Aluminum Extrusions from China
Our customs attorneys represent importers in scope and ADCVD issues.
Contact a firm attorney at (415) 498-0070.
Impact of ADCVD on Aluminum Extrusions from China
When imported into the United States, certain Aluminum Extrusions from China may be subject to high Antidumping duties (ADD) and Countervailing duties (CVD).**
ADCVD issues are a "priority trade" issue of U.S Customs. As a consequence, importers should exercise care when importing any products made of Extruded Aluminum from China.
While certain "finished goods" may be excepted from the scope of these ADCVD orders, the legality of such scope exclusions is frequently the subject of legal debate (and enforcement actions).
Companies wishing to confirming that their Aluminum Extruded product meets the "finished goods" exception to the Orders are encouraged to seek a Scope Ruling request from the Department of Commerce. As of November 2017, there 109 companies have received published scope determinations. List of Scope Determinations (as of 09/2017)
Scope ruling requests can be complex and nuanced. Please feel free to contact us if you would like additional information, or wish to seek a scope determination for your product.
** For example, in the period of review 5/2015 to 4/ 2016, the ITA set the 'all others' ADD liquidated duties and cash deposit margins at 85.96%. While the CVD determinaion in Dec. 2016, set the majority of respondents CVD rates at 16.08% (for the period 01/01/2014 through 12/31/2014).
CURATED NEWS ON SCOPE OF AL EXTRUSIONS:
December 7, 2017: Final CV results 2015 POR.
July 26, 2017: Final Determination that heat-treated extruded aluminum products that meet the chemical specifications for 5050-grade aluminum alloy, regardless of producer, exporter, or importer, constitute later-developed merchandise, and are circumventing the orders.
June 19, 2017: Commerce determines that Woodward Chair Parts would not qualify as a "finished goods kit" and will be subject to ADCVD.
June 13, 2017: Commerce determines that Aluminum Pallets (6- series) are subject to the orders.
June 9, 2017: Commerce issued a final scope determination that Innovative Outdoor Solutions's Power Rails would be within scope.
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Our practice areas include classification, valuation, admissibility, customs detentions, seizures and penalty proceedings, and customs audits. We bring litigation, and handle numerous other types of issues arising in international trade. See our services listings.
To schedule an appointment, please contact our offices at (415) 498-0070.