America Declares War on Cheap Chinese Rust Prevention
Published Date: 1/2/2025
Notice
Summary
The U.S. Department of Commerce found that some Chinese companies sold corrosion inhibitors at unfairly low prices from March 2023 to February 2024. They’re stopping the review for one company but continuing with others, and they’ve pushed the deadline to March 24, 2025. This could affect import duties and how much companies pay when selling these products in the U.S.
Analyzed Economic Effects
5 provisions identified: 0 benefits, 5 costs, 0 mixed.
Very high preliminary dumping margins
If your business imported corrosion inhibitors from Anhui Trust Chem, Nantong Botao, or Gold Chemical during March 1, 2023–February 29, 2024, Commerce preliminarily found dumping margins of 96.67%, 96.04%, and 96.46%, respectively. Those percentages are the preliminary weighted‑average dumping margins Commerce may use to calculate antidumping duties on entries if finalized.
Cash deposit rules tied to final margins
When Commerce publishes final results, cash deposit requirements for shipments entered on or after the publication date will be set equal to the weighted‑average dumping margins established in the final results for exporters with a separate rate. For companies not entitled to a separate rate the China‑wide cash deposit rate (241.02%) will apply, and non‑Chinese exporters without their own rate will be assigned the rate of their Chinese supplier.
How duties will be assessed and liquidated
Commerce will instruct U.S. Customs and Border Protection (CBP) to assess antidumping duties based on the final results; assessment instructions will be issued no earlier than 35 days after publication of the final results. If a timely summons is filed at the U.S. Court of International Trade, CBP will be directed not to liquidate relevant entries until the statutory injunction period (within 90 days of publication) has expired.
Review rescinded for Delian; duties based on cash deposits
Commerce rescinded the administrative review for Jiangyin Delian Chemical Co., Ltd. after the petitioner withdrew its review request on June 5, 2024. For Delian, Commerce will instruct CBP to assess antidumping duties on entries during March 1, 2023–February 29, 2024 at a rate equal to the cash deposit required at the time of entry or withdrawal from warehouse for consumption.
Reimbursement certificate requirement and double‑duty risk
Importers must file a certificate under 19 CFR 351.402(f)(2) regarding reimbursement of antidumping and/or countervailing duties prior to liquidation of relevant entries. If an importer fails to file this certificate, Commerce may presume reimbursement occurred and could order assessment of double antidumping duties and/or increase the antidumping duties by the amount of countervailing duties.
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