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Ukraine OCTG Antidumping Review: 18.43% Margin

Reis Renneker

Written by Reis Renneker

The Ukraine OCTG review gives Interpipe a preliminary 18.43% margin, creating immediate reserving, certification, and drawback issues.

Ukraine OCTG Antidumping Review: 18.43% Margin

The Ukraine OCTG antidumping review has assigned Interpipe a preliminary weighted-average dumping margin of 18.43%. Although the result is not final, importers should assess potential liquidation exposure, preserve entry-level records, and separate antidumping duties from ordinary customs duties in drawback calculations.

What the 18.43% Preliminary Margin Means

The U.S. Department of Commerce released preliminary results on October 5, 2026, for the antidumping duty administrative review covering oil country tubular goods from Ukraine. The period of review runs from July 1, 2024, through June 30, 2025, under case A-823-815.

Interpipe was the only respondent examined. For purposes of the proceeding, Commerce treats Interpipe Ukraine LLC, Interpipe Europe S.A., LLC Interpipe Niko Tube, and PJSC Interpipe Niznedneprovsky Tube Rolling Plant as a single entity. That entity received a preliminary weighted-average dumping margin of 18.43%.

The review continued even though Interpipe withdrew its own request on November 19, 2025. The U.S. OCTG Manufacturers Association maintained its request, allowing the proceeding to continue. Administrative deadlines were also tolled because of the 2025 federal government shutdown, and the preliminary determination deadline was extended to September 30, 2026.

Preliminary Results Do Not Immediately Change Cash Deposits

The 18.43% margin is preliminary. It does not immediately establish a new cash deposit rate for future Interpipe entries. Cash deposit instructions generally change only after Commerce issues final results and communicates the applicable instructions to U.S. Customs and Border Protection.

The distinction between a review margin, an assessment rate, and a cash deposit rate is important. The preliminary weighted-average margin signals potential exposure, but the final liquidation amount for a particular importer may depend on importer-specific assessment calculations and Commerce's final methodology.

The all-others rate remains 7.47%. That rate can be especially relevant where Interpipe-produced merchandise reaches the United States through an intermediary and the transaction cannot be tied to an examined U.S. sale under Commerce's assessment methodology. Importers should not assume that every entry of Interpipe-manufactured merchandise will automatically receive the same assessment treatment.

Importer Exposure and Entry-Level Compliance

Importers of Ukrainian OCTG should evaluate open entries from the July 1, 2024, through June 30, 2025 review period. The preliminary result creates a reasonable basis for financial reserving, but it should not be treated as a final liquidation instruction or a guaranteed liability amount.

A disciplined review begins with entry numbers, entry dates, manufacturers, exporters, sellers, declared antidumping case numbers, deposit rates, and the current liquidation status. Importers should reconcile those fields against commercial invoices, mill certificates, purchase orders, and broker entry records. This is particularly important when products were manufactured by Interpipe but sold through trading companies or other intermediaries.

Build a Defensible Reserve

Importers may consider reserving for possible liquidation at or near the 18.43% preliminary margin, subject to their accounting policies and transaction-specific circumstances. The analysis should account for antidumping deposits already paid, the entered value used for assessment, and the possibility that final results may increase or decrease the margin.

The reserve should also distinguish between cash flow exposure and final duty expense. Existing deposits remain with the government while entries are suspended. Once final assessment instructions are issued, an importer may owe additional duties or receive a refund, generally with applicable interest.

Importers should avoid applying the 18.43% rate mechanically across all Ukrainian OCTG entries. Entries associated with a different producer, exporter, or reseller may be subject to another rate or assessment methodology. Classification scope also matters. Product descriptions, physical specifications, end use, and scope language should be reviewed before concluding that a particular tubular product is covered.

File the Non-Reimbursement Certificate Before Liquidation

Importers subject to antidumping duties generally must address the non-reimbursement certification requirement under 19 CFR 351.402(f). The certificate should be filed before liquidation and should accurately state whether the importer was reimbursed for antidumping duties by the exporter, producer, or another party.

Failure to provide the required certification can create a presumption of reimbursement and may substantially increase the assessed antidumping duty liability. Importers should confirm filing responsibility with their customs broker and trade counsel rather than assuming the certificate has already been submitted.

Deadlines, Drawback, and Immediate Action Items

Parties participating in the administrative review face several near-term procedural deadlines. On the current schedule, case briefs are due October 26, 2026, which is 21 days after publication of the preliminary results. Rebuttal briefs are due five days later. Because October 31 falls on a Saturday, that deadline generally moves to Monday, November 2, 2026.

Requests for a hearing are due within 30 days, making November 4, 2026, the expected deadline. Hearing requests should be submitted through ACCESS by 5:00 p.m. Eastern Time. Parties should verify current docket instructions and any subsequent deadline changes before filing.

Keep Antidumping Duties Out of Drawback Claims

Antidumping and countervailing duties are not eligible for duty drawback under 19 U.S.C. 1677h. Importers and drawback filers must therefore exclude OCTG antidumping duty amounts from recoverable-duty calculations, even if the imported merchandise is later exported or destroyed.

That exclusion does not necessarily eliminate all drawback opportunity associated with the entry. Ordinary customs duties paid on the same merchandise may still qualify when statutory and operational requirements are satisfied. Merchandise processing fees and other amounts require separate eligibility analysis based on the drawback provision used and the underlying transaction.

Drawback records should preserve distinct duty components rather than treating the total payment to CBP as a single recoverable amount. Entry data should separately identify ordinary customs duty, antidumping duty, countervailing duty, fees, and any other charges. This separation reduces the risk of overstating a claim and makes review easier for both the filer and the importer.

Recommended Compliance Steps

Importers, brokers, and trade compliance teams should prioritize the following actions:

  1. Identify unliquidated Ukrainian OCTG entries from July 1, 2024, through June 30, 2025.
  2. Confirm the manufacturer, exporter, seller, case number, and deposit rate for each entry.
  3. Evaluate a reserve for possible liquidation based on the 18.43% preliminary margin.
  4. Confirm that the non-reimbursement certificate will be filed before liquidation.
  5. Calendar the October 26, November 2, and November 4 procedural deadlines where participation is contemplated.
  6. Exclude antidumping and countervailing duties from drawback calculations while evaluating ordinary duty eligibility separately.
  7. Monitor the final results and subsequent CBP liquidation instructions before closing the exposure.
Recent Developments
  • On October 5, 2026, the U.S. Department of Commerce published preliminary results of the antidumping duty administrative review of oil country tubular goods (OCTG) from Ukraine (A-823-815, 91 FR 63262), covering July 1, 2024, through June 30, 2025.* Interpipe (treated as a single entity comprising Interpipe Ukraine LLC, Interpipe Europe S.A., LLC Interpipe Niko Tube, and PJSC Interpipe Niznedneprovsky Tube Rolling Plant) received a preliminary weighted-average dumping margin of 18.43 percent. The review continued at the request of the U.S. OCTG Manufacturers Association after Interpipe withdrew its own request on November 19, 2025. Deadlines were delayed due to the 2025 government shutdown and related tolling. Case briefs are due 21 days after publication. The all-others rate remains 7.47 percent. These are preliminary only.
  • The U.S. International Trade Commission completed its second five-year sunset reviews of OCTG orders from India, South Korea, Turkey, Ukraine, and Vietnam around September 24-29, 2026, determining that revocation would likely lead to continuation or recurrence of material injury to the U.S. industry.* One commissioner voted in the negative specifically regarding the Ukraine antidumping order. This followed an ITC vote in early September 2026 to keep the duties in place.
  • On October 7, 2026, Canada's International Trade Tribunal rescinded its antidumping order on OCTG from Ukraine while continuing duties (with some exceptions) for seven other sources including Chinese Taipei, India, Indonesia, South Korea, Thailand, Türkiye, and Vietnam.* This is a notable contrast to the U.S. actions.
  • Steel industry publications including SteelRadar, SteelOrbis, and GMK Center covered the U.S. preliminary determination on October 6-9, 2026, highlighting the 18.43 percent margin for Interpipe, the continued review despite Interpipe's withdrawal, and next steps for comments and final results (which will set the new cash deposit rate).* No significant practitioner discussions on X were identified in the past 30 days.
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Frequently Asked Questions

Is the 18.43% Interpipe Margin Final?

No. The 18.43% weighted-average dumping margin is a preliminary result for the July 1, 2024, through June 30, 2025 review period. Commerce may modify its calculations or methodology after considering case briefs, rebuttal briefs, hearing arguments, and other issues raised in the proceeding.

Does the Preliminary Margin Change Current Cash Deposits?

Generally, no. Preliminary administrative review results do not immediately establish a new cash deposit rate. Current deposit requirements typically remain in effect until final results are issued and CBP receives updated cash deposit instructions. Importers should continue following the rate applicable at entry unless instructed otherwise.

Why Could an Interpipe Product Receive the All-Others Rate?

Interpipe-manufactured goods sold through an intermediary may receive different assessment treatment if Commerce cannot connect the transaction to a reviewed U.S. sale or determine that Interpipe knew the merchandise was destined for the United States. Depending on the facts, the 7.47% all-others rate may apply. Transaction documentation is critical.

Can Antidumping Duties Be Recovered Through Duty Drawback?

No. Antidumping and countervailing duties are not eligible for drawback. However, ordinary customs duties paid on the same entry may remain eligible if the merchandise is exported or destroyed and all requirements of the applicable drawback provision are met. Claims must exclude the antidumping duty component.

What Happens if the Non-Reimbursement Certificate Is Not Filed?

An importer that does not timely address the certification requirement may be presumed to have received reimbursement for antidumping duties. That presumption can result in increased duty liability. Importers should confirm the certificate's accuracy, filing method, and timing before liquidation rather than waiting for assessment instructions.

How Stable Software Can Help

Keep Drawback Calculations Separate and Defensible

Ukrainian OCTG entries can contain both nonrecoverable antidumping duties and ordinary customs duties that may remain eligible for drawback. Brokers and importers therefore need clear separation between duty types when preparing claims.

DrawbackAI is Stable Software's flat-license duty drawback software. U.S. customs brokers can white-label the software for importer clients and file claims under their own filer codes. Stable Software charges a flat software license and never takes a percentage of the refund.

Customs brokers evaluating drawback opportunities involving trade remedy entries can explore DrawbackAI as part of a controlled approach to identifying eligible ordinary duties without including prohibited antidumping or countervailing duty amounts.

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