24.09.2026 Regulation #USA #China #Import #Duties
US Commerce finds circumvention via Cambodia hangers and China CGI brake drums
On September 22, 2026, the US Department of Commerce published two preliminary affirmative determinations of circumvention in the Federal Register (FR 2026-19376; FR 2026-19372). The first covers steel wire garment hangers finished in Cambodia from Chinese and Vietnamese wire; the second covers compacted graphite iron (CGI) brake drums from China. Both determinations are country-wide; final rulings will follow later.
How Cambodia became a link in the hangers circumvention chain
Commerce self-initiated the inquiry on August 12, 2025, under section 781(b) of the Tariff Act, and did so on a country-wide basis from the outset (FR 2025-15246). On December 31, 2025, Alpha Hanger (Cambodia) Co., Ltd was named the sole mandatory respondent; the company did not provide the information Commerce requested, and Commerce preliminarily found it uncooperative and applied adverse facts available (govinfo, hangers). As a result, hangers finished in Cambodia using Chinese- or Vietnamese-origin steel wire were found to constitute merchandise completed in a third country that falls within the orders on China (case A-570-918) and Vietnam (same source).
CBP is suspending liquidation and collecting cash deposits on entries made on or after August 12, 2025, the date the inquiry was initiated. By default, the Vietnam orders' rates apply: an antidumping cash deposit rate of 220.68 percent for the Vietnam-wide entity and a countervailing duty rate of 31.58 percent for all other companies, under the third-country case numbers A-555-812 (AD) and C-555-813 (CVD). Where the importer and the exporter each file a separate certification (an importer certification and an exporter certification) that the hangers were produced using Chinese-origin steel wire, or wire and paper accessories, the China order's rate applies instead under case number A-555-918. Supporting records must be retained until the later of five years after the latest entry date or three years after the conclusion of any litigation (govinfo, hangers).
CGI brake drums qualify as "later-developed merchandise"
The existing orders, AD A-570-174 and CVD C-570-175, dated August 12, 2025, cover gray cast iron brake drums with an inside diameter of 14.75 to 16.6 inches weighing more than 50 pounds. Acting on a request from domestic producer Webb Wheel Products, Inc., Commerce initiated the circumvention inquiry on January 27, 2026 and preliminarily determined that CGI brake drums constitute "later-developed merchandise", goods developed after the orders took effect that circumvent them. The notice itself does not spell out the technical basis for that finding; the rationale is contained in a separate Preliminary Decision Memorandum. The determination cites model M328D557, produced by PanAsia CVS (HK) Limited, as an example (govinfo, brake drums).
This determination is also country-wide: suspension of liquidation and cash deposits apply to entries made on or after January 27, 2026, the date this inquiry was initiated, not the date of the original orders. Deposit rates are 150.25 percent antidumping for the China-wide entity and 11.94 percent countervailing duty for all other companies (govinfo, brake drums).
Retroactive deposits and certifications importers now face
Both determinations are preliminary; Commerce will issue final ones after reviewing the parties' written briefs. Importers who have already entered Cambodia-finished hangers on or after August 12, 2025, or CGI brake drums from China on or after January 27, 2026, should be prepared for cash-deposit collection at these rates on those entries. For hangers, the China order's rate, rather than the higher Vietnam rates, is available only with both certifications in place, from the importer and from the exporter, backed by records kept for the required period.
Hangers get a week to object, brake drums two
In the hangers case, case briefs are due no later than seven days after the date of publication, rebuttal briefs no later than five days after the case brief deadline, and hearing requests within 30 days of publication (govinfo, hangers). In the brake drums case, case briefs are due no later than 14 days after publication, rebuttal briefs no later than seven days after the case brief deadline, and hearing requests likewise within 30 days of publication (govinfo, brake drums).
Primary sources
- Steel Wire Garment Hangers From China and Vietnam: Preliminary Affirmative Determination of Circumvention (govinfo, full text)
- Federal Register 2026-19376 (hangers)
- Steel Wire Garment Hangers: Initiation of Circumvention Inquiries (govinfo, full text)
- Certain Brake Drums From China: Preliminary Affirmative Determination of Circumvention (govinfo, full text)
- Federal Register 2026-19372 (brake drums)
This material is for information only and does not constitute legal advice or customs consulting. Verify changes against the primary sources before acting.