Importers and foreign producers with merchandise covered by antidumping or countervailing duty orders reaching their anniversary month in June have a closing window to request an administrative review — and missing it means living with the current cash deposit rate for another full year.
The Mechanism
Each year, during the anniversary month of the publication of an antidumping duty (AD) or countervailing duty (CVD) order, finding, or suspended investigation, an interested party may request that the Department of Commerce conduct an administrative review of that order under 19 CFR 351.213. Commerce will publish a notice of initiation for administrative review for any requests it receives by the last day of the anniversary month.
For orders with a June anniversary, the deadline to request a review of the relevant period falls on June 30, 2026.
What Happens if the Deadline Is Missed
If Commerce does not receive a review request by the deadline for a given order, finding, or suspended investigation, Commerce will instruct CBP to:
- Assess antidumping or countervailing duties on the relevant entries at a rate equal to the cash deposit rate that was in effect at the time of entry or withdrawal from the warehouse for consumption, and
- Continue collecting that same cash deposit rate going forward.
In practical terms, no review means no opportunity to seek a lower assessed rate or a revised cash deposit rate for that period — importers and foreign producers are locked into the existing rate until the next annual review window.
Why This Matters for Trade Compliance Teams
AD/CVD administrative reviews are one of the few mechanisms available to importers and exporters to seek a revised duty rate reflecting current pricing and subsidy conditions, rather than the rate established at the time of the original investigation or a prior review. Missing the annual window — even inadvertently — forecloses that opportunity for an entire additional year on the affected entries.
What Importers Should Watch
- Cross-reference your portfolio of AD/CVD case numbers against their original order publication dates to identify which orders have a June anniversary.
- Coordinate with foreign suppliers or producers who may also have an interest in requesting a review on their own behalf.
- If multiple companies are covered under a single order, requests for review should include an appendix listing company names in alphabetical order, per Commerce’s stated format requirements.
- Build administrative review tracking into your annual compliance calendar going forward, given that anniversary months vary by order and are easy to miss without a standing reminder.
ASK Alba™
Answers • Solutions • Knowledge
Determining whether your AD/CVD case numbers have a review opportunity closing this month requires checking original order publication dates against Commerce’s anniversary-month framework. Alba’s trade advisory team can help identify upcoming review windows and coordinate review requests before deadlines close.
Contact us: https://albawheelsup.com/contact-us/
