Taiwan PET Film Antidumping Review: Nan Ya Margin Set at 3.95%, Partial Rescission Planned

The Taiwan PET film antidumping review has produced a 3.95% preliminary weighted-average dumping margin for Nan Ya Plastics Corporation. For importers and customs brokers, the result requires careful deposit planning, entry-level exposure analysis, and continued monitoring of the intended partial rescission involving SMTC/SSFC.

What the Preliminary Taiwan PET Film Results Mean

Nan Ya Received a 3.95% Preliminary Margin

The U.S. Department of Commerce preliminarily determined that Nan Ya made sales of polyethylene terephthalate film, sheet, and strip from Taiwan at less than normal value. The review covers entries during the period from July 1, 2024, through June 30, 2025, under antidumping case A-583-837.

Nan Ya’s preliminary weighted-average dumping margin is 3.95%. This is the principal published rate from the preliminary results and will shape importers’ estimates of potential duty exposure while the administrative review proceeds toward a final determination.

The reviewed merchandise is generally described as PET film from Taiwan, but product descriptions alone should not be used to make scope decisions. Importers should continue to compare physical specifications, commercial documentation, country of origin, producer identity, and applicable scope language. A product marketed simply as polyester film may require a more detailed analysis before an antidumping case is declared on an entry.

Preliminary Results Are Not Final Assessment Instructions

The 3.95% margin is preliminary. It does not, by itself, establish the final antidumping duty assessment for reviewed entries. Commerce may revise calculations after considering case briefs, rebuttal arguments, factual issues, or other matters addressed before the final results.

Importers should therefore treat the preliminary margin as a material exposure indicator rather than a completed duty determination. Finance and compliance teams can use it to update accrual assumptions, but they should preserve the ability to adjust those assumptions when final results and liquidation instructions become available. Customs brokers should likewise distinguish the preliminary result from an immediately actionable instruction issued through U.S. Customs and Border Protection systems.

Cash Deposit and Entry Management for Nan Ya Imports

Separate Preliminary Analysis From Deposit Execution

A preliminary dumping margin does not typically replace the existing cash deposit rate immediately. In administrative reviews, revised cash deposit requirements generally become effective prospectively when final results are published and corresponding operational instructions are implemented. Importers and brokers should not change entry filing configurations solely because a preliminary result has been announced unless an effective instruction requires that change.

Once an updated requirement becomes effective, it generally applies to subject merchandise entered or withdrawn from warehouse for consumption on or after the relevant publication date. It does not ordinarily rewrite the deposit declared on earlier entries. The final assessment of entries made during the period of review is a separate process that generally occurs after final results and liquidation instructions.

This distinction matters because three different values may be involved:

• The cash deposit rate in effect when merchandise is entered
• The preliminary margin calculated during the administrative review
• The final assessment rate used to liquidate reviewed entries

Treating these values as interchangeable can produce incorrect entry summaries, misstated duty accruals, and avoidable post-entry work.

Build a Controlled Rate-Change Process

PET film importers should identify all active and anticipated entries associated with Nan Ya, including direct purchases and transactions involving trading companies or intermediaries. Producer and exporter combinations should be validated at the purchase-order, commercial-invoice, and entry-summary levels.

Brokers should maintain effective-date controls in their tariff and antidumping duty databases. Any future rate update should be tested against entry date, warehouse withdrawal date, producer, exporter, country of origin, and case number. Importers should also confirm that landed-cost models do not automatically apply the 3.95% preliminary margin to entries outside the reviewed period or before an updated deposit requirement becomes effective.

Why the SMTC/SSFC Partial Rescission Matters

No Reviewable Entries Were Identified

Shinkong Materials Technology Corporation and Shinkong Synthetic Fiber Corporation are being treated as a single entity, referred to as SMTC/SSFC. Commerce preliminarily found that the entity had no reviewable entries during the July 1, 2024, through June 30, 2025 period of review. It also preliminarily found no suspended entries for SMTC/SSFC during that period.

Commerce therefore intends to rescind the administrative review in part with respect to SMTC/SSFC. If that conclusion remains unchanged, Commerce would not calculate a review-specific dumping margin for the entity for this period.

Partial rescission is procedurally different from a zero or de minimis dumping margin. It generally means there were no qualifying entries to review, not that reviewed sales were examined and found to carry no dumping liability. Compliance records should preserve that distinction.

Rescission Does Not Remove the Antidumping Order

Importers should not interpret the intended partial rescission as removing SMTC/SSFC merchandise from the antidumping duty order. It does not necessarily change scope coverage, establish a new exclusion, or eliminate deposit requirements for future subject entries.

The practical question is whether an importer has entries that conflict with the no-entry finding. Companies that imported merchandise represented as produced or exported by SMTC/SSFC during the period should reconcile their records against entry summaries, manufacturer identification codes, commercial invoices, bills of lading, and suspended-entry reports.

Discrepancies may arise from incorrect producer declarations, exporter and producer confusion, timing differences, scope treatment, or merchandise entered under another company’s identity. Any inconsistency should be investigated promptly because a no-shipment or no-entry finding can expose weaknesses in supplier master data and antidumping declaration controls.

Operational Priorities Before the Final Results

Reconcile the Entire Period of Review

The period of review spans July 1, 2024, through June 30, 2025. Importers should create a complete population of PET film entries from Taiwan during those dates and segment them by producer, exporter, importer of record, entry date, entry number, deposit rate, entered value, and current liquidation status.

For Nan Ya entries, the 3.95% preliminary margin can support a scenario-based exposure calculation. The model should compare deposited duties with estimated liability at the preliminary margin while clearly labeling the result as provisional. Finance teams should avoid releasing reserves solely on the basis of preliminary calculations.

For SMTC/SSFC, the reconciliation should focus on whether any entry data appears inconsistent with Commerce’s preliminary finding of no reviewable or suspended entries. Brokers should give importers enough entry-level detail to determine whether producer and exporter identities were correctly reported.

Monitor Timing and Preserve Audit Support

The proceeding experienced deadline adjustments associated with the Federal Government shutdown, including tolling periods of 47 days and an additional 21 days. The preliminary-results deadline was later extended to September 30, 2026, followed by publication on October 2, 2026. These timing changes do not alter the period of review, but they extend the time during which entries may remain unresolved.

Importers should retain purchase orders, invoices, product specifications, scope analyses, origin records, entry packets, deposit calculations, and communications confirming producer identity. Records should connect each customs declaration to the underlying transaction rather than relying only on summary reports.

Customs brokers should also document who approved any future rate change, the effective date used, the affected producer-exporter combinations, and the entries tested after implementation. A controlled change log is particularly important when a preliminary margin, final margin, assessment rate, and deposit rate may appear in internal systems at different times.

Frequently Asked Questions

What Is Nan Ya’s Preliminary Dumping Margin for Taiwan PET Film?

Commerce calculated a preliminary weighted-average dumping margin of 3.95% for Nan Ya Plastics Corporation. The calculation covers the administrative review period from July 1, 2024, through June 30, 2025. Because the result is preliminary, it may change before the final determination.

Should Brokers Immediately Apply the 3.95% Rate to New Entries?

Generally, no. A preliminary administrative review result does not typically instruct brokers to replace the current cash deposit rate immediately. Updated deposit requirements generally become effective prospectively following final results and applicable implementation instructions. Brokers should verify the effective requirement before changing entry software or declaring a different deposit rate.

Does the 3.95% Margin Determine Duties Owed on Every Nan Ya Entry?

Not necessarily. The preliminary weighted-average margin is not automatically the final assessment amount for every entry. Final liquidation may depend on Commerce’s final calculations, assessment methodology, importer-specific information, and subsequent liquidation instructions. Importers should model exposure without treating the preliminary percentage as a completed liquidation result.

Why Does Commerce Intend to Rescind the Review for SMTC/SSFC?

Commerce preliminarily found that SMTC/SSFC had no reviewable entries and no suspended entries during the period of review. As a result, it intends to rescind the review in part for that entity. This is not equivalent to calculating a zero dumping margin, and it does not remove future subject merchandise from the order.

What Should an Importer Do if Its Records Show SMTC/SSFC Entries?

The importer should reconcile those records immediately. It should verify producer and exporter names, manufacturer identification codes, entry dates, case declarations, scope treatment, and whether the entries remained suspended. The customs broker’s entry data should be compared with commercial and logistics records to identify naming errors, role confusion, or other reporting discrepancies.

What Is the Difference Between a Cash Deposit and an Antidumping Duty Assessment?

A cash deposit is security collected when subject merchandise enters U.S. commerce. The final antidumping duty assessment determines the liability used to liquidate reviewed entries. The amount deposited and the amount ultimately assessed can differ, potentially creating an additional duty bill or a refund opportunity.

How Stable Software Can Help

Support Duty Recovery Without Percentage-Based Fees

Administrative reviews can eventually produce refunds when final antidumping duty assessments are lower than the deposits paid at entry. Customs brokers need a disciplined way to evaluate and manage drawback opportunities across importer clients while maintaining control of their filing relationships.

Stable Software makes DrawbackAI, flat-license duty drawback software that U.S. customs brokers can white-label for importer clients and use to file under their own filer codes. Stable Software charges a flat software license and never takes a percentage of the refund. This structure allows brokers to build duty drawback services around their own compliance processes and client relationships without surrendering a share of importer recoveries.

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