Thai Aluminum Containers Using Chinese Foil Hit U.S. Duty Wall
Published Date: 4/20/2026
Notice
Summary
The U.S. Department of Commerce found that some disposable aluminum containers made in Thailand using Chinese aluminum foil are sneaking around import taxes meant for Chinese products. This means these Thai-made containers might soon face the same extra duties as those from China, starting April 20, 2026. Companies involved and importers should get ready for possible new costs and rules.
Analyzed Economic Effects
4 provisions identified: 0 benefits, 3 costs, 1 mixed.
Thailand-Made Containers Deemed Circumventing
If you import or sell disposable aluminum containers completed in Thailand using aluminum foil made in China, the Department of Commerce preliminarily found those imports are circumventing the antidumping and countervailing duty orders on products from China. Commerce preliminarily determined the Thailand-made merchandise should be included within the scope of the China orders, effective April 20, 2026.
Suspension and Very Large Cash Deposits
Commerce will direct U.S. Customs and Border Protection to suspend liquidation and require cash deposits on unliquidated entries of the inquiry merchandise entered or withdrawn for consumption on or after October 28, 2024. Where certifications are not met, Commerce intends to instruct CBP to collect antidumping cash deposits at 287.80 percent (China-wide) and countervailing cash deposits at 317.85 percent (all-others), with company-specific rates used when applicable.
Certification Documents and Deadlines
Importers and exporters must complete and retain certifications stating the aluminum containers were not produced using China-origin aluminum foil and must upload the importer certification, exporter certification, commercial invoice, bill of lading, and the aluminum mill certificate (identifying country of smelt and cast) into the Document Imaging System in ACE at the time of entry. For entries entered or withdrawn for consumption from October 28, 2024 through May 6, 2026 that remain unliquidated, these certifications and supporting documents must be completed and uploaded by June 5, 2026; for entries with shipment/entry dates after May 7, 2026, the exporter certification must be completed by shipment and the importer certification by the time the entry summary is filed.
Convert Misclassified Entries; Pay Deposits
For unliquidated entries of aluminum containers entered or withdrawn for consumption in the United States during October 28, 2024 through May 6, 2026 that were declared as non-AD/CVD type entries (for example, type 01) and for which certifications cannot be made, importers must file a Post Summary Correction with CBP to convert those entries to AD/CVD type entries and pay the required cash deposits. Importers must report those entries using the specified third-country case numbers and pay additional duties consistent with post summary correction rules.
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Key Dates
Department and Agencies
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