Brazil aluminum foil AD: final 2023-2024 review
Cash deposit 13.65% from publication; all-others stays 13.93%. Assessment floor Dec 4 (by our count).
Commerce determines that Companhia Brasileira de Alumínio and CBA Itapissuma Ltda. (collectively CBA), treated as a single entity, made sales of certain aluminum foil from Brazil at prices below normal value during the period of review November 1, 2023 through October 31, 2024. The final weighted-average dumping margin for CBA is 13.65% (A-351-856). The notice was placed on public inspection October 29, 2026 at 8:45 a.m. and is scheduled for publication October 30, 2026 (FR Doc. 2026-22126). Dated October 27, 2026, Scot Fullerton. Contact: Robert Hedberg, (202) 482-0955.
Brazil aluminum foil AD finals: CBA single-entity margin 13.65%. Cash deposit 13.65% from publication; all-others stays 13.93%.
What Commerce decided
- Order: Certain Aluminum Foil from Armenia, Brazil, Oman, Russia, and Turkey: Antidumping Duty Orders, 86 FR 62790 (November 12, 2021).
- POR: November 1, 2023 through October 31, 2024.
- Single entity: Commerce continues to treat Companhia Brasileira de Alumínio and CBA Itapissuma Ltda. as affiliated under sections 771(33)(E) and (G) and as a single entity under 19 CFR 351.401(f). No comments on that preliminary finding.
- Preliminary results: published May 7, 2026. Commerce made certain changes from the preliminary results after comments; see the Issues and Decision Memorandum on ACCESS.
- Issues briefed: whether to treat CBA Aluminio and CBA Itapissuma as a single entity; whether to add taxes related to billing adjustments to the gross unit price; whether insurance expenses were properly deducted from export price.
CBA (single entity) final margin 13.65% · cash deposit 13.65% on/after publication · all-others continues 13.93%
Order: 86 FR 62790 (Nov 12, 2021) · prelims published May 7, 2026 · IDM on ACCESS
Assessment instructions no earlier than 35 days after publication (by our count, Dec 4, 2026) · CIT summons caveat within 90 days
Assessment and cash deposits
For CBA, Commerce calculated importer-specific assessment rates on the ratio of dumping to entered value under 19 CFR 351.212(b)(1). Where an importer-specific rate is de minimis (under 0.5 percent), those entries liquidate without regard to antidumping duties. The reseller policy applies: for POR merchandise produced by CBA where CBA did not know the goods were destined for the United States, unreviewed entries liquidate at the all-others rate if there is no rate for the intermediary.
Commerce intends to issue assessment instructions to CBP no earlier than 35 days after publication. By our count from October 30, 2026, that floor is December 4, 2026. If a timely summons is filed at the Court of International Trade, liquidation of relevant entries waits until the statutory-injunction request window expires (within 90 days of publication; by our count, January 28, 2027).
Cash deposits for CBA equal the 13.65% final margin for entries on or after publication. The all-others rate continues at 13.93% from the LTFV investigation. Importers must file the reimbursement certificate under 19 CFR 351.402(f)(2) before liquidation; failure can lead to a presumption of reimbursement and double antidumping duties.
A separate aluminum foil sunset proceeding is covered in aluminum foil sunset reviews (Oct 2026); that is not this Brazil administrative review.
Antidumping duties are not drawback-eligible (19 U.S.C. 1677h). Ordinary customs duties on the same entries can still qualify when merchandise is exported or destroyed (or used to manufacture exported goods) and the claim otherwise qualifies. See AD/CVD drawback exclusion and how to file a duty drawback claim.
Action items
- Update CBA deposit modeling to 13.65% for Brazil aluminum foil entries on or after the October 30, 2026 publication date.
- Watch the assessment floor: instructions no earlier than December 4, 2026 by our count; flag any CIT summons that pauses liquidation.
- File reimbursement certificates under 19 CFR 351.402(f)(2) before liquidation of POR entries.
- Keep the sunset review separate: the multi-country aluminum foil sunset is a different proceeding from this Brazil admin review final.
- FR Doc. 2026-22126 (A-351-856): Commerce final AD admin review for Brazil aluminum foil, POR Nov 1, 2023–Oct 31, 2024. Public inspection Oct 29; scheduled publication Oct 30, 2026.
- CBA (single entity) final margin 13.65%. Cash deposit 13.65% from publication; all-others continues at 13.93%.
- Importer-specific assessment; de minimis importer rates liquidate without AD. Assessment instructions no earlier than Dec 4, 2026 (by our count).
- AD duties are not drawback-eligible; ordinary duties on the same entries may still qualify when the claim otherwise meets the statute.
- Certain Aluminum Foil from Brazil: Final Results of Antidumping Duty Administrative Review; 2023-2024 (FR Doc. 2026-22126; A-351-856) · U.S. Department of Commerce, International Trade Administration
- Certain Aluminum Foil from Brazil: Final Results of Antidumping Duty Administrative Review; 2023-2024 (public inspection PDF) · Federal Register Public Inspection
- Antidumping and Countervailing Duty Centralized Electronic Service System (ACCESS) · U.S. Department of Commerce, International Trade Administration
- 19 CFR 351.402 - Calculation of export price and constructed export price; reimbursement of antidumping and countervailing duties · eCFR
This article is for general information and is not legal or tax advice. Drawback eligibility depends on your specific facts, and final refunds are determined by CBP at liquidation. Consult a licensed customs broker or attorney for your situation.