financially significant for affected supply chains.

Why Commerce Recalculated Galvasid's Margin

The dispute concerned Commerce's use of partial adverse facts available in connection with U.S. freight and insurance revenue. Galvasid had not separately reported that revenue, and Commerce initially applied an adverse inference and made a related adjustment to the company's U.S. gross unit price.

The CIT directed Commerce to reconsider that treatment. On remand, Commerce reversed the partial adverse facts available determination and removed the corresponding adjustment from Galvasid's U.S. price calculations. That change lowered the company-specific margin and required a corresponding revision to the all-others rate.

The Function of a Timken Notice

When a CIT judgment is not in harmony with Commerce's original determination, Commerce generally publishes what trade professionals call a Timken notice. The notice acknowledges the conflicting court judgment and amends the determination when appropriate under the litigation posture.

The CIT entered final judgment sustaining Commerce's remand redetermination on October 19, 2026. Commerce signed the implementing notice on October 28, placed it on public inspection on October 30, and scheduled publication for November 2. Commerce will issue revised cash deposit instructions to U.S. Customs and Border Protection, which will guide the operational treatment of covered entries.

Cash Deposit and Entry Review Priorities

Importers and customs brokers should treat the amended rates as an entry compliance event, not merely a legal update. Product scope, manufacturer identity, exporter identity, entry date, and applicable case number must all align before a revised rate is applied. The relevant antidumping case remains A-201-863.

The principal exposure falls on entries of covered corrosion-resistant steel produced by Galvasid and entries associated with companies that receive the all-others rate. Merchandise outside the order's scope is not brought into the case merely because it is steel from Mexico, so scope review remains a necessary first step.

Rates and Effective Date

The amended rates are:

The amendment applies as of October 29, 2026. Importers and brokers should check covered entries made on or after that date against the revised instructions transmitted to CBP. Operational systems should not be updated solely by replacing every historical rate associated with the case. The correct treatment depends on the entry date, party combination, scope, and effective instructions.

Cash deposits are provisional. They do not necessarily represent the final antidumping duty liability determined at liquidation. Nevertheless, an incorrect deposit rate can create avoidable cash flow pressure, correction work, and discrepancies between broker records, importer ledgers, and CBP entry data.

A Practical Broker and Importer Workflow

A controlled response should generally include the following steps:

1. Identify unliquidated and newly filed entries of potentially covered merchandise.
2. Confirm whether Galvasid or the all-others category applies to each producer and exporter combination.
3. Compare entries made on or after October 29, 2026, with CBP's revised deposit instructions.
4. Review entry summaries, payment records, purchase documentation, and manufacturer declarations for inconsistent rate treatment.
5. Preserve records showing deposits paid under earlier instructions.
6. Coordinate corrections through the appropriate CBP mechanism when an entry was filed using an incorrect rate.

Compliance teams should also verify that enterprise resource planning systems, broker instructions, landed cost models, and purchase order assumptions use the same effective date logic. Updating a reference table without reviewing open transactions may leave shipments in transit or preconfigured entry templates tied to obsolete rates.

Drawback, Liquidation, and Duty Segregation

The reduction in the Galvasid antidumping margin does not make antidumping duties eligible for duty drawback. Under 19 U.S.C. 1677h, antidumping and countervailing duties are not refundable through drawback. Importers and drawback filers must therefore prevent AD/CVD amounts from being included in the pool of potentially recoverable ordinary customs duties.

That distinction is especially important when the same entry includes both antidumping deposits and ordinary customs duties. A single payment record may reflect multiple duty types, but each amount must retain its own legal and accounting treatment.

Separating AD/CVD From Drawback-Eligible Duties

Ordinary customs duties paid on covered steel entries may still qualify for drawback when the merchandise is subsequently exported or destroyed, or when it is used in manufacturing exported articles. Eligibility depends on the applicable drawback framework, documentary support, timing, merchandise matching, and all other claim requirements.

A robust duty ledger should generally distinguish:

• Ordinary customs duties that may be considered for drawback
• Antidumping duty deposits excluded from drawback
• Countervailing duty deposits, if any, excluded from drawback
• Merchandise processing fees and other charges subject to their own refund rules
• Corrections, refunds, or additional assessments resulting from liquidation

This segregation should flow from entry data into the drawback calculation rather than being reconstructed only when a claim is prepared. Treating total duty paid as a single recoverable amount can overstate the claim and create audit exposure.

Preserving Records Through Liquidation

Importers should retain entry summaries, deposit calculations, broker communications, manufacturer documentation, payment evidence, and subsequent CBP notices. Earlier deposits should remain traceable even if the applicable cash deposit rate later changes.

The final amount owed may depend on liquidation instructions and the outcome of the relevant administrative process. A new cash deposit rate generally governs provisional collection for applicable entries. It does not automatically rewrite the final liability for every prior entry.

Accounting and compliance teams should reconcile their records when liquidation occurs, but they should not assume that the CBP Reconciliation program can be used to change antidumping liability. The term reconciliation in internal procedures should be clearly distinguished from the formal CBP program. Drawback calculations should then use the eligible ordinary duty amount supported by the final entry record while continuing to exclude AD/CVD duties.

Frequently Asked Questions

The amended order raises practical questions about effective dates, cash deposits, prior entries, and drawback treatment. Each answer should be applied together with the product scope and CBP's instructions for the specific entry.

What Is Galvasid's New Antidumping Duty Margin?

Galvasid S.A. de C.V.'s amended antidumping margin is 14.54 percent. The revised rate resulted from Commerce removing an adjustment connected with partial adverse facts available for U.S. freight and insurance revenue. The previously amended margin was 24.09 percent.

What Is the Revised All-Others Rate?

The amended all-others rate is 14.29 percent. This rate generally applies to covered producers and exporters from Mexico that do not have an applicable company-specific rate. Brokers should confirm the complete party combination and current CBP instructions rather than assigning the rate based only on country of origin.

When Do the Amended Rates Apply?

The amendment applies as of October 29, 2026. Entries made on or after that date should be reviewed against the revised cash deposit instructions issued to CBP. Publication timing, entry timing, and the effective date should be maintained as separate data points in compliance systems.

Do the New Rates Change Earlier Cash Deposits Automatically?

No. The revised rates do not necessarily produce an automatic refund or adjustment for every earlier entry. Antidumping deposits are provisional, and final liability generally depends on liquidation instructions and the applicable administrative review period. Importers should preserve earlier deposit records and monitor unliquidated entries.

Can Antidumping Duties Be Included in a Drawback Claim?

No. Antidumping and countervailing duties are excluded from drawback under 19 U.S.C. 1677h. Ordinary customs duties paid on the same entry may remain eligible if the merchandise and subsequent export, destruction, or manufacturing activity satisfy the applicable drawback requirements.

How Stable Software Can Help

Broker-Controlled Duty Drawback Operations

The amended steel rates reinforce the need to keep antidumping deposits separate from ordinary duties that may qualify for drawback. Stable Software's DrawbackAI platform provides flat-license duty drawback software that U.S. customs brokers can white-label for importer clients. Brokers retain the client relationship and file claims under their own filer code.

Stable Software charges a flat software license and never takes a percentage of the refund. For brokers supporting importers with complex steel entries, this model can provide a clear foundation for managing drawback work while preserving the necessary separation between non-drawback-eligible AD/CVD amounts and potentially eligible ordinary customs duties.

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