Claiming AD/CVD Refunds: The Administrative Review Playbook for US Importers

Last updated 2026-10-21·Data: 19 CFR 351.212–351.214 + 19 U.S.C. 1675(a)(3) + Federal Register-mined case feed

Most importers treat an antidumping or countervailing duty rate as a final bill: look up the percentage, wire the money, move on. The United States runs the opposite system — a retrospective assessment regime under which final liability is decided after the goods arrive, in annual reviews most buyers never think to join. That blind spot costs real money both ways: importers keep paying deposit rates long after market conditions have moved past them, and they forfeit interest-bearing over-deposits that a timely request would have unlocked.

Cash deposits are not final duty

When CBP suspends liquidation of your entry under an AD/CVD order, the percentage you post is an estimate — what Commerce believed the margin was when the order issued, possibly years before your shipment. Under 19 CFR 351.212(a), the amount actually owed is determined later, by dividing the dumping margin or subsidy found on examined merchandise by its entered value, and applying that assessment rate to the entered value of everything covered by the review period. The gap between the deposit rate and the assessed rate flows either direction: you can owe more, but you can also claw back over-deposits — with interest calculated from deposit through liquidation under section 778 of the Act.

The anniversary-month window

Reviews are not continuous; they open once a year. During each anniversary month of the order's publication, three parties can act (19 CFR 351.213(b)): domestic producers asking Commerce to examine specific exporters; the exporter or producer itself, requesting a review of only its own rate; and the importer, who may request a review limited to the exporter whose merchandise it entered. An importer who wants out of a country-wide rate does not need to convince anyone first — filing the written request inside the month-long window is enough to force the calculation.

Miss the window and nothing dramatic happens — which is exactly the trap. With no timely request, Commerce instructs CBP to assess duties automatically at the cash-deposit rate in effect at entry (19 CFR 351.212(c)(1)). Your provisional number becomes permanent without any notice landing in your inbox.

The statutory clock, worked end to end

The deadlines below are recomputed at generation time from the statute for a hypothetical order published April 15, 2024 — so its anniversary month is each April:

Two escape valves matter in practice. A requester may withdraw within 90 days of the initiation notice, and Commerce may rescind the review outright for periods with no subject shipments. Conversely, if nobody objects, the initiation can be deferred a full year — useful when the market needs two more seasons to settle before your margin reflects reality.

What a review is worth in dollars

Take a scenario constant across many steel and aluminum cases: an importer entering $$500,000 of subject goods per year at a 25% cash-deposit rate. Two review cycles later Commerce finds the true margin is 10%. The arithmetic:

That $$75,000 sits with CBP until someone opens the review. It earns interest the whole time — but only for importers whose entries were covered by a completed review; the automatic-assessment path returns nothing.

Recent final results from the live case feed

To show what reviewed margins look like when they land, here are the highest-rate final administrative results currently in our Federal Register-mined dataset of 211 trade-remedy actions (84 final results spanning 2026-07-13 to 2026-10-13); the top row shows a 541.8% final rate:

Every rate above started life as somebody's cash deposit. Importers who tracked these notices knew the trajectory years in advance; those who did not kept posting deposits at the old rate until liquidation made the difference permanent.

New exporters: the one-year side door

If your supplier was not exporting to the US during the investigation period, it may qualify as a new shipper under 19 CFR 351.214 and request an individual rate within one year of its first entry  — backed by proof of bona fide sales at arm's-length prices. Until that review concludes, CBP keeps collecting at the country-wide rate, so timing the first entry relative to the request matters for cash flow. Buyers negotiating EXW or DDP terms should care: whoever economically bears the deposit, the refund accrues to the importer of record's account.

The importer's playbook, condensed

1. Map every SKU against active orders with the AD/CVD lookup and note each order's publication date — it sets the anniversary month.
2. Calendar the anniversary month annually. File the written request then; an importer may target just its own exporter.
3. Track the resulting FR notices (initiation, preliminary, final) and reconcile CBP's liquidation bills against the final assessment rate.
4. Claim interest on over-deposits — it accrues from deposit date through liquidation by operation of law.

Ongoing monitoring of rate changes, new orders and scope rulings is part of our tariff monitoring plans; the free tier covers basic lookups.

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Related guides

• landed-cost duty calculator.
• AD/CVD duty lookup by HS code.
• AD/CVD stacked cash-deposit exposure calculator.
• active trade-remedy actions mapped to HS chapters.
• tariff monitoring plans.