Commerce opens circumvention inquiry on Chinese corrosion-resistant steel via Thailand, China-rate deposits continue
Importers of CORE completed in Thailand from Chinese components must carry China-order cash deposits and remain under suspension of liquidation while Commerce's circumvention inquiry proceeds
Change
On 6 July 2026 Commerce initiated a circumvention inquiry into whether corrosion-resistant steel from China completed in Thailand circumvents the existing AD/CVD Orders, and directed CBP to continue suspension of liquidation and apply the China-order cash-deposit rate to affected entries while the inquiry proceeds.
Why it matters
While the circumvention determination is pending, the notice carries an immediate consequence for importers: CBP continues to suspend liquidation and applies the China-order cash-deposit rate to Thai-completed CORE entries covered by the inquiry. Commerce will issue questionnaires to Thai producers and exporters and select respondents from CBP data; non-responsive companies face facts available, including adverse inferences under section 776. Importers cannot assume Thai-completed CORE is outside the Orders' scope during the inquiry.
Implications
- — Import compliance teams and customs brokers clearing CORE completed in Thailand from Chinese-origin components must ensure affected entries carry the China-order cash-deposit rate and remain under suspension of liquidation — treating the goods as non-subject during the inquiry risks under-deposit and assessment at the China rate at liquidation.
- — Importers must reconcile prior and ongoing Thai-completed CORE entries against the continued suspension of liquidation, since CBP will apply the applicable China-order deposit rate to covered entries while the inquiry is open.
- — Thai producers and exporters of corrosion-resistant steel must respond fully to Commerce's questionnaires within the deadlines set, or Commerce may apply partial or total facts available, including adverse inferences under section 776 of the Tariff Act.
Who is affected
- — Import compliance teams and customs brokers clearing Thai-completed CORE through U.S. customs
- — U.S. importers of corrosion-resistant steel sourced via Thailand
- — Thai producers and exporters of corrosion-resistant steel subject to Commerce's questionnaires
What to watch
- — Ongoing: CBP continues suspension of liquidation and applies the China-order cash-deposit rate to covered Thai-completed CORE entries while the inquiry proceeds.
- — Pending: Commerce's circumvention determination, following questionnaires to Thai producers/exporters and respondent selection from CBP data — outcome will fix whether the goods are covered by the Orders.