China common alloy aluminum sheet: circumvention inquiry on Alumetal ACPs
Commerce opens a minor-alteration circumvention inquiry on Alumetal aluminum composite panels under the China CAAS Orders. Inquiry merchandise, ALPCO scope background, and CBP deposit instructions.
Commerce self-initiated a circumvention inquiry to determine whether certain aluminum composite panels (ACPs) produced in China by Shanghai Alumetal Decorative Material Co. (Alumetal) circumvent the AD and CVD orders on common alloy aluminum sheet (CAAS) from China. Applicable October 2, 2026 (91 FR 62693; FR Doc. 2026-20256). Cases A-570-073 and C-570-074.
China CAAS circumvention self-initiation on Alumetal ACPs (LDPE core, aluminum skins ≤0.2 mm, panel >0.2 to ≤6.3 mm, 1100 alloy). Companion AD/CVD single inquiry on the AD record. Final within 300 days unless rescinded.
Why Commerce opened this
The CAAS CVD and AD orders published February 6 and 8, 2019. On April 14, 2025, Commerce initiated a scope inquiry on certain ACPs produced by Alumetal and imported by Aluminum Line Products Company (ALPCO). After analyzing that scope-inquiry record, Commerce determined a minor-alteration circumvention inquiry under section 781(c) of the Act and 19 CFR 351.226(j) is warranted if those ACPs are not found covered by the written scope.
Inquiry merchandise
ACPs: LDPE core permanently bonded between two aluminum sheets (each ≤0.2 mm)
Cumulative panel thickness >0.2 mm and ≤6.3 mm · manufactured from 1100 alloy
Producer/exporter in inquiry: Shanghai Alumetal Decorative Material Co. (China)
Single companion AD/CVD inquiry conducted on the AD record (19 CFR 351.226(m)(2))
CAAS order scope covers flat-rolled aluminum sheet thickness greater than 0.2 mm and less than or equal to 6.3 mm (1XXX/3XXX/5XXX not-clad or 3XXX-core clad), currently classifiable under HTSUS subheadings including 7606.11.3060, 7606.11.6000, 7606.12.3090, 7606.12.6000, 7606.91.3090, 7606.91.6080, 7606.92.3090, and 7606.92.6080 (written description controls; aluminum can stock is excluded).
Under 19 CFR 351.226(l)(1), Commerce notifies CBP, directs continued suspension of already-suspended unliquidated entries of inquiry merchandise, and applies the cash deposit rate that would apply if the products were determined to be covered by the Orders. If Commerce later issues an affirmative preliminary or final circumvention determination, it will also instruct suspension and deposits for previously unsuspended unliquidated entries entered or withdrawn on or after the Oct 2, 2026 initiation publication date, and may reach back (not earlier than Nov 4, 2021) under 351.226(l)(2)–(3).
Importer and broker checklist
Map Alumetal ACP entries against the inquiry description now. Watch ACCESS for the Initiation Memorandum and any preliminary determination. Companion AD/CVD results run on the AD record, then Commerce places the final materials on the CVD record. Unless rescinded, Commerce intends a final within 300 days of publication. AD/CVD cash deposits and assessed duties remain generally outside drawback (AD/CVD drawback exclusion).
- Self-initiated circumvention inquiry on Alumetal China ACPs under CAAS China Orders (91 FR 62693; FR Doc. 2026-20256; A-570-073 / C-570-074; applicable Oct 2, 2026).
- Inquiry merchandise: LDPE-core ACPs, aluminum skins ≤0.2 mm each, panel >0.2 to ≤6.3 mm, 1100 alloy, produced by Alumetal in China.
- Background: April 14, 2025 ALPCO/Alumetal scope inquiry record; minor-alteration theory under section 781(c).
- Single companion inquiry on the AD record. CBP continues suspension where already suspended and applies would-be order cash deposits.
- Affirmative prelim/final can expand suspension from Oct 2, 2026 (and possibly earlier, not before Nov 4, 2021). Final within 300 days unless rescinded. AD/CVD generally outside drawback.
- Common Alloy Aluminum Sheet From the People's Republic of China: Initiation of Circumvention Inquiry of the Antidumping Duty and Countervailing Duty Orders (91 FR 62693; FR Doc. 2026-20256) · International Trade Administration, Department of Commerce
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.