US Commerce Preliminary Affirmative Countervailing Duty Determination: Tin Mill Products from China (September 2026)

Mechanism

Commerce's Enforcement and Compliance unit preliminarily found that Chinese producers/exporters of tin mill products (tinplate and related tin-coated steel sheet used chiefly for food, beverage and aerosol cans) received countervailable subsidies. Because the mandatory respondents — Shougang Holding Trade (Hong Kong) Ltd. and Shougang Jingtang United Iron & Steel Co. Ltd. — did not fully cooperate, Commerce applied facts available with adverse inferences, yielding a single 66.61% subsidy rate applied to both named respondents and to the all-others rate (all other Chinese exporters/producers not individually examined). Commerce also preliminarily found critical circumstances, which lets it apply provisional suspension-of-liquidation and cash-deposit requirements to entries as far back as 90 days before the preliminary determination, addressing a surge of pre-duty stockpiling. Per 19 CFR 351.210(b)(4), Commerce aligned the final CVD determination to issue on the same date as the final antidumping determination in the companion AD case (case A-570-228, preliminarily determined 2026-09-17), currently scheduled no later than 2026-11-30. Case number C-570-229.

Downstream implications

• A 66.61% CVD rate stacks with the companion AD case's cash-deposit rate

(130.17%, already netted against this CVD finding to avoid double-counting the export-subsidy component), pushing combined preliminary duty exposure on Chinese tin mill products well past prohibitive levels for US buyers.

• Petitioner beneficiaries are domestic tin mill producers; downstream

packaging/can manufacturers sourcing tinplate from China face materially higher landed costs unless they shift to domestic or non-Chinese mills.

• The critical-circumstances retroactive window exposes importers who

stockpiled ahead of the preliminary determination to unexpected cash-deposit liability on entries made in the prior ~90 days.

Open questions

• Whether either Shougang respondent belatedly cooperates before the final

determination, potentially earning a calculated (non-AFA) company-specific rate.

• Scale of pre-preliminary-determination import stockpiling caught by the

critical-circumstances retroactive window.

• Whether the US International Trade Commission's concurrent injury

determination confirms both the AD and CVD orders before they become definitive.