Paper Shopping Bags Antidumping Review Results

Preliminary results in the first paper shopping bags antidumping review create sharply different outcomes for Cambodian and Taiwanese suppliers. Importers now need to evaluate supplier-specific exposure, prepare for possible liquidation adjustments, and keep antidumping duties separate from ordinary customs duties in drawback calculations. ## Preliminary Results Create Divergent Supplier Outcomes The reviews cover entries of certain paper shopping bags from Cambodia and Taiwan during January 3, 2024 through June 30, 2025. They are the first administrative reviews following the antidumping duty orders issued on July 18, 2024, making them particularly important for importers assessing how deposited amounts may compare with eventual assessment rates. The Cambodian review, case A-555-002, produced substantial preliminary margins. Nice Packaging (Cambodia) Co., Ltd. received a 20.08% margin. Brandart S.p.A. and TB Packaging (Cambodia) Co., Ltd. also received 20.08%. UUPak Company Limited received a 73.30% margin based on total adverse facts available. ### Taiwan's Respondent Received a Zero Margin The Taiwan review, case A-583-872, produced a 0.00% preliminary weighted-average dumping margin for Haur Tyi Paper Bag Co., Ltd., the sole remaining respondent. The review was rescinded for Chung Tai Bag King Corporation, Chyan Tay International Corp., Toolsworks International Ltd., Xiamen Yasili Trade Co., Ltd., and Zheng Da Paper Industry Co., Ltd. after the applicable review requests were withdrawn. The preliminary results do not immediately change cash deposit requirements. Cambodia's all-others cash deposit rate remains 7.07%, while Taiwan's all-others rate remains 4.74%. Supplier-specific cash deposit rates generally change only after final results become effective. Importers should therefore distinguish among preliminary calculated margins, current deposit rates, and final assessment rates for reviewed entries. ## Importers Should Quantify Entry-Level Financial Exposure The Cambodian results present the most immediate financial concern, particularly for importers that purchased from UUPak. A 73.30% preliminary margin could create a significant difference between antidumping deposits made at entry and the amount ultimately assessed if the final result remains at or near that level. Importers should identify all entries during the period of review and map each entry to the producer and exporter combination reported to U.S. Customs and Border Protection. Commercial invoices, purchase orders, entry summaries, manufacturer affidavits, and broker instructions should be compared for consistency. A supplier's trade name, invoicing entity, or intermediary should not be assumed to establish entitlement to a particular rate. ### Cash Deposits Are Not Final Duty Assessments Antidumping cash deposits function as security. The final liability for reviewed entries is generally determined through the administrative review and subsequent liquidation instructions. A preliminary margin therefore does not itself establish the final amount due, but it provides a reasonable basis for evaluating contingent exposure. Importers should consider reserves for possible liquidation differences on affected 2024-2025 entries. The analysis should account for: - The antidumping deposit actually paid on each entry

• The supplier-specific preliminary margin
• The entered value subject to antidumping duties
• Potential interest associated with underpayment or overpayment
• The timing of final results and liquidation instructions Companies using Cambodian suppliers should also evaluate whether purchasing, pricing, and contract terms allocate responsibility for unexpected antidumping assessments. Taiwan importers should remain cautious as well. Haur Tyi's 0.00% result is preliminary, and rescission for other companies does not necessarily create a new zero rate for their entries. ## Compliance Controls Before Final Results and Liquidation Interested parties have a limited opportunity to address Commerce's preliminary analysis. Case briefs are due within 21 days after the applicable result was published. Rebuttal briefs are due five days after case briefs, and hearing requests are generally due within 30 days. Importers participating through counsel should organize factual records, calculation issues, and legal arguments early rather than waiting for the final stage. Importers that are not active parties still need operational controls. The final results may affect both the assessment of entries covered by the review and future cash deposits for merchandise entered after the final results become effective. ### Reimbursement Certification Requires Attention Importers should file the certification required by 19 CFR 351.402(f) before liquidation. The certification addresses whether the importer has entered into an agreement or understanding for reimbursement of antidumping duties. Failure to provide the required certification can generally lead to a presumption of reimbursement and additional assessment consequences. A disciplined response should include the following actions: 1. Compare every Cambodian and Taiwanese supplier against the reviewed company names and case numbers.

2. Confirm the producer, exporter, country of origin, and scope treatment for each entry.
3. Calculate potential exposure using entry-level entered values rather than broad purchase estimates.
4. Review contracts, credit arrangements, and post-entry payments for possible reimbursement concerns.
5. Track liquidation status and preserve supporting import records.
6. Separate antidumping duties from ordinary customs duties in all drawback datasets. These controls are especially important when a customs broker, trade counsel, finance team, and importer maintain different versions of the entry population. A single reconciled dataset allows the company to reserve accurately and respond when final assessment instructions are issued. ## Frequently Asked Questions ### Are the Cambodia and Taiwan margins final? No. The 20.08% and 73.30% Cambodian margins and the 0.00% Taiwan margin are preliminary. Commerce may revise its calculations after considering briefs, rebuttals, hearing arguments, and other issues properly raised in the proceeding. Importers should monitor the final results before treating any preliminary margin as the final assessment rate. ### Do the preliminary results change current cash deposit rates? Not immediately. The Cambodia all-others rate remains 7.07%, and the Taiwan all-others rate remains 4.74%. New supplier-specific cash deposit rates generally become effective after final results. Reviewed entries from the 2024-2025 period may later be liquidated using final assessment instructions. ### What does the 73.30% UUPak margin mean for importers? It indicates substantial potential exposure for reviewed entries associated with UUPak. Because the preliminary margin was based on total adverse facts available, importers should model the difference between deposits paid and a possible final assessment near 73.30%. The actual liability remains uncertain until final results and liquidation. ### Can antidumping duties be recovered through duty drawback? Antidumping and countervailing duties are not eligible for drawback under 19 U.S.C. 1677h. Ordinary customs duties paid on the same entries may still qualify when the merchandise is subsequently exported or destroyed and all applicable drawback requirements are met. Claim calculations should clearly exclude AD/CVD amounts. ### What is the effect of Taiwan's partial rescission? The rescission ends the administrative review for the five named companies. It does not assign those companies Haur Tyi's 0.00% preliminary margin. The treatment of their entries generally depends on the applicable cash deposit rate, liquidation instructions, and the specific producer-exporter combination reported at entry. ## How Stable Software Can Help ### Keep Drawback Calculations Separate and Controlled Antidumping exposure makes accurate duty classification within drawback claims especially important. DrawbackAI is flat-license duty drawback software that U.S. customs brokers can white-label for importer clients while filing claims under their own filer codes. Stable Software charges a flat software license and never takes a percentage of the refund. For entries containing both ordinary customs duties and antidumping duties, a structured drawback process helps brokers and importers avoid treating ineligible AD/CVD amounts as refundable duty. Customs brokers evaluating how to support importer clients can explore DrawbackAI as part of a controlled approach to identifying and claiming eligible ordinary customs duties.

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