Thai Aluminum Products Hit with Duties for Chinese Foil Sneak
Published Date: 4/20/2026
Notice
Summary
The U.S. Department of Commerce found that aluminum containers made in Thailand using Chinese aluminum foil are sneaking around import taxes meant for Chinese products. This means these Thai-made containers will now face the same extra duties as those from China, starting April 20, 2026. Companies importing these products should get ready for new costs and rules to keep things fair.
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Analyzed Economic Effects
5 provisions identified: 1 benefits, 3 costs, 1 mixed.
Thailand-made Aluminum Treated as Chinese
The Department of Commerce preliminarily found that disposable aluminum containers completed in Thailand using aluminum foil produced in China are circumventing U.S. antidumping and countervailing duty orders on China. As of April 20, 2026, Commerce preliminarily includes these Thailand-origin-but-China-foiled products within the scope of the China Orders, so importers of that merchandise may be treated the same as imports from China.
Huge Cash Deposits and Suspended Liquidation
Commerce will direct CBP to suspend liquidation and require cash deposits on unliquidated entries of the covered Thailand merchandise entered or withdrawn for consumption on or after October 28, 2024. Where certifications are not met, Commerce intends to require cash deposits at the China-wide AD rate of 287.80 percent and the CVD all-others rate of 317.85 percent (company-specific rates apply where available).
Certification and Document Upload Rules
Importers and exporters must complete importer and exporter certifications and submit supporting documents (commercial invoice, bill of lading, and aluminum mill certificate identifying country of smelt and cast) to CBP by uploading them into the Document Imaging System in ACE at the time of entry. For unliquidated entries dated October 28, 2024 through May 6, 2026, certifications and required uploads must be completed and signed by June 5, 2026. Brokers or agents may not certify on behalf of the importer.
Non-Chinese Foil Entries Are Exempt If Documented
Aluminum containers completed in Thailand using aluminum foil that is not of Chinese origin are not subject to this circumvention inquiry or the China Orders. Importers can avoid suspension and cash deposits by completing the certifications and providing required documentation proving the aluminum input is not Chinese-origin.
Convert Non-AD/CVD Entries and Pay Deposits
For unliquidated entries of aluminum containers entered as non-AD/CVD types (e.g., type 01) during October 28, 2024 through May 6, 2026 for which certifications cannot be made, importers must file a Post Summary Correction to convert entries to AD/CVD type (e.g., type 03) and must pay the required cash deposits and any additional duties consistent with PSC rules.
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