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Aluminum Extrusions from China

Impact of ADCVD on Aluminum Extrusions from China

When imported into the United States products containing aluminum extrusions from China may be subject to antidumping duties (AD) 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 from extruded Chinese aluminum.  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 confirm that their Aluminum Extruded product meets the "finished goods" exception to the Orders are encouraged to discuss the matter with an experienced trade attorney. 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. 


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Additional Historic Resources:

Customs NIS Presentation from 2012.

China (PRC)Aluminum Extrusions (A-570-967)

China (PRC)Aluminum Extrusions (C-570-968) 



July 31, 2019: DOJ: Announcement of Federal Indictment for Alleged scheme to avoid payment of $1.8 Billion in Anti-dumping duties on Chinese aluminum imported as ‘pallets’. (Perfectus indictment)

July 22, 2019: DOC: Countervailing Review: Final Results.

April 16, 2019: DOC: Antidumping Review: Preliminary Results.

January 14, 2019: CIT: Commerce ordered to provided additional analysis in the analysis related to the “finished goods” scope exclusion in Whirlpool, and Meridian.

July 27, 2018: Commerce: Aluminum Extrusions (China): Final results of ADD Annual Review (2016-2017).

July 25, 2018: DOC: Countervailing Review: Final Results:

May 21, 2018: CAFC: Whirlpool: "the exception for fasteners unambiguously applies only to the finished goods kit exclusion and not to the finished merchandise exclusion . . ."

March 17, 2018:  BIS: NPRN on Steel and Aluminum Exclusions.

March 2, 2018:  Client Advisory: Gazing into the Crystal Ball for Steel & AL.

NPR: Article: U.S. Plan For Steel And Aluminum Tariffs Prompts Global Backlash

March 1, 2018: POTUS announces section 232 duties will be imposed 25% for steel products, and 10% for Aluminum products. 

January 8, 2018: Anti-Circumvention Request (partial document) re: Aluminum products from Vietnam

December 27, 2017: CIT decision in Shenyang Yuanda case finally clarifies to which types of curtain wall will be exempted from the order. 

December 7, 2017: Final CV results of AD review, POR 2015.

December 6, 2017: CIT: In Adams Thermal Systems v US, the Court held that certain post-extrusion processes that created fittings for engine cooling system failed to remove the product from Scope.

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.