Introduction

On April 9, 2026, the U.S. domestic producers filed a petition with the U.S. Department of Commerce (DOC) and the U.S. International Trade Commission (ITC) seeking the imposition of antidumping duties (AD) on imports of tin mill products (“subject merchandise”) from China, Taiwan, and Turkey and countervailing duties (CVD) on subject merchandise from China.

The periods of the AD investigations at DOC cover subject merchandise imported from China from Oct. 1, 2025, to March 31, 2026, and from Taiwan and Turkey from April 1, 2025, to March 31, 2026.

The period of the CVD investigation covers subject merchandise imported from China from Jan. 1, 2025, to Dec. 31, 2025.

The domestic producers that filed the petition are United States Steel Corporation and the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers Union (the “Petitioners”).

Under U.S. law, a domestic industry may petition the U.S. government to initiate AD or CVD investigations into imports alleged to injure the domestic industry.  In an AD investigation, DOC determines whether subject imports are sold in the U.S. at less than fair value (i.e., dumped), while in a CVD investigation, DOC determines whether foreign producers and/or exporters of subject imports received countervailable subsidies. If DOC makes affirmative determinations and the ITC further finds material injury or threat thereof by reason of the subject imports, additional duties may be imposed to offset the dumping or subsidization.

If DOC and the ITC both issue affirmative preliminary determinations, U.S. importers may be required to post cash deposits equal to the estimated AD and CVD duties on all subject imports entered into the U.S. on or after the dates DOC publishes its preliminary determinations in the Federal Register.  Such duties may be imposed 90 days prior to the date of publication of the preliminary determinations if both the DOC and ITC make affirmative critical circumstances determinations.  The preliminary AD and CVD rates may be revised or eliminated in the final phase of the DOC proceeding, particularly where foreign producers/exporters fully participate in the investigation.

Scope

The following describes the imported merchandise that is included within the scope of these investigations:

The products within the scope of these investigations are tin mill flat-rolled products that are coated or plated with tin, chromium, or chromium oxides. Flat-rolled steel products coated with tin are known as tinplate. Flat-rolled steel products coated with chromium or chromium oxides are known as tin-free steel or electrolytic chromium-coated steel. The scope includes all the noted tin mill products regardless of thickness, width, form (in coils or cut sheets), coating type (electrolytic or otherwise), edge (trimmed, untrimmed or further processed, such as scroll cut), coating thickness, surface finish, temper, coating metal (tin, chromium, chromium oxide), reduction (single- or double-reduced), and whether or not coated with a plastic material.

The merchandise subject to these investigations is currently classified in the Harmonized Tariff Schedule of the United States (HTSUS), under HTSUS subheadings 7210.11.0000, 7210.12.0000, 7210.50.0020, 7210.50.0090, 7212.10.0000, 7212.50.0000, if of non-alloy steel and under HTSUS subheadings 7225.99.0090, and 7226.99.0180 if of alloy steel. Although the subheadings are provided for convenience and customs purposes, the written description of the scope of the investigations is dispositive.

Foreign Producers/Exporters and U.S. Importers of Subject Merchandise

A list of foreign producers and exporters of subject merchandise, as identified in the petition, is provided in Attachment 1 – Foreign Producers.

A list of U.S. importers of subject merchandise, as identified in the petition, is provided in Attachment 2 – US Importers.

Alleged Dumping Margins and Subsidy Rates

Petitioners allege dumping margins of 202.02%-1077.08% for imports of subject merchandise from China, 152.15%-160.37% for imports of subject merchandise from Taiwan, and 190.95%-192.91% for imports of subject merchandise from Turkey.

Petitioners allege that producers in China received countervailable subsidies under 18 programs, including tax reductions, grants, preferential financing, and the provision of goods and services for less than adequate remuneration.

DOC generally assigns duties at the margins and rates alleged by the petitioners to foreign producers and exporters that fail to participate and cooperate during the investigations.

Potential Trade Impact

According to the petition, U.S. imports of subject merchandise from China, Taiwan, and Turkey totaled $382,187,000 in 2025.

Estimated Schedule of AD/CVD Investigations

4/9/2026	Petitions Filed
5/26/2026	ITC Preliminary Injury Determination
7/3/2026	DOC Preliminary CVD Determination (un-extended)
9/8/2026		DOC Preliminary CVD Determination (fully extended)
9/16/2026	DOC Preliminary AD Determination (un-extended)
11/5/2026		DOC Preliminary AD Determination (fully extended)
9/16/2026	DOC Final CVD Determination (un-extended)
3/29/2027		DOC Final CVD Determination (fully extended)
12/7/2026	DOC Final AD Determination (un-extended)
3/29/2027		DOC Final AD Determination (fully extended)
1/21/2027	ITC Final Injury Determination (un-extended)
5/13/2027		ITC Final Injury Determination (fully extended)
2/4/2027	AD and CVD Orders Published (un-extended)
5/27/2027		AD and CVD Orders Published (fully extended)

Foreign producers/exporters and U.S. importers or purchasers of subject merchandise with questions about this case should contact Taft’s International Trade practice.