Trade Compliance Weekly · Week 40, 2026 · Sep 28 – Oct 4
NORTH AMERICA TRADE COMPLIANCE BRIEF
CBSA Steel Import Measures and U.S. AD/CVD Actions on Chinese and Other Imports
This issue covers September 28 to October 4, 2026. The Canada Border Services Agency continued implementing steel import measures, including country of melt and pour requirements under GIPs 80 and 81, surtax and TRQ rules under SOR/2026-0119, and CARM transition changes affecting exporter accounts and late payment penalties. In the United States, the Department of Commerce issued preliminary affirmative determinations on truck bed covers and large diameter graphite electrodes from China, and on air compressors from China, Vietnam, and Malaysia, while self-initiating a circumvention inquiry on aluminum composite panels from China. The USITC instituted new investigations on amine compounds from China and found a Section 337 violation on storage containers and toolboxes. Commerce also issued sunset review results on various orders, and CBSA made preliminary and expiry determinations on wheat gluten and rebar.
CBSA Steel Import Requirements and CARM Transition
Section summaryCBSA requires importers using GIP 80 and GIP 81 to provide country of melt and pour information as of November 5, 2024. Customs Notice 25-24 states that the Order Imposing a Surtax on the Importation of Certain Steel Goods (SOR/2025-148), as amended, applies a 50% surtax on certain steel goods. Effective October 21, 2024, CBSA stopped accepting exporter BN15 accounts for release and accounting under CARM. From October 21, 2024 to January 30, 2026, CBSA will not issue late payment penalties or interest; effective January 31, 2026, all overdue accounts will be subject to penalties and interest.
CBSA requires country of melt and pour information for steel imports under GIPs 80 and 81
CBSA states that, as of November 5, 2024, importers using GIP Number 80 – Carbon Steel and GIP Number 81 – Specialty Steel Products must provide country of melt and pour (COM) information in the form and manner determined by CBSA when completing customs declarations through the Single Window Integrated Import Declaration. The requirement is a term and condition of using the GIPs, and CBSA notes the conditional COM rules are not expected to be implemented in the SW IID on November 5, though the COM field has been available on an optional basis since February 2024.
CBSA updates surtax and TRQ rules for certain steel goods under SOR/2026-0119
The Canada Border Services Agency states in Customs Notice 25-24 that the Order Imposing a Surtax on the Importation of Certain Steel Goods (SOR/2025-148), as amended by SOR/2025-155, SOR/2025-266 and SOR/2026-0119, applies a 50% surtax on the value for duty of certain steel goods originating outside Canada, the United States and Mexico, with the SOR/2026-0119 amendments effective June 27, 2026 extending the tariff rate quota surtax until June 27, 2027 and changing Schedules 1 and 2.
CBSA stops accepting exporter BN15 accounts for release and accounting under CARM
CBSA states in Customs Notice 24-37 that, effective October 21, 2024, its commercial processing systems will not accept exporter "RM" program accounts to obtain release of imported goods, and the CARM system will not accept a Commercial Accounting Declaration quoting an exporter BN15. Only BN15s set up with an importer or importer/exporter "RM" account profile can obtain release and account for goods.
CBSA to resume late payment penalties and interest on overdue CARM accounts from January 31, 2026
The Canada Border Services Agency states in Customs Notice 25-02 that, between October 21, 2024 and January 30, 2026, it will not issue late payment penalties or late payment interest as a CARM transition measure. Effective January 31, 2026, all accounts with an overdue balance from the January 2026 statement of account will be subject to late payment penalties, and late payment interest will start accruing on overdue balances and appear on the statement of account issued February 25, 2026. Accounts not paid by the specified due date will be subject to collection measures by the Canada Revenue Agency.
U.S. AD/CVD Actions on Chinese Products
Section summaryCommerce preliminarily determined that truck bed covers from China are sold at less than fair value, applicable October 1, 2026, for the period July 1, 2025, through December 31, 2025. Commerce preliminarily determined that large diameter graphite electrodes from China are sold at less than fair value, applicable September 30, 2026. Commerce preliminarily determined that countervailable subsidies are provided to producers of air compressors from China, with a period of investigation of January 1, 2025, through December 31, 2025. Commerce self-initiated a circumvention inquiry on aluminum composite panels from China. The USITC instituted AD/CVD investigations on amine compounds from China.
Federal Register · Commerce ITA (AD/CVD)Official09.30Commerce issues preliminary affirmative LTFV determination on truck bed covers from China
Commerce preliminarily determines that truck bed covers from the People's Republic of China are being, or are likely to be, sold in the United States at less than fair value, applicable October 1, 2026, for a period of investigation of July 1, 2025, through December 31, 2025. Commerce also postpones the final determination and extends provisional measures, and preliminarily treats Wenzhou Tianmao and Wenzhou Chaoming Auto Parts Co., Ltd. as a single entity. The notice does not state the preliminary cash deposit rates.
Federal Register · Commerce ITA (AD/CVD)Official09.29Commerce issues preliminary affirmative LTFV determination on large diameter graphite electrodes from China
Commerce preliminarily determines that large diameter graphite electrodes from the People's Republic of China are being, or are likely to be, sold in the United States at less than fair value, applicable September 30, 2026, for a period of investigation of July 1, 2025, through December 31, 2025. Commerce also made a preliminary affirmative determination of critical circumstances. Interested parties are invited to comment on the preliminary determination.
Federal Register · Commerce ITA (AD/CVD)Official09.30Commerce issues preliminary affirmative countervailing duty determination on air compressors from China
Commerce preliminarily determines that countervailable subsidies are being provided to producers and exporters of stationary and portable air compressors from the People's Republic of China, with the period of investigation January 1, 2025, through December 31, 2025, applicable October 1, 2026. Commerce also aligns the final countervailing duty determination with the final antidumping duty determination. Interested parties are invited to comment on the preliminary determination.
Federal Register · Commerce ITA (AD/CVD)Official10.01Commerce self-initiates circumvention inquiry on aluminum composite panels from China
Commerce is self-initiating a circumvention inquiry to determine whether certain aluminum composite panels (ACPs) produced in China by Shanghai Alumetal Decorative Material Co. (Alumetal) are circumventing the antidumping and countervailing duty orders on common alloy aluminum sheet from China. The inquiry applies as of October 2, 2026. The AD order is at 84 FR 2813 and the CVD order at 84 FR 2157.
Federal Register · USITCOfficial10.03USITC institutes antidumping and countervailing duty investigations on amine compounds from China
The USITC gives notice of the institution of preliminary-phase antidumping and countervailing duty investigations Nos. 701-TA-808 and 731-TA-1809 (Preliminary) into imports of amine compounds from China provided for in HTS statistical reporting numbers 2909.11.00.00, 2921.29.00.55, 2922.19.96.90 and 2934.99.90.01, alleged to be sold at less than fair value and subsidized by the Government of China. The Commission must reach its preliminary determination by November 13, 2026, unless Commerce extends the time for initiation, and transmit its views to Commerce by November 20, 2026. The notice is dated September 29, 2026.
U.S. AD/CVD Actions on Other Countries
Section summaryCommerce preliminarily determined that countervailable subsidies are provided to producers of air compressors from Vietnam, with a period of investigation of January 1, 2025, through December 31, 2025. Commerce preliminarily determined that large diameter graphite electrodes from India are sold at less than fair value, with a period of investigation of January 1, 2025, through December 31, 2025, applicable September 30, 2026. Commerce preliminarily determined that countervailable subsidies are provided to producers of air compressors from Malaysia, with a period of investigation of January 1, 2025, through December 31, 2025, applicable October 1, 2026. Commerce found in the expedited first sunset review that revocation of the CVD order on passenger vehicle and light truck tires from Vietnam would likely resume subsidies.
Federal Register · Commerce ITA (AD/CVD)Official09.30Commerce issues preliminary affirmative countervailing duty determination on air compressors from Vietnam
Commerce preliminarily determines that countervailable subsidies are being provided to producers and exporters of stationary and portable air compressors from the Socialist Republic of Vietnam, with the period of investigation January 1, 2025, through December 31, 2025, applicable October 1, 2026. Commerce also aligns the final countervailing duty determination with the final antidumping duty determination, and interested parties are invited to comment on the preliminary determination. The notice does not state the cash deposit rates.
Federal Register · Commerce ITA (AD/CVD)Official09.29Commerce issues preliminary affirmative LTFV determination on large diameter graphite electrodes from India
Commerce preliminarily determines that large diameter graphite electrodes from India are being, or are likely to be, sold in the United States at less-than-fair-value, with a period of investigation of January 1, 2025, through December 31, 2025, applicable September 30, 2026. Commerce also made a preliminary affirmative determination of critical circumstances and postponed the final determination, extending provisional measures. Interested parties are invited to comment on the preliminary determination.
Federal Register · Commerce ITA (AD/CVD)Official09.30Commerce issues preliminary affirmative countervailing duty determination on air compressors from Malaysia
Commerce preliminarily determines that countervailable subsidies are being provided to producers and exporters of stationary and portable air compressors from Malaysia, with the period of investigation January 1, 2025, through December 31, 2025, applicable October 1, 2026. Commerce also aligns the final countervailing duty determination with the final antidumping duty determination. Interested parties are invited to comment on the preliminary determination.
Federal Register · Commerce ITA (AD/CVD)Official10.03Commerce finds revocation of CVD order on passenger vehicle and light truck tires from Vietnam would likely resume subsidies
Commerce issued the final results of the expedited first sunset review of the countervailing duty order on passenger vehicle and light truck tires from the Socialist Republic of Vietnam, finding that revocation of the order would be likely to lead to continuation or recurrence of countervailable subsidies at the levels indicated in the notice's "Final Results of Sunset Review" section. The notice is applicable October 5, 2026. The order was published at 86 FR 38013 (July 19, 2021), and the five-year sunset review was initiated at 91 FR 32376 (June 1, 2026).
CBSA Dumping and Expiry Determinations
Section summaryOn September 17, 2026, CBSA made a preliminary determination under subsection 38(1) of SIMA that wheat gluten from Italy, Poland, and the United Kingdom is being dumped. CBSA determined under paragraph 76.03(7)(a) of SIMA that expiry of the CITT finding in Inquiry No. NQ-2020-004 is likely to result in continued or resumed dumping of concrete reinforcing bar from Algeria, Egypt, Indonesia, Italy, Malaysia, and Vietnam. CBSA also determined that expiry of the CITT's July 2, 2021 finding in Inquiry No. NQ-2020-005 on hot-rolled deformed steel concrete reinforcing bar from Oman and Russia is likely to result in continued or resumed dumping.
CBSA makes preliminary dumping determination on wheat gluten from Italy, Poland and the UK
The Canada Border Services Agency made a preliminary determination on September 17, 2026, under subsection 38(1) of the Special Import Measures Act, that wheat gluten originating in or exported from Italy, Poland and the United Kingdom is being dumped, and imposed provisional duty on the same date on dumped goods released from that day until the CBSA terminates the investigation or the CITT makes an order or finding.
CBSA determines expiry of rebar finding likely to resume dumping from seven countries
CBSA determined on September 17, 2026, under paragraph 76.03(7)(a) of SIMA, that expiry of the CITT finding in Inquiry No. NQ-2020-004 is likely to result in the continuation or resumption of dumping of certain concrete reinforcing bar from Algeria, Egypt, Indonesia, Italy, Malaysia, Singapore and Vietnam. The goods are hot-rolled deformed steel concrete reinforcing bar in straight lengths or coils, in diameters up to and including 56.4 millimeters, excluding plain round bar and fabricated rebar products, and excluding 10 mm (10M) rebar meeting CSA G30 18.09 coated to ASTM A775/A 775M 04a in lengths from 1 foot up to and including 8 feet.
CBSA determines expiry of rebar finding from Oman and Russia likely to resume dumping
CBSA determined on September 17, 2026, under paragraph 76.03(7)(a) of SIMA, that the expiry of the CITT's July 2, 2021 finding in Inquiry No. NQ-2020-005 on hot-rolled deformed steel concrete reinforcing bar in straight lengths or coils, commonly identified as rebar, originating in or exported from Oman and Russia is likely to result in the continuation or resumption of dumping. The goods are rebar in diameters up to and including 56.4 mm, excluding plain round bar and fabricated rebar products, and excluding 10 mm (10M) rebar meeting CSA G30 18.09 coated to ASTM A775/A 775M 04a in lengths from 1 foot up to and including 8 feet.
Sunset Reviews and Section 337
Section summaryCommerce found in the final results of the expedited fifth sunset reviews that revocation of the AD orders on cut-to-length carbon steel plate from China and Russia would likely lead to continuation or recurrence of dumping. Commerce found in the final results of the expedited third sunset review that revocation of the CVD order on potassium phosphate salts from China would likely continue subsidies. Commerce found in the final results of the expedited second sunset review that revocation of the CVD order on melamine from China would likely continue subsidies. The USITC found a Section 337 violation on storage containers and toolboxes and issued exclusion and cease and desist orders. Commerce also found in the expedited second sunset review that revocation of the AD order on melamine from China would likely lead to continuation or recurrence of dumping.
Federal Register · Commerce ITA (AD/CVD)Official10.03Commerce issues final results of expedited fifth sunset reviews on cut-to-length carbon steel plate from China and Russia
Commerce finds in the final results of the expedited fifth sunset reviews of the antidumping duty orders on certain cut-to-length carbon steel plate from the People's Republic of China and the Russian Federation that revocation of the orders would be likely to lead to continuation or recurrence of dumping at the levels indicated in the "Final Results of Sunset Reviews" section of the notice. The notice is applicable October 5, 2026. The reviews were initiated June 1, 2026 (91 FR 32376), with Cleveland-Cliffs Inc., Nucor Corporation and SSAB Enterprises LLC participating as domestic interested parties.
Federal Register · Commerce ITA (AD/CVD)Official10.03Commerce finds revocation of CVD order on potassium phosphate salts from China would likely continue subsidies
Commerce states in the final results of the expedited third sunset review of the countervailing duty order on certain potassium phosphate salts from the People's Republic of China that revocation of the order would be likely to lead to continuation or recurrence of countervailable subsidies at the levels indicated in the Final Results of Sunset Review section of the notice. The notice is applicable October 5, 2026. The order was published at 75 FR 42682 (July 22, 2010), and the five-year sunset review was initiated at 91 FR 32376 (June 1, 2026).
Federal Register · Commerce ITA (AD/CVD)Official10.01Commerce finds revocation of CVD order on melamine from China would likely continue subsidies
Commerce finds in the final results of the expedited second sunset review of the countervailing duty order on melamine from the People's Republic of China that revocation of the order would be likely to lead to continuation or recurrence of countervailable subsidies at the levels indicated in the notice's "Final Results of Sunset Review" section. The notice is applicable October 2, 2026. The order was originally published at 80 FR 80751 and continued at 86 FR 36252; the review was initiated at 91 FR 32377.
Federal Register · USITCOfficial10.01USITC finds Section 337 violation on storage containers and toolboxes, issues exclusion and cease and desist orders
The U.S. International Trade Commission determined to find a violation of section 337 of the Tariff Act of 1930 with respect to U.S. Patent Nos. 11,365,026 and 11,794,952 covering certain storage containers and toolboxes, organizers, component boxes and coolers, and set the remedy as a limited exclusion order and a cease and desist order on those patents. The Commission set a bond of 18% of entered value for covered articles imported or sold during the period of Presidential review. It has not reached a final determination on U.S. Patent No. 11,952,167, and extended the target date for completion of the investigation to November 2, 2026.
Federal Register · Commerce ITA (AD/CVD)Official10.03Commerce finds dumping likely to continue in expedited second sunset review of melamine from China
Commerce states in the final results of the expedited second sunset review of the antidumping duty order on melamine from the People's Republic of China that revocation of the order would be likely to lead to continuation or recurrence of dumping at the levels indicated in the notice's "Final Results of Sunset Review" section, applicable October 5, 2026. The order was published at 80 FR 80751, and the review was initiated at 91 FR 32376. The domestic interested party is Cornerstone Chemical Company.