AD/CVD

AD/CVD is the combined US trade-remedy regime under which the Department of Commerce (USDOC) calculates antidumping and countervailing duties on imports of specific products from specific countries, and US Customs and Border Protection (CBP) enforces the cash-deposit and final-duty assessment at entry. AD/CVD operates on a parallel-track basis: Commerce conducts a Less-Than-Fair-Value (LTFV) investigation for the antidumping side and a subsidy investigation for the countervailing side, often simultaneously on the same product from the same country. The result is a single AD/CVD order that imposes both duty types on imports.

How AD/CVD differs from a tariff or Section 301 duty

The defining feature of AD/CVD is that the duty rate is producer-specific or exporter-specific, not HTS-code-specific. Two Chinese factories shipping the same product under the same HTS code can face different AD/CVD rates because Commerce calculated different dumping margins or subsidy benefits for each. The factory’s assigned rate is the cash-deposit rate that the US importer must post at entry.

The cash-deposit mechanic

When an AD/CVD order is in force, every entry of the covered product from the covered country triggers a cash deposit:

1. At entry. The US importer posts a cash deposit (or a bond) equal to the producer’s current cash-deposit rate × the entered value. The rate is from Commerce’s most recent administrative review, or from the original investigation if no review has yet been completed.
2. During the period. The cargo clears CBP and enters US commerce. The cash deposit sits with CBP.
3. Administrative review. Annually, Commerce reviews the producer’s actual sales prices and home-market data to calculate the producer’s actual rate for the prior year (the period of review, POR).
4. Liquidation. Commerce instructs CBP to liquidate the entries from the POR at the actual rate. If the actual rate is higher than the cash-deposit rate, the importer pays the difference plus interest. If lower, the importer receives a refund.
5. New cash-deposit rate. The actual rate for the just-completed POR becomes the cash-deposit rate going forward, until the next review.

The cash-flow consequence: AD/CVD is settled per-entry on a multi-year delay. An importer can post deposits for two years before learning the final liquidation rate. For a USD 1 million annual import volume at a 50% AD/CVD rate, USD 500,000 sits in CBP’s escrow for the full review cycle. The cash-flow cost is real and is rarely modelled into landed-cost calculations until an importer feels it.

Common Chinese chemical products under AD/CVD

These rates change at every administrative review. The numbers here are indicative, always confirm current rates from the Commerce ACCESS portal or the CBP ACE database before booking.

How AD/CVD catches importers off guard

Three failure patterns recur:

1. Importer assumes the published rate is final. The cash-deposit rate posted at entry is provisional. Two years later, the actual liquidation rate may be substantially higher, producing an unanticipated bill. Sometimes the difference exceeds the importer’s available cash. CBP collection is aggressive.
2. New shipper review trap. A “new shipper” Chinese factory not in the original investigation can request a new shipper review to receive its own rate. During the review window (typically 6-12 months), entries are at the country-wide rate, which is often the worst-case rate. New shippers regularly underestimate this and ship at terms that crash their margins.
3. Producer-importer-broker confusion. The cash-deposit rate is producer-specific, not importer-specific. Two importers buying from the same Chinese factory pay the same rate. But customs brokers sometimes file under the wrong producer code, applying the wrong rate. Reconciliation is painful.

Sunset reviews

Every AD/CVD order is subject to a sunset review every 5 years. The International Trade Commission (ITC) and Commerce jointly determine whether revoking the order would lead to a continuation or recurrence of dumping/subsidisation and material injury to the US industry. If yes, the order is renewed for another 5 years; if no, the order is revoked.

For Chinese chemical orders, sunset reviews almost always result in continuation. The petitioner US industry has the burden to show ongoing risk; in practice, Commerce and ITC almost always find for continuation when the petitioner has any domestic production.

How AD/CVD interacts with Section 301 and standard tariffs

The duty types stack:

• HTS tariff (the standard rate) applies first
• Section 301 (if the product is on the China list) applies on top
• AD/CVD (if covered by an order) applies on top of both

For citric acid from China at HTS 2918.14.00, the import duty stack in 2026 is:

These stack on the entered value. A USD 100,000 shipment of Chinese citric acid generates a cash deposit of USD 162,000 to USD 346,000, depending on the producer.

How Chinese exporters track AD/CVD

For a Chinese factory shipping into the US:

1. Confirm whether your product is covered. Check the Commerce ACCESS portal for active orders by HTS code and country.
2. Confirm your cash-deposit rate. Each producer has its own rate, listed in the most recent administrative review or in the original investigation.
3. Track sunset review timing. Five-year cycles; the order may be revoked at sunset.
4. Engage a US customs broker familiar with AD/CVD. Mistakes at the broker level produce the most expensive failures.

Related terms

Anti-Dumping Duty is the parent entry for the AD side. Countervailing Duty is the parent entry for the CVD side. Section 301 is the parallel China-specific tariff regime. HTS Code classification determines whether AD/CVD applies. TSCA is the chemical-inventory regime that applies in parallel. Duty Drawback is the refund mechanism for re-exported goods, which can recover AD/CVD paid on inputs that did not enter US commerce.