The preliminary paper shopping bags antidumping duty review creates a significant potential liability for importers sourcing from Vietnam. IPSC received a 28.52% preliminary margin, while the Vietnam-wide rate remains 92.34%, making exporter identification, entry analysis, and duty classification critical.
What the Preliminary Antidumping Results Mean
IPSC Received a 28.52% Preliminary Margin
The first administrative review covers Vietnamese paper shopping bag entries made from January 3, 2024, through June 30, 2025. Commerce preliminarily calculated a 28.52% weighted-average dumping margin for International Packaging Limited Company, commonly identified as IPSC. IPSC was the sole mandatory respondent in the review.
Commerce used a constructed export price analysis and its methodology for exporters in a non-market economy. The resulting margin represents Commerce's preliminary measurement of dumping during the review period. It is not yet IPSC's final assessment or cash deposit rate.
Importers should model the 28.52% margin against affected IPSC entries, but they should not treat that calculation as a final duty bill. Final results can change because of submitted briefs, corrected calculation errors, methodological revisions, or other case-specific determinations.
Preliminary Results Do Not Immediately Change Deposits
The preliminary result does not change the cash deposit rate currently applied to new IPSC entries. A new deposit rate generally becomes effective only after Commerce publishes the final results of the administrative review.
The distinction between deposits and assessments is essential. Cash deposits collected at entry are security against potential antidumping liability. The final review results generally establish how reviewed entries will be assessed when they liquidate. Deposits can therefore be higher or lower than the final liability.
The Vietnam-wide entity was not reviewed, so its rate remains 92.34%. Exporters that previously qualified for separate rates generally retain their existing cash deposit rates unless a subsequent determination changes them. Non-Vietnamese exporters of subject bags typically receive the rate associated with the Vietnamese producer or supplier responsible for the merchandise.
How Importers and Brokers Should Analyze Exposure
Identify the Exporter and Producer on Every Entry
The first control point is accurate party identification. Importers and customs brokers should distinguish among IPSC, companies for which the review was rescinded, other exporters with separate rates, and exporters subject to the Vietnam-wide rate. Commercial names, manufacturer identifiers, invoices, purchase orders, and entry records should be reconciled rather than relying on a supplier's informal description.
The review was rescinded for Blue Sea Pack Import Export Company Limited, Goldsun Packaging and Printing Joint Stock Company, and Vietnam Red Star Industry Company Limited after the applicable review requests were withdrawn. Entries associated with those companies are generally assessed at the cash deposit rate in effect on the entry date. Assessment instructions for these rescinded companies are expected no earlier than November 18, 2026.
Misidentifying the exporter can create substantial exposure because the difference between IPSC's preliminary 28.52% margin and the 92.34% Vietnam-wide rate is significant. Brokers should also confirm that the entered company name matches the entity that qualified for any claimed separate rate.
Model Entry-Level Liability Without Overstating Certainty
A useful exposure model should include entered value, exporter, producer, entry date, deposit rate paid, deposit amount, and the preliminary margin associated with the reviewed exporter. For IPSC entries, applying 28.52% to the relevant value can provide an initial liability estimate. The modeled amount can then be compared with cash deposits already paid.
That comparison may indicate a potential receivable, additional assessment, or reserve adjustment, but it is not a liquidation calculation. Commerce generally intends to calculate importer-specific assessment rates for IPSC if the final margin is above de minimis. Those rates can produce outcomes that differ from a simple application of the weighted-average margin.
Retailers, restaurant groups, grocery chains, and packaging distributors should coordinate with finance teams before recognizing any expected recovery. Importers should also preserve the underlying entry data until liquidation is complete and all protest or correction opportunities have been evaluated.
Compliance Priorities Before Final Results
Track Brief and Hearing Deadlines
Interested parties generally have 21 days after publication to file case briefs, placing the expected deadline on November 4, 2026. Rebuttal briefs are due five days after case briefs and should ordinarily be limited to issues raised in those briefs. Hearing requests are due within 30 days after publication, producing an expected date of November 13, 2026.
Parties should confirm electronic filing deadlines and any subsequent procedural changes before submission. IPSC and participating importers may wish to review Commerce's calculations, sales databases, surrogate values, and importer attribution for possible factual or clerical issues.
Prepare for Assessment and Deposit Changes
If IPSC's final margin is zero or de minimis, meaning below 0.50%, reviewed entries would generally liquidate without antidumping duties. If the final margin remains above that threshold, Commerce generally calculates importer-specific assessment rates and instructs CBP to liquidate the entries accordingly.
After final results, IPSC's future entries would be subject to its final cash deposit rate. Previously reviewed exporters with separate rates generally retain their established rates. The Vietnam-wide rate would remain 92.34% unless changed through an applicable proceeding.
Importers should file required reimbursement certificates before liquidation. These certificates address whether the importer was reimbursed for antidumping duties by the exporter or another party. Missing or inaccurate certifications can create an assumption of reimbursement and potentially increase the assessed antidumping liability.
Separate Antidumping Duties From Drawback-Eligible Duties
Antidumping and countervailing duties are not eligible for duty drawback. They should be excluded from drawback calculations even when they appear on an entry containing ordinary customs duties that may qualify.
Ordinary customs duties paid on the same paper bag entries can still be eligible when the merchandise is subsequently exported or destroyed, or when qualifying imported merchandise is used to manufacture exported articles. The claim must otherwise satisfy the applicable drawback requirements.
Brokers and importers should maintain separate duty fields for ordinary customs duties, antidumping deposits, countervailing deposits, merchandise processing fees, and other charges. Combining these amounts can overstate a drawback claim and create avoidable compliance risk. Data retained for drawback should also preserve the final liquidation status because a deposit made at entry may not equal the antidumping duty ultimately assessed.
- On October 14, 2026, the U.S. Department of Commerce published preliminary results of the first antidumping duty administrative review of certain paper shopping bags from Vietnam (A-552-836, 91 FR 65174), covering the period January 3, 2024 through June 30, 2025. Commerce calculated a 28.52 percent weighted-average dumping margin for International Packaging Limited Company (IPSC), the sole mandatory respondent, and rescinded the review for four companies that withdrew their requests (Blue Sea Pack Import Export Company Limited, Goldsun Packaging and Printing Joint Stock Company, Vietnam Red Star Industry Company Limited, and Vietnam Red Star Industry Company Limited of Vietnam). The Vietnam-wide entity rate remains 92.34 percent, as it was not under review. These are preliminary results only. Cash deposit rates do not change until final results are published.
- Interested parties may submit case briefs no later than 21 days after publication (approximately November 4, 2026), with rebuttal briefs due five days later. Hearing requests must be filed within 30 days of publication (approximately November 13, 2026). Final results are currently anticipated in February. For IPSC, if the margin is not zero or de minimis in the finals, Commerce intends to calculate importer-specific assessment rates. For the rescinded companies, CBP will assess duties at the cash deposit rates in effect at the time of entry.
- On October 19, 2026, Vietnam's Ministry of Industry and Trade (Trade Remedy Department) issued guidance noting the delays from the 2025 U.S. government shutdown (tolling of 47 plus 21 days, plus two further extensions of the prelim deadline). It recommended that IPSC review Commerce's calculations for errors, prepare comments by November 4, 2026, and consider requesting a hearing by November 13, 2026. Other Vietnamese exporters were advised to monitor the case and consider requesting a separate rate in the next administrative review to avoid the 92.34 percent Vietnam-wide rate. It also urged coordination with U.S. importers on refund certifications under 19 CFR 351.402(f).
- Trade publications on October 14, 2026 covered the prelim results, highlighting the 28.52 percent rate for IPSC (compared to 36.51 percent separate rates from the original investigation for some firms) and confirming no immediate cash deposit changes. No significant practitioner discussions on X were identified in the past 30 days.
Frequently Asked Questions
Does the 28.52% Preliminary Margin Change IPSC's Deposit Rate Now?
No. IPSC's current cash deposit requirement generally remains in effect until Commerce publishes the final administrative review results. The 28.52% figure is a preliminary margin used to evaluate the reviewed period, not an immediate instruction to collect deposits at that rate on new entries.
Which Rate Applies to a Vietnamese Paper Bag Exporter?
The applicable rate depends on the exporter's status. IPSC has a preliminary review margin of 28.52%. Other exporters may retain previously established separate rates. Exporters that do not qualify for a separate rate are generally subject to the 92.34% Vietnam-wide rate. Non-Vietnamese exporters typically take the rate of their Vietnamese supplier.
What Happens to Entries From the Rescinded Companies?
Entries associated with the companies removed from the review are generally assessed at the cash deposit rate in effect when the merchandise entered. Because those companies are no longer covered by this review, the 28.52% IPSC preliminary margin does not apply to their entries.
Can Duties on These Paper Shopping Bags Be Recovered Through Drawback?
Antidumping and countervailing duties cannot be recovered through drawback. Ordinary customs duties on the same entries may still qualify if the merchandise is exported or destroyed, or used in qualifying production of exported goods. Claimants should exclude all AD and CVD amounts from the drawback calculation.
How Stable Software Can Help
Support Broker-Led Duty Recovery
Antidumping reviews reinforce the importance of separating ordinary customs duties from AD and CVD amounts before preparing drawback claims. DrawbackAI is flat-license duty drawback software that U.S. customs brokers can white-label for importer clients and use to file claims under their own filer codes.
Stable Software charges a flat software license and never takes a percentage of the refund. This model allows customs brokers to maintain control of the client relationship and duty drawback filing process while offering importer clients a broker-branded recovery service. Brokers evaluating ordinary duty recovery opportunities on entries affected by trade remedies can explore whether DrawbackAI fits their drawback practice.
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