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The 2027 Sunset-Review Wave: US AD/CVD Orders Facing Five-Year Reviews

Updated October 2026. Every figure below is recomputed at build time from our structured archive of Federal Register AD/CVD lifecycle documents; provenance notes are embedded in the page source.

Sunset reviews are the moment an antidumping or countervailing duty order can die: five years after an order takes effect, Commerce and the ITC must decide whether revoking it would likely let dumping or subsidization — and the injury behind them — continue. Miss the cycle and you plan your pricing against a duty that may be gone in twelve months; ignore it and you keep paying cash deposits into a review nobody contested. We mined 2,738 Federal Register lifecycle documents covering 198 unique AD/CVD cases, applied a three-layer audit to every five-year anniversary landing in 2027, and found that only 7 product families — 11 case numbers — carry verifiable 2022 original-order dates that put their first sunset review squarely in 2027. Six of those eleven case numbers involve China, and the calendar peaks in May (6 case-number anniversaries). This guide lists every family on the docket, shows which anniversaries fail the audit and why, and gives the compliance calendar importers should actually plan around.

1. How sunset reviews work — and when they land

Under 19 CFR §351.218, Commerce must publish a notice of initiation no later than 30 days before the fifth anniversary of the order (or of the last continuation determination), and both Commerce and the ITC must reach a likelihood-of-continuation-or-recurrence determination within the statutory window. Three practical consequences follow. First, the administrative burden lands in the run-up to the anniversary, so a March 2022 order means paperwork starting late 2026. Second, a review where no interested party responds is usually expedited to revocation — participation (even a minimal notice of appearance) is what keeps an order alive. Third, initiation does not suspend the order: cash deposits and assessment levels continue at existing margins throughout. Our trade remedies lookup shows the current deposit picture per case, and the AD/CVD screen flags whether your HS line sits inside a covered scope.

2. The 2027 docket: seven product families with verifiable dates

Rows are case numbers whose earliest establishment-type Federal Register document is the original order publication, dated 2022, in data/adcvd-orders.json (vintage 2026-10-16T16:09:24Z). Highest published margin is the maximum rate_pct recorded anywhere in the case file — company-specific rates vary. Recompute with python3 .state/scripts/probe_weekly58_sunset_2027.py.

Two features stand out. The refrigerant pair (pentafluoroethane, R-125) anchors the front of the calendar: both the AD and CVD case numbers celebrate their anniversary in March 2027, meaning initiation notices were already due by early February. The vertical-shaft-engine case carries the largest published margin among the seven verified families — 468.33% — which is precisely the kind of rate that makes sunset arithmetic worth tracking: a five-point swing in a continuation decision moves landed cost more than most tariff schedules ever will. Mobile access equipment (HS 8431.20) follows at up to 165.14%, and even the “small” entries matter: organic soybean meal from India looks modest at 3.07%, but CVD exposure stacks on top of the AD margin. For context on how these layered exposures interact with the base schedule, see the Section 301 line-level exposure map; classification fights that begin at lines like these are catalogued in our census of the most disputed HS codes.

3. Methodology: from 2,738 documents to a defensible calendar

Naive arithmetic — take every establishment-dated case, add five years, keep 2027 — produces 36 case numbers. That number is wrong, and showing why is more useful than hiding it. Our audit ladder:

• Layer 1 — establishment census. Among 2,738 lifecycle documents we keep only order-establishment types (order publications, AD orders, CVD orders), deduplicate by case number taking the earliest effective date, and exclude two documents whose titles begin with “Preliminary Results of Changed Circumstances Review” despite carrying establishment type labels. Result: 198 unique cases.
• Layer 2 — anniversary filter. Earliest establishment date + 5 years falling in 2027 leaves 36 case numbers. Monthly spread: February 5, March 4, April 1, May 6, June 2, July 4, August 2, September 2, October 3, November 2, December 5.
• Layer 3 — truncation gate. Our archive window opens at 2020-01-01, so a pre-2020 order whose sunset review was concluded in 2020-2022 still shows establishment-type paperwork dated 2022 — its true anniversary is elsewhere. We flag any case whose earliest archive activity (any document type) predates its establishment date by more than 60 days: 15 of the 36 are such continuation clocks, leaving 21 clean. Example: the Large Residential Washers order dates to 2018; its first sunset review concluded in 2022, so the 2027 date our arithmetic produces is a filing artifact, not a statutory event.
• Layer 4 — originality test. Finally we require the establishment document itself to be the original order publication (title ending in “Antidumping Duty Order”, “Countervailing Duty Order”, or the combined form). That yields the 11 case numbers / 7 product families in the table above — the only anniversaries we will defend statistically. One engine case (A-570-119) survives the gate despite cross-attributed paperwork from a sister investigation polluting its file: the order publication itself is unambiguous, so document-level evidence outranks file hygiene.

Pure Magnesium (A-570-832) illustrates the stakes of getting this right: its “expedited fifth sunset review” concluded in June 2022 — fifth! — so treating its 2022 paperwork as evidence of a first review in 2027 would be wrong by four cycles. When you read competitor calendars built by simple date arithmetic, ask which layer they stopped at. For the full accounting, the appendix below lists all 36 case numbers with their audit verdicts.

4. What to do with these dates

If you export into one of these scopes, the calendar gives you three planning marks. Anniversary minus 30 days: watch for Commerce’s initiation notice in the Federal Register — for the May cluster that means February 2027, and for March anniversaries the notices were already due in early 2027. Initiation plus questionnaires: the ITC and Commerce questionnaires arrive within weeks; foreign producers/exporters who want the order revoked must respond and appear. Determination season: full reviews run questionnaires through hearings; expedited ones move faster precisely because nobody showed up. Throughout, remember that duties remain collectible — model both outcomes with the landed-cost duty calculator before repricing annual contracts. And because revocation decisions turn on likely resurgence of injury, historical import volumes from your own category are the evidence that matters most.

5. Appendix: all 36 case-number anniversaries in 2027

Audit verdicts: “First five-year review” = original order published 2022 (statutory first sunset in 2027); “Continuation clock” = establishment-clustered document consistent with first archive activity; “Pre-window order” = archive shows earlier activity, true order date precedes our collection window. Recompute with python3 .state/scripts/probe_weekly58_sunset_2027.py (ROSTER section).

6. Frequently asked questions

1. What is a sunset review of an AD/CVD order?

A periodic proceeding required roughly every five years under 19 CFR §351.218: Commerce determines whether dumping or subsidisation would likely continue or recur if the order were revoked, and the ITC asks the same about material injury. If both answers are affirmative the order continues; otherwise it is revoked. The review exists because trade-remedy orders are not supposed to outlive the conditions that justified them.

2. Which orders face sunset reviews in 2027?

In our audited census, 11 case numbers across 7 product families carry verifiable 2022 original-order publication dates that place their first five-year review in 2027: pentafluoroethane (R-125) from China, certain mobile access equipment from China, organic soybean meal from India, walk-behind snow throwers from China, sodium nitrite from Russia, certain large vertical shaft engines (225cc-999cc) from China, and certain superabsorbent polymers from Korea. Thirty-six case numbers show a 2027 five-year anniversary before auditing; the difference is explained by continuation clocks and archive-window truncation.

3. When will Commerce initiate the 2027 sunset reviews?

Commerce must publish the initiation notice no later than 30 days before each five-year anniversary. For the wave counted here that means notices start appearing in winter 2026-2027: the March anniversaries (R-125) trigger initiations by early February 2027, the May cluster by April 2027, and December anniversaries by November 2027.

4. Do duties stop during a sunset review?

No. Initiation or conduct of a sunset review does not suspend the underlying order: importers keep posting cash deposits at existing rates and entries keep being assessed unless Commerce instructs otherwise. Revocation, if it comes, applies going forward from the revocation date rather than retroactively erasing deposits made while the order stood.

5. How did you count these cases?

We parsed 2,738 Federal Register lifecycle documents covering 198 unique case numbers, kept establishment-type documents (order publications, AD orders, CVD orders), took each case's earliest effective date, added five years, and kept 2027 anniversaries. We then audited every survivor: excluding continuation clocks whose true order predates our 2020 archive window (15 case numbers) and requiring the establishment document itself to be the original order publication, 11 case numbers in 7 product families remain. Every figure is recomputable from the public archive with the commands printed beneath each exhibit.

7. Recap

• 7 product families (11 case numbers) face their first sunset reviews in 2027, with anniversaries clustering in May (6 of 36 case-number anniversaries across all tiers).
• China accounts for 22 of the 36 case-number anniversaries country-tagged in the file, and 6 of the 11 verified first-review case numbers.
• Naive five-year arithmetic overcounts by 25 case numbers here — mostly continuation clocks from pre-2020 orders our archive window truncates.
• Reviews are decided by participation: no appearance, no contest, revocation — which importers should price for either direction.