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On October 28, 2024, the U.S. Department of Commerce issued a preliminary determination that countervailable subsidies are being provided to certain Chinese manufacturers of disposable aluminum containers, pans, trays, and lids. The new duties, which took effect retroactively from July 30, 2024, impose a 312.91% rate for Zhejiang Acumen Living Technology Co., Ltd. and a 78.12% rate for all other Chinese producers.

The investigation scope covers disposable aluminum items designed for single or limited uses, typically used in food-related applications like packaging, baking, or storage. These items are subject to countervailing duties despite their specifications or whether they are embossed, coated, or printed. Importantly, these duties apply to items currently classified under Harmonized Tariff Schedule codes 7615.10.7125 and several others, underscoring the critical need for accurate classification when importing these goods.

The U.S. Customs and Border Protection was instructed to suspend the liquidation of these items, requiring cash deposits equal to the preliminary rates. The decision remains contingent on the International Trade Commission’s (ITC) assessment, expected by March 2025, when the concurrent antidumping investigation’s final determination will be announced.

What Importers Need to Know
This preliminary ruling means importers could face substantial costs without the final duty determinations, companies should act now to review compliance and pricing strategies. Zarach closely monitors these developments and is ready to help clients navigate the evolving landscape of trade regulations and duties.

Contact Edward J. Zarach & Associates today to ensure your imports comply with the latest U.S. trade regulations and explore strategies to manage the impact of potential duties.