Importers should be aware that there are now related third-country cases for merchandise from Canada and Mexico that contain aluminum components extruded in China. Certain goods from these countries may now “flag” for possible AD/CVD for aluminum extrusions from China. If merchandise from Canada or Mexico contains aluminum components extruded in China that were further processed or assembled in Canada or Mexico, the aluminum extrusion portion may be subject to AD/CVD under the cases below.

Canada Third Country Case (China): A122-158/C122-159

Mexico Third Country Case (China): A201-158/C201-159

There is also a third country case covering goods from China containing aluminum extruded in Thailand, and it is possible that there will be more to come.

China Third Country Case (Thailand): A570-300

On May 7, 2024, the U.S. Department of Commerce issued its preliminary affirmative determination on antidumping duties (ADD) for imports of aluminum extrusions from the following 14 countries.

• China
• Colombia
• Ecuador
• India
• Indonesia
• Italy
• Korea
• Malaysia
• Mexico
• Taiwan
• Thailand
• Turkey
• Vietnam
• United Arab Emirates

The scope of the orders is broad and includes  “aluminum extrusions contained in merchandise that is a part or subassembly of a larger whole.” It also covers aluminum extrusions that have been further processed in a third country prior to export to the U.S., including certain finishing and fabrication processes as well as assembly with other aluminum extrusion components or with non-aluminum extrusion components.

Antidumping and Countervailing Duty (AD/CVD) orders generally cover products from the country identified in the AD/CVD order. In some cases, however, merchandise produced in the country of an AD/CVD order may undergo further processing in a third country before being imported into the U.S. This means that even though the aluminum extrusion is further processed or assembled in another country, for AD/CVD purposes, the merchandise could still fall under the scope of the AD/CVD orders of the original country, yet for Customs and Border Protection (CBP) purposes, the country of origin of the imported merchandise could be the third country where the goods were further processed or assembled. Commerce may issue third-country AD/CVD cases to identify and “flag” shipments of goods from these countries as possibly being subject to the AD/CVD cases of the original country.

Importers should review all components of their products to determine whether they contain extruded aluminum components, and if they do, identify the country where the aluminum was extruded.

Determining whether your goods are included in the scope of these orders is complex. If you need guidance determining whether your imported products are subject to AD/CVD, Tradewin can help.