In October 2023, we reported that antidumping (AD) and countervailing (CVD) duty petitions were filed on aluminum extrusions from Colombia, the Dominican Republic, Ecuador, India, Indonesia, Italy, Malaysia, Mexico, China, South Korea, Taiwan, Thailand, Turkey, the United Arab Emirates, and Vietnam. The investigation against the Dominican Republic has since been terminated. The US Department of Commerce (DOC) is investigating these allegations and is scheduled to determine any preliminary CVD duties to be imposed on products from Turkey, Indonesia, Mexico, and China on March 4 (typically announced the following day). Those duties will be in effect upon publication of those determinations, which is typically a few business days after the duties are announced. Preliminary AD duties on imports from the 14 countries are expected to be determined on May 1 (typically announced the following day) and will go into effect shortly thereafter.
The proposed scope of products that are covered by the investigations is extremely broad and ill-defined. Some changes to that scope are under consideration by the DOC. For now, importers should be aware that if your product contains an aluminum extrusion part or a part that contains extruded aluminum, it may be subject to additional duties. While this result seems absurd, it is a very real possibility. Below, we provide responses to some commonly asked questions regarding this investigation. Be advised that the interpretation of the scope can be quite complex. If you have specific questions on the applicability of these tariffs to your imports, please contact a member of our team. 2020 t slot
The current scope of the investigations covers the aluminum extrusion portion of a product. Even if the aluminum extrusion has been processed in a third country (such as a country not named in the investigations), the aluminum extrusion portion of the product is still covered by the investigations. There are some exclusions from the scope such as for discrete kits entered on the same customs entry form, extrusions made from certain Aluminum Association series designations, products from continuous casting or rolling, cast aluminum products or unwrought aluminum products, among other exclusions.
The importer should review all components of its product to determine whether any aluminum extrusions were used. This will likely require reviewing the bill of materials, schematics, product brochures, etc.
If the product contains any extruded aluminum, duty deposits may be required on the aluminum extrusion portion of a product. The company will need to determine the following:
Documentation on the condition of the merchandise at the time of importation and on how the merchandise is sold, installed, and used after importation may need to be reviewed to determine whether any of the exclusions from the scope are applicable.
The amount of the duties will be calculated based on the value of the product that is subject to the duties and the applicable rate from the producer of the aluminum extrusion. If the product includes aluminum extrusions from multiple countries or multiple producers, separate calculations and deposits will be required for each producer/country.
It is likely included under these new investigations. These investigations include products from China and are a follow-up to the much-litigated 2011 AD/CVD Orders on Aluminum Extrusions from China. The scope of products that would be covered by any AD/CVD duties imposed in this new case is much broader than the existing cases against China. Petitioners have specifically written the scope in this case to include products the DOC has previously found to be excluded from the China AD/CVD orders so that those products will now be subject to any AD/CVD duties resulting from these investigations.
Products subject to AD or CVD duties must be entered as type 03 entries and cash deposits to cover the duties must be made for the subject entries. The importer of record is responsible for entering the product correctly, for depositing the duties, and for ultimately paying the duties to US Customs and Border Protection (CBP) when the entries are liquidated. The liquidation rates for AD or CVD duties can be higher or lower than the deposit rates, and typically are the result of a lengthy administrative review process conducted by the DOC. The importer of record will have to certify to CBP that it was not reimbursed for the duties from the foreign producer.
Yes. The US International Trade Commission (ITC) is beginning the final phase of its investigations to determine whether the US industry that produces aluminum extrusions is being materially injured, or threatened with material injury, from subject imports. Importers and purchasers can participate by completing questionnaire responses, submitting letters or briefs, testifying at the hearing, and taking other action to voice concerns. There may also be an opportunity to file comments on the scope of the investigations with the DOC.
The scope of these investigations is extraordinarily complex, as is how to calculate the value of the aluminum extrusion portion of your product to ensure you are paying the correct AD or CVD deposit. Opportunities still exist to challenge the scope of this case and whether AD or CVD orders are needed to protect aluminum extrusion producers in the United States.
You are responsible for reading, understanding, and agreeing to the National Law Review's (NLR’s) and the National Law Forum LLC's Terms of Use and Privacy Policy before using the National Law Review website. The National Law Review is a free-to-use, no-log-in database of legal and business articles. The content and links on www.NatLawReview.com are intended for general information purposes only. Any legal analysis, legislative updates, or other content and links should not be construed as legal or professional advice or a substitute for such advice. No attorney-client or confidential relationship is formed by the transmission of information between you and the National Law Review website or any of the law firms, attorneys, or other professionals or organizations who include content on the National Law Review website. If you require legal or professional advice, kindly contact an attorney or other suitable professional advisor.
Some states have laws and ethical rules regarding solicitation and advertisement practices by attorneys and/or other professionals. The National Law Review is not a law firm nor is www.NatLawReview.com intended to be a referral service for attorneys and/or other professionals. The NLR does not wish, nor does it intend, to solicit the business of anyone or to refer anyone to an attorney or other professional. NLR does not answer legal questions nor will we refer you to an attorney or other professional if you request such information from us.
Under certain state laws, the following statements may be required on this website and we have included them in order to be in full compliance with these rules. The choice of a lawyer or other professional is an important decision and should not be based solely upon advertisements. Attorney Advertising Notice: Prior results do not guarantee a similar outcome. Statement in compliance with Texas Rules of Professional Conduct. Unless otherwise noted, attorneys are not certified by the Texas Board of Legal Specialization, nor can NLR attest to the accuracy of any notation of Legal Specialization or other Professional Credentials.
The National Law Review - National Law Forum LLC 2070 Green Bay Rd., Suite 178, Highland Park, IL 60035 Telephone (708) 357-3317 or toll-free (877) 357-3317. If you would like to contact us via email please click here.
t slot aluminum accessories Copyright ©2025 National Law Forum, LLC