November 2026 AD/CVD Sunset Reviews Explained

The November 2026 sunset reviews place several long-standing and newer AD/CVD orders at a critical five-year checkpoint. Importers, customs brokers, and domestic producers should act now to manage participation deadlines, preserve accurate deposit treatment, and model both continuation and revocation outcomes for affected supply chains.

Products and AD/CVD Orders Under Review

The reviews cover mobile access equipment and subassemblies from China, potassium permanganate from China, and polyester textured yarn from four Southeast Asian countries. Although these products serve very different industries, each review requires affected businesses to evaluate current imports, historic entries, supplier relationships, and exposure to antidumping or countervailing duty deposits.

Mobile Access Equipment From China

Mobile access equipment, commonly abbreviated as MAE, is subject to both an antidumping duty order and a countervailing duty order. The relevant case references are A-570-139 for antidumping duties and C-570-140 for countervailing duties. The corresponding International Trade Commission investigations are 731-TA-1557 and 701-TA-665.

These are the first sunset reviews of the MAE orders. The countervailing duty order dates to December 10, 2021, while the antidumping duty order dates to April 14, 2022. Importers should pay close attention to product scope language because subassemblies may be covered even when they are not imported as complete machines.

Potassium Permanganate and Polyester Textured Yarn

The antidumping duty order on potassium permanganate from China, A-570-001, is undergoing its sixth sunset review. The order has been in place since January 31, 1984, making it substantially older than the other measures in this review cycle.

The polyester textured yarn reviews cover Indonesia, A-560-838, Malaysia, A-557-823, Thailand, A-549-843, and Vietnam, A-552-832. These are the first sunset reviews of the yarn orders, which took effect on December 14, 2021. Importers should review country of origin support, product specifications, and scope determinations before assuming that a particular yarn falls outside an order.

Key Commerce and ITC Filing Deadlines

Commerce initiated the five-year reviews on October 27, 2026, with publication scheduled for November 2, 2026. The ITC reviews are also instituted effective November 2. Because sunset proceedings move on compressed schedules, interested parties should establish internal ownership before the first filing deadline arrives.

Commerce Participation Deadlines

Domestic interested parties generally must file a notice of intent to participate within 15 days after publication. Based on the November 2 publication date, that deadline is November 17, 2026. If no qualifying domestic interested party files a timely notice for an order, Commerce generally revokes that order without completing the usual sunset analysis.

Complete substantive responses are due within 30 days after publication, making December 2, 2026 the operative deadline. These submissions typically address whether dumping or subsidization would be likely to continue or recur if the order were revoked. Parties should follow the applicable filing, service, certification, and business proprietary information requirements rather than treating the response as a routine business letter.

ITC Review Schedule

Responses to the ITC are also due December 2, 2026. Comments addressing the adequacy of the responses are due January 12, 2027. The ITC then determines whether to conduct a full review or an expedited review.

A full review generally involves a more extensive evidentiary process. An expedited review may occur when participation is limited or responses are considered inadequate. Commerce and the ITC perform different functions, so participation before one agency does not eliminate the need to evaluate obligations before the other. No additional sunset reviews are scheduled for initiation in December 2026, but that does not change the deadlines for the November proceedings.

Operational Implications for Importers and Brokers

A sunset review does not suspend an AD/CVD order or immediately change the applicable cash deposit rate. Importers must continue depositing estimated antidumping and countervailing duties at the rates in effect when entries are made, unless and until the government issues instructions implementing a different result.

Continue Applying Current Deposit Requirements

Importers should not remove AD/CVD indicators from entry instructions merely because an order is under review. Brokers should continue applying the relevant case numbers, exporter or producer combinations, and deposit rates supported by current instructions. Entry teams should also preserve documentation showing how the applicable rate was selected.

This is particularly important when merchandise may be covered as a subassembly, when product descriptions are commercially broad, or when the exporter is not the producer. A sunset proceeding is not a substitute for a scope analysis. Product engineering details, composition, dimensions, manufacturing records, and country of origin evidence may all remain relevant.

Model Continuation and Revocation Scenarios

Trade directors should plan for both possible outcomes. If an order is continued, the existing AD/CVD framework generally remains in place and may be reviewed again in a later five-year cycle. Importers may still face rate changes through separate administrative reviews, new shipper reviews, scope proceedings, or other case activity.

If an order is revoked, the practical effect depends on the effective date and implementation instructions. Revocation should not be treated as an automatic refund of every deposit associated with prior entries. Liquidation status, period of entry, administrative review coverage, and agency instructions can affect the final treatment.

Procurement teams should therefore compare landed cost under continuation and revocation scenarios. That analysis should include deposit exposure, working capital, supplier viability, origin risk, and the possibility that sourcing changes could introduce new classification or compliance issues.

Duty Drawback Treatment of AD/CVD Entries

Duty drawback requires careful handling when an import entry includes both ordinary customs duties and AD/CVD amounts. The different duty categories should not be combined into a single recoverable duty figure because antidumping and countervailing duties are not eligible for drawback under 19 U.S.C. 1677h.

Separate Ineligible AD/CVD From Eligible Duties

The drawback exclusion applies even if the imported merchandise is later exported, destroyed, or used in manufacturing exported merchandise. An importer cannot recover the AD/CVD portion through a drawback claim merely because the underlying transaction otherwise supports unused merchandise, manufacturing, or another drawback provision.

Ordinary customs duties paid on the same entry may still qualify. Eligibility generally depends on the type of drawback claim, the relationship between imported and exported merchandise, applicable time limits, recordkeeping, and satisfaction of all other statutory and administrative requirements.

For example, an entry involving polyester textured yarn may include ordinary customs duty and a separate antidumping duty deposit. If qualifying merchandise is later exported or used in an eligible manufacturing process, the ordinary duty may potentially enter the drawback calculation. The antidumping duty amount must remain excluded.

Build Clean Duty Data Into Claim Preparation

Importers and customs brokers should retain duty amounts by entry line, duty type, case number, and relevant merchandise. Data controls should prevent AD/CVD deposits from flowing into the drawback value attributed to ordinary customs duties.

This separation also supports financial reporting and post-entry review. A business may carry substantial AD/CVD deposits while simultaneously pursuing drawback on eligible ordinary duties. Maintaining distinct records reduces the risk of overstated drawback claims and gives compliance teams a clearer view of contingent AD/CVD exposure.

Frequently Asked Questions

What Is a Five-Year Sunset Review?

A sunset review evaluates whether revoking an AD or CVD order would likely lead to the continuation or recurrence of dumping, subsidization, and material injury. Commerce generally evaluates dumping or subsidy considerations, while the ITC evaluates injury considerations. An order is typically continued when the required findings support continuation.

Do Importers Stop Paying AD/CVD During the Review?

No. Importers must generally continue paying cash deposits at the current applicable rates while a sunset review is pending. The initiation of a review does not itself suspend the order, change deposit rates, or authorize brokers to remove AD/CVD case information from entries.

Can Importers Participate in These Reviews?

Importers may qualify as interested parties and may have opportunities to submit responses, depending on the proceeding and applicable requirements. Participation decisions should consider legal strategy, sourcing interests, access to supporting data, filing deadlines, and the potential business effect of continuation or revocation.

What Happens if Domestic Producers Do Not Participate?

If no qualifying domestic interested party files a timely notice of intent to participate with Commerce, the affected order is generally revoked. Domestic producers supporting an order should therefore treat the November 17, 2026 deadline as a critical compliance date.

Does Revocation Automatically Refund Prior Cash Deposits?

Not necessarily. The treatment of prior entries depends on the effective date of revocation, liquidation status, review periods, and implementation instructions. Importers should not record a refund receivable solely because a sunset review may result in revocation.

Are AD/CVD Deposits Eligible for Duty Drawback?

No. Antidumping and countervailing duties are excluded from drawback under 19 U.S.C. 1677h. Ordinary customs duties paid on the same entries may still qualify if the exportation, destruction, manufacturing, timing, and documentation requirements for the relevant drawback claim are satisfied.

How Stable Software Can Help

Keep Drawback Calculations Separate From AD/CVD Exposure

Entries subject to AD/CVD can still contain ordinary customs duties that may qualify for drawback, but the recoverable and nonrecoverable amounts must remain clearly separated. DrawbackAI is flat-license duty drawback software that U.S. customs brokers can white-label for importer clients and use to file claims under their own filer code.

Stable Software charges a flat software license and never takes a percentage of the refund. For brokers serving importers affected by the November 2026 sunset reviews, this model supports a clear division between AD/CVD compliance and eligible drawback activity without tying software cost to claim value. Brokers evaluating how to manage eligible ordinary duties alongside significant AD/CVD deposits can explore whether DrawbackAI fits their service model.

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