The first boltless steel shelving antidumping review for Thailand has produced a potentially significant result for Fuding Industries Company Limited. Although Commerce preliminarily calculated a 0.00% dumping margin, importers, brokers, and finance teams must continue distinguishing a favorable preliminary calculation from a final assessment and cash deposit change.
What the Preliminary 0.00% Margin Means
Fuding did not receive a final zero rate
Commerce preliminarily determined that Fuding Industries Company Limited did not sell subject boltless steel shelving below normal value during the period of review. The resulting weighted-average dumping margin is 0.00% for the period from November 29, 2023, through May 31, 2025.
This result is commercially important, but it is not yet final. Interested parties generally have an opportunity to submit case briefs, rebuttal briefs, and hearing requests before Commerce completes the administrative review. Arguments raised during that process can affect the calculations, methodology, or final dumping margin.
Importers should therefore avoid treating the preliminary result as an immediate refund authorization. Entries remain subject to the administrative review process, and liquidation generally remains suspended until Commerce issues final results and corresponding assessment instructions.
Current cash deposits remain unchanged
A preliminary margin does not ordinarily replace the cash deposit rate currently applied by U.S. Customs and Border Protection. Fuding's deposit requirements remain governed by the rate already in effect until the final results establish a new company-specific rate.
If the final weighted-average margin remains zero or de minimis, covered Fuding entries from the review period would generally liquidate without antidumping duties. Fuding's prospective cash deposit rate would also become zero after the final results take effect. Until then, importers should continue depositing antidumping duties as required at entry.
The all-others cash deposit rate remains 2.75%. Companies without an applicable company-specific rate should not assume that Fuding's preliminary result changes their treatment.
Partial Rescission Requires Company-Level Analysis
Five companies had no reviewable suspended entries
Commerce rescinded the review for ABC Tools Mfg. Corp., Bangkok Sheet Metal Public Co., Ltd., Great Star Industries, Pengdong Electromechanical (Thailand) Co., Ltd., and Thai First Precision Industry Company Limited. The rescission reflects the absence of reviewable suspended entries for those companies during the relevant period.
Rescission is procedurally different from receiving a calculated zero margin. Commerce did not calculate new dumping margins for these five companies. Their applicable entries are generally assessed at the cash deposit rate in effect on the date of entry. Rescission instructions are expected no earlier than 35 days after the October 19, 2026 applicability date, which places the earliest expected instruction date on November 23, 2026.
Importers should not classify these companies as zero-rate suppliers. A rescission typically preserves entry-specific treatment based on the deposit rate that applied when the merchandise entered.
Supplier names must match entry records
Trade compliance teams should reconcile supplier, producer, exporter, and manufacturer data at the entry-line level. Commercial naming conventions, affiliated entities, abbreviated names, and intermediary transactions can create mismatches between purchasing records and customs documentation.
The analysis should determine whether the merchandise was produced and exported by Fuding, involved one of the rescinded companies, or falls under another rate category. That determination may require reviewing commercial invoices, manufacturer identification data, purchase orders, entry summaries, and broker instructions.
Company-specific antidumping treatment generally depends on the precise producer-exporter facts. A buyer's internal supplier label is not sufficient when customs records identify a different exporter or intermediary. Accurate entity mapping is therefore essential for forecasting liquidation outcomes and potential refunds.
Importers Must Separate Assessment and Deposit Exposure
Historical assessments and future deposits serve different purposes
Antidumping administrative reviews affect two related but distinct obligations. The assessment rate determines the antidumping duties ultimately owed on covered entries during the period of review. The cash deposit rate applies prospectively to qualifying entries made after final results establish a new rate.
For Fuding, a final zero or de minimis margin would generally produce two favorable outcomes. Covered review-period entries could liquidate without antidumping duties, potentially generating refunds of deposited amounts. Future qualifying entries could also enter with a zero antidumping cash deposit rate, subject to the applicable producer-exporter combination and any subsequent administrative developments.
Neither outcome is available solely because of the preliminary calculation. Importers should maintain existing deposit practices until final results are published and implemented.
Intermediary sales can change liquidation treatment
Fuding-produced merchandise sold through an intermediary requires additional scrutiny. When Fuding did not know that the merchandise was destined for the United States, entries may be subject to the reseller policy rather than Fuding's calculated rate.
If the intermediary has its own applicable rate, that rate may govern. If no intermediary-specific rate exists, the entries may liquidate at the investigation all-others rate, which is 2.75%. Consequently, evidence that the producer knew the U.S. destination can materially affect assessment treatment.
Importers and brokers should retain purchase orders, shipping instructions, customer communications, destination details, and other transaction records that establish the supply-chain facts. They should also avoid applying Fuding's preliminary margin broadly to every entry involving Fuding-manufactured goods. Producer identity, exporter identity, intermediary involvement, and knowledge of destination should all be evaluated before estimating the final liability.
Financial Planning and Drawback Treatment
Potential refunds should be modeled conservatively
Finance teams can model the potential recovery of antidumping deposits on eligible Fuding entries, but the model should remain contingent until the final results and liquidation instructions are issued. A useful entry-level schedule generally includes the entry number, entry date, entered value, producer, exporter, deposited antidumping amount, liquidation status, and estimated refund.
The forecast should distinguish principal from possible interest and account for entries that may be excluded because of intermediary sales, incorrect company identification, or a period-of-review mismatch. It should also separate review-period entries from later entries covered by a subsequent administrative review.
Importers should monitor liquidation status carefully. Premature liquidation, data discrepancies, or incorrect rate application can create protest and correction issues with strict deadlines. Brokers can support this process by preserving rate instructions, checking entry data, and communicating changes only after final instructions become operational.
AD and CVD deposits must remain outside drawback claims
Antidumping and countervailing duties are not eligible for duty drawback under 19 U.S.C. 1677h. A favorable administrative review may return AD deposits through liquidation, but that return is not a drawback refund.
Ordinary customs duties paid on the same entry can still be eligible for drawback when the imported merchandise is subsequently exported or destroyed and the claim satisfies the applicable requirements. Drawback calculations must therefore separate ordinary duties from antidumping and countervailing duty amounts.
This distinction is especially important when a single entry includes ordinary customs duty, merchandise processing fees, and AD or CVD deposits. Claim data should classify each amount correctly rather than treating the total payment as drawback-eligible duty. Maintaining this separation supports accurate claim calculations, reduces overclaim risk, and keeps potential AD refunds distinct from drawback recoveries.
- Commerce published preliminary results of the first AD administrative review on boltless steel shelving from Thailand on October 19, 2026 (91 FR 66080).* Fuding Industries Company Limited, the mandatory respondent, received a 0.00 percent weighted-average dumping margin for the POR of November 29, 2023, through May 31, 2025. The review was rescinded for five companies with no reviewable suspended entries. These results are preliminary. Cash deposit rates remain unchanged until final results are issued. The all-others rate stays at 2.75 percent. Interested parties may comment.
- CBP issued automatic liquidation instructions (message 6264414) dated September 21, 2026, covering the subsequent POR of June 1, 2025, through May 31, 2026.* Entries for most companies are to be liquidated at the cash deposit rate in effect at entry. Liquidation remains suspended for several firms, including Fuding Industries Company Limited and Bangkok Sheet Metal Public Co., Ltd.
- The U.S. initiated the next administrative review of the Thailand order around August 10, 2026, covering June 1, 2025, to May 31, 2026.* Thai authorities noted that producers or exporters with no shipments during that period could request rescission within 30 days. Final results for that review are due by June 30, 2027.
- In a related development for the same product, Commerce continued the AD and CVD orders on boltless steel shelving from China on or about October 8-14, 2026, after the second sunset review.* Revocation would likely lead to continued dumping, subsidies, and material injury. The orders remain in effect from September 29, 2026.
- No notable practitioner discussions on X were identified in the recent period. Fuding continues active U.S. shipments of the merchandise, with records through August 2026.
Frequently Asked Questions
Does Fuding's 0.00% preliminary margin eliminate current deposits?
No. The preliminary margin does not immediately alter Fuding's cash deposit requirement. Importers should continue using the currently applicable rate until Commerce publishes final results and the new rate becomes effective. CBP implementation also depends on formal cash deposit and liquidation instructions.
Could importers receive refunds on Fuding entries?
Yes, potentially. If Fuding's final margin remains zero or de minimis, covered entries from November 29, 2023, through May 31, 2025, would generally liquidate without antidumping duties. Deposits associated with qualifying entries could then be refunded, typically with applicable interest. Actual treatment depends on entry facts and final instructions.
Does the 0.00% margin apply to all Thai shelving suppliers?
No. The calculation is specific to Fuding and the transactions covered by the review. The all-others cash deposit rate remains 2.75%, and the five rescinded companies generally retain assessment treatment based on the deposit rate in effect when their entries were made.
What is the deadline for requesting a hearing?
Hearing requests are generally due within 30 days of the October 19, 2026 publication date. Based on that calculation, the expected deadline is November 18, 2026. Parties should verify procedural deadlines and filing requirements before submitting comments or requesting a hearing.
Are antidumping duties eligible for duty drawback?
No. Antidumping and countervailing duties are excluded from drawback. Ordinary customs duties paid on the same entries may still qualify if the merchandise is exported or destroyed and all drawback requirements are met. Drawback records should clearly exclude AD and CVD amounts from the claimed duty calculation.
What should brokers do before final results are issued?
Brokers should preserve current deposit treatment, identify entries involving Fuding or the rescinded companies, verify producer-exporter combinations, and flag intermediary sales. They should also help importer clients build entry-level exposure schedules while making clear that preliminary results do not authorize immediate refunds or deposit changes.
How Stable Software Can Help
Keep drawback calculations separate and controlled
The Thailand shelving review illustrates why importers and brokers must separate ordinary customs duties from non-drawback-eligible AD and CVD amounts. Stable Software's DrawbackAI gives U.S. customs brokers a duty drawback software platform they can white-label for importer clients and use to file under their own filer code.
Stable Software charges a flat software license and never takes a percentage of the refund. For brokers managing claims involving entries with multiple duty components, this model supports a clear division between software cost and client recovery. Brokers evaluating ordinary-duty drawback opportunities alongside antidumping exposure can explore whether DrawbackAI fits their filing operation and client service model.
Resources
| Type | Resource |
|---|---|
| Source | Primary source |
