24.09.2026 Regulation #USA #China #Import #Duties
US sets preliminary 136.52% anti-dumping duty on Chinese tin mill products
The US Department of Commerce published a preliminary affirmative antidumping determination on tin mill products from China in the Federal Register on September 21, 2026, finding that Chinese suppliers sold the product in the US market below fair value. Commerce also made a preliminary affirmative finding of critical circumstances and ordered retroactive cash deposits. The determination was signed on September 16; the case is A-570-228, covering the period of investigation from October 1, 2025 through March 31, 2026 (Federal Register).
A 136.52 percent margin for everyone without a separate rate
None of the examined Chinese producers qualified for an individual "separate rate" — all were folded into a single China-wide entity. According to the determination, these companies failed to rebut the presumption of government control: some did not respond to the quantity-and-value questionnaire, others did not submit a separate-rate application, and others did not respond to the initial questionnaire and withdrew from the investigation. Commerce therefore applied adverse facts available (AFA) and assigned the China-wide entity a weighted-average dumping margin of 136.52 percent; after offsetting for subsidies found in the companion countervailing-duty case, the cash deposit rate was reduced to 130.17 percent (Federal Register).
A week earlier, on September 15, Commerce issued its own preliminary countervailing duty determination on the same product, setting an identical subsidy rate of 66.61 percent for the examined respondents — Shougang Holding Trade (Hong Kong) Ltd. and Shougang Jingtang United Iron & Steel Co. Ltd. — and for all other exporters, with final determinations in both cases now aligned (Federal Register, CVD notice).
Why deposits reach back in time
Commerce's affirmative critical circumstances finding for the China-wide entity means CBP will collect cash deposits not only on entries filed after the notice's publication but retroactively — on all unliquidated entries entered, or withdrawn from warehouse for consumption, on or after the date 90 days before publication, roughly June 23, 2026 (Federal Register).
What it means for importers and already-shipped cargo
The investigation covers tin mill flat-rolled products coated or plated with tin, chromium, or chromium oxides, regardless of thickness, width, form or coating type. The notice lists HTSUS headings 7210 and 7212 — subheadings 7210.11.0000, 7210.12.0000, 7210.50.0020, 7210.50.0090, 7212.10.0000 and 7212.50.0000 for non-alloy steel — plus 7225 and 7226, subheadings 7225.99.0090 and 7226.99.0180 for alloy steel (Federal Register).
The determination directly affects US importers of tin mill and tinplate products, as well as can-making and packaging manufacturers sourcing steel from China. Companies that entered merchandise during the retroactive window (roughly since June 23) should check with their customs broker whether CBP will demand supplemental deposits on shipments already cleared.
Path to a final ruling and USITC's role
The notice's own title also references an extension of provisional measures; the published text does not specify the new duration of that period. Commerce's final determinations in both the antidumping and companion countervailing-duty cases are due no later than November 30, 2026 (Federal Register, CVD notice). Interested parties may file case briefs within 14 days of publication, with rebuttal briefs due five days later. After Commerce's final determination, the US International Trade Commission (USITC) must issue its own material-injury ruling no later than 120 days after the preliminary determination or 45 days after the final determination, whichever is later — only an affirmative USITC injury finding would make the duties permanent (Federal Register).
Primary sources
- Federal Register: Tin Mill Products From China — Preliminary AD Determination, Critical Circumstances and Extension of Provisional Measures
- Federal Register: Tin Mill Products From China — Preliminary CVD Determination and Critical Circumstances
Mentioned codes
This material is for information only and does not constitute legal advice or customs consulting. Verify changes against the primary sources before acting.