AD/CVD administrative reviews for September anniversary orders create immediate obligations for affected exporters and meaningful financial exposure for U.S. importers. Separate rate deadlines arrive quickly, while final duty liability may remain unresolved until September 2027, making supplier coordination and entry-level controls essential.
What Commerce Initiated and Which Orders Are Covered
Commerce initiated administrative reviews on November 2, 2026, for antidumping and countervailing duty orders with September anniversary dates. Publication is scheduled for November 5, 2026, and final results are intended no later than September 30, 2027.
Most antidumping periods of review cover entries made from September 1, 2025, through August 31, 2026. Most countervailing duty reviews cover calendar year 2025. Importers should verify the applicable period for each order rather than assume that every product follows the general timeframe.
Antidumping Duty Orders Under Review
The antidumping duty reviews cover a broad range of products and countries, including:
- Lined paper products and mattresses from India
- Brass rod from Israel
- Heavy walled rectangular welded carbon steel pipes and tubes from Mexico, Korea, and Turkiye
- Mattresses from Mexico
- Common alloy aluminum sheet from Oman
- Oil country tubular goods from Korea and Vietnam
- Cold-rolled steel from Korea
- Frozen fish fillets from Vietnam
- Methionine from Spain
- Forged steel fittings from Taiwan
- Low speed personal transportation vehicles, magnesia carbon bricks, steel racks, and steel wheels from China
- Seamless standard, line, and pressure pipe from Ukraine
Countervailing Duty Orders Under Review
The countervailing duty reviews include common alloy aluminum sheet and lined paper products from India, brass rod from Israel, cold-rolled steel from Korea, and several products from China. The Chinese products include low speed personal transportation vehicles, steel racks, steel wheels, and narrow woven ribbons.
The initiation also corrects earlier actions by adding certain omitted cases or companies. Importers should therefore review the complete company list even if they previously assessed an earlier initiation notice. A corrected listing can change whether a supplier, exporter, or producer is subject to review.
Immediate Separate Rate and Withdrawal Deadlines
The most urgent compliance issue is the separate rate deadline for exporters from non-market economy countries, particularly China and Vietnam. A qualifying exporter may seek a rate separate from the country-wide entity rate, but the required filing must generally be complete and timely.
The 14-Day Separate Rate Filing Window
Separate rate certifications and applications are due 14 calendar days after publication of the initiation notice. If publication occurs on November 5, 2026, the expected deadline is November 19, 2026.
This deadline is especially important because a foreign supplier's separate rate status can materially affect the antidumping duty rate ultimately assigned to reviewed entries. Importers should not assume that a supplier, producer, or exporter will handle the process without prompting. They should confirm:
- Whether the exporter is named in the review.
- Whether it previously received a separate rate.
- Whether it qualifies to submit a certification or must file an application.
- Who is responsible for preparing and submitting the filing.
- Whether sales and shipment records support the representations being made.
Applications related to eligibility for the certification process are generally due 30 calendar days after publication. Because eligibility and separate rate procedures can differ based on a company's history, exporters should evaluate the correct filing path immediately.
Review Withdrawal Deadline
A party that requested a review may generally withdraw its request within 90 days after publication. Based on the scheduled publication date, that period is expected to end on February 3, 2027.
Withdrawal can affect whether a company remains under review, but it does not automatically eliminate exposure in every situation. Multiple parties may have requested review of the same company, and Commerce may continue a review when another valid request remains in place. Importers should therefore monitor the official case status rather than rely solely on a supplier's stated intention to withdraw.
Importer Controls Through the Final Results
An administrative review determines the actual antidumping or countervailing duty assessment rate for entries made during the applicable period of review. Cash deposits made at entry are provisional. Final liability may be higher or lower after the review is completed and liquidation instructions are issued.
Build an Entry-Level Exposure File
Importers should identify all potentially affected entries and preserve a reliable link among the importer, exporter, producer, product, case number, entry date, entered value, and cash deposit amount. The review population should generally include unliquidated entries within the applicable period, including entries that may have been filed by multiple brokers or through different ports.
A practical review file should contain:
- Entry summaries and associated line data
- Commercial invoices and purchase orders
- Manufacturer and exporter identities
- Antidumping and countervailing duty case numbers
- Cash deposit rates and amounts
- Product descriptions and scope support
- Liquidation status and suspension indicators
- Supplier communications concerning review participation
Importers should also reconcile the supplier named on customs documentation against the company named in the administrative review. Similar legal names, trading companies, affiliates, and producer-exporter combinations can create material classification and rate-assignment risks.
Monitor Liability Beyond the Entry Date
Commerce intends to issue final results by September 30, 2027, but administrative timelines can change. Importers should keep affected entries visible in their compliance systems until liquidation is complete.
Financial planning should account for the possibility of additional duty assessments, interest, or a lower final rate. Broker records, customs data, and accounts payable information should be reconciled so that management can evaluate exposure by supplier and product line. Importers may also need contractual clarity regarding whether suppliers will reimburse additional duties, although contractual recovery does not change the importer's obligations to U.S. Customs and Border Protection.
Duty Drawback Treatment for Reviewed Entries
The presence of antidumping or countervailing duties does not make an entry entirely unusable for duty drawback. It does, however, require careful separation of ineligible AD/CVD amounts from ordinary customs duties that may qualify for a refund.
AD/CVD Amounts Are Not Eligible for Drawback
Under 19 U.S.C. 1677h, antidumping and countervailing duties are not eligible for drawback. An importer cannot include those amounts in a drawback refund calculation, even when the imported merchandise is later exported or destroyed.
Ordinary customs duties paid on the same entry may still qualify when the merchandise is exported or destroyed, or when it is used to manufacture an exported article, provided the claim satisfies the applicable drawback requirements. The key control is to prevent AD/CVD cash deposits and final assessments from being treated as eligible ordinary duty.
Segregate Duties at the Entry-Line Level
Drawback filers should maintain separate fields for ordinary customs duty, antidumping duty, countervailing duty, and other fees. This distinction becomes especially important when an administrative review changes the final AD/CVD assessment after a drawback claim has been prepared or filed.
Importers and customs brokers should consider the following controls:
- Match imports and exports using duty amounts that exclude AD/CVD.
- Retain the AD/CVD case number and rate as separate reference data.
- Track liquidation status for reviewed entries.
- Prevent revised AD/CVD assessments from entering the drawback-eligible duty pool.
- Reconcile broker data against customs records before claim submission.
A conservative approach that excludes the entire entry from drawback may leave eligible ordinary duty unrecovered. The more accurate approach is generally to preserve the entry's eligible ordinary duty while expressly excluding antidumping and countervailing duty amounts.
- On November 2, 2026, Commerce initiated administrative reviews of AD and CVD orders with September anniversary dates (FR Doc. 2026-22629), with publication scheduled for November 5, 2026. Final results are intended by September 30, 2027. Most AD periods of review cover September 1, 2025, through August 31, 2026.
- Separate rate applications or certifications (for NME-country exporters such as those from China or Vietnam seeking individual rates rather than the country-wide rate) are due 14 days after Federal Register publication of the initiation notice.
- AD orders under review include lined paper products and mattresses from India, brass rod from Israel, heavy walled rectangular welded carbon steel pipes and tubes from Mexico, Korea, and Turkiye, mattresses from Mexico, common alloy aluminum sheet from Oman, oil country tubular goods from Korea and Vietnam, cold-rolled steel from Korea, frozen fish fillets from Vietnam, methionine from Spain, forged steel fittings from Taiwan, low speed personal transportation vehicles, magnesia carbon bricks, steel racks, and steel wheels from China, and seamless standard, line, and pressure pipe from Ukraine.
- CVD orders under review include common alloy aluminum sheet and lined paper from India, brass rod from Israel, cold-rolled steel from Korea, and low speed personal transportation vehicles, steel racks, steel wheels, and narrow woven ribbons from China.
- Related activity in the same period includes Commerce’s November 2, 2026, notice of opportunity to request administrative reviews of orders with November anniversary dates (requests due by November 30, 2026) and initiation of certain five-year sunset reviews. No notable practitioner discussions of the September-anniversary initiations were identified on X.
Frequently Asked Questions
What Is an AD/CVD Administrative Review?
An administrative review generally determines the actual antidumping or countervailing duty assessment rate for covered entries during a defined period. The resulting rate may differ from the cash deposit rate in effect when the goods entered the United States.
When Is the Separate Rate Deadline?
For this initiation, separate rate certifications and applications are due 14 calendar days after publication. Assuming publication on November 5, 2026, the expected deadline is November 19, 2026. Exporters should confirm the applicable filing requirements and should not wait until the final day.
Which Importers Should Investigate Their Entries?
Importers of the listed products should investigate if entries were supplied by a producer or exporter named in the review. Particular attention should be given to entries from China and Vietnam where separate rate status may affect exposure to a country-wide antidumping rate.
Can Review Requests Be Withdrawn?
A requesting party may generally withdraw a review request within 90 days after publication, making February 3, 2027, the expected deadline. A withdrawal may not end the review if another party submitted a valid request covering the same company.
Are Antidumping and Countervailing Duties Eligible for Drawback?
No. AD/CVD amounts are not eligible for drawback. Ordinary customs duties on the same entry may still qualify if the merchandise and transaction satisfy the applicable drawback requirements and the ineligible AD/CVD amounts are excluded.
Why Must Importers Track Unliquidated Entries?
Cash deposits are not necessarily the final liability. Tracking unliquidated entries allows an importer to monitor potential additional assessments, identify liquidation activity, preserve supporting records, and keep drawback calculations aligned with eligible ordinary duties.
How Stable Software Can Help
Protect Eligible Drawback Without Including AD/CVD
Administrative reviews increase the importance of accurate duty segregation and entry-level records. DrawbackAI is flat-license duty drawback software that U.S. customs brokers can white-label for importer clients and use to file claims under the broker's own filer code.
Stable Software charges a flat software license and never takes a percentage of the refund. For brokers managing entries that include both ordinary customs duty and ineligible AD/CVD amounts, a structured drawback process can help preserve eligible recovery while keeping antidumping and countervailing duties outside claim calculations. Customs brokers evaluating how to support importer clients can explore DrawbackAI as part of their drawback service strategy.
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