US AD/CVD order record · dataset entry, not legal advice.
Source: Federal Register · data retrieved 2026-10-16T15:58:05Z
The product subject to these Orders is amorphous silica fabric with silica content of at least 90 percent from China. For a complete description of the scope of the Orders, see the Initiation Decision Memorandum dated concurrently with this notice. See Memorandum, ``Decision Memorandum for Initiation of Anti-Circumvention Inquiry,'' dated concurrently with and hereby adopted by this notice (Initiation Decision Memorandum). Merchandise Subject to the Circumvention Inquiry This circumvention inquiry covers amorphous silica fabric with silica content between 70 and 90 percent produced in China and exported to the United States. Legal Framework Section 781(c) of the Act provides that Commerce may find circumvention of an AD or CVD order when merchandise of the same class or kind as merchandise has been ``altered in form or appearance in minor respects . . . whether or not included in the same tariff classification.'' Section 781(c)(2) of the Act provides an exception that ``{p{time} aragraph 1 shall not apply with respect to altered merchandise if the administering authority determines that it would be unnecessary to consider the altered merchandise within the scope of the {order{time} .'' While the Act is silent regarding the factors to consider in determining whether alterations are properly considered ``minor,'' the legislative history of this provision indicates that there are certain factors that should be considered before reaching a circumvention determination. In conducting a circumvention inquiry under section 781(c) of the Act, Commerce has generally relied upon ``such criteria as the overall physical characteristics of the merchandise, the expectations of the ultimate users, the use of the merchandise, the channels of marketing and the cost of any modification relative to the total value of the imported products.'' Concerning the allegation of minor alteration under section 781(c) of the Act and 19 CFR 351.225(i), Commerce examines such factors as: (1) Overall physical characteristics; (2) expectations of ultimate users; (3) use of merchandise; (4) channels of marketing; and, (5) cost of any modification relative to the value of the imported products. See Carbon and Certain Alloy Steel Wire Rod from Mexico: Initiation of Anti-Circumvention Inquiry of Antidumping Duty Order, 83 FR 5405 (February 7, 2018) (citing S. Rep. No. 71, 100th Cong., 1st Sess. 100 (1987)). Id.; see also Deacero S.A. de C.V. v. United States, 817 F.3d 1332 (Fed. Cir. 2016). Section 781(d) of the Act provides that Commerce may initiate an circumvention inquiry to determine whether merchandise developed after an AD or CVD investigation is within the scope of the order(s). In conducting later-developed merchandise inquiries under section 781(d)(1) of the Act, Commerce will evaluate whether: (1) The general physical characteristics of the merchandise subject to the inquiry are the same as subject merchandise covered by the order(s); (2) the expectations of the ultimate purchasers of the merchandise subject to the inquiry are no different to the expectations of the ultimate purchasers of subject merchandise; (3) the ultimate use of the inquiry merchandise and subject merchandise are the same; (4) the channels of trade of both products are the same; and, (5) there are any differences in the advertisement and display of both products. First, however, Commerce applies a commercial availability test to determine whether the merchandise subject to the inquiry was commercially available at the time of the investigation(s) (i.e., the product was present in the commercial market or the product was tested and ready for commercial production). See section 781(d)(1) of the Act. See Later-Developed Anticircumvention Inquiry of the Antidumping Duty Order on Petroleum Wax Candles from the People's Republic of China: Affirmative Preliminary Determination of Circumvention of Antidumping Duty Order, 71 FR 32033, 32035 (June 2, 2006), unchanged in Later-Developed Merchandise Anticircumvention Inquiry of the Antidumping Duty Order on Petroleum Wax Candles from the People's Republic of China: Affirmative Final Determination of Circumvention of the Antidumping Duty Order, 71 FR 59075 (October 6, 2006). Analysis After analyzing the record evidence and the petitioner's allegation, we determine that there is sufficient information to warrant the initiation of a minor alterations circumvention inquiry, pursuant to section 781(c) of the Act and 19 CFR 351.225(i). However, we determine that initiation of a later-developed merchandise circumvention inquiry, pursuant to section 781(d) of the Act and 19 CFR 351.225(j), is not warranted. For a full discussion of the basis for our decision to initiate a minor alterations circumvention inquiry, but not a later-developed merchandise circumvention inquiry, see the Initiation Decision Memorandum. The Initiation Decision Memorandum is a public document, on file electronically via Enforcement and Compliance's Antidumping and Countervailing Duty Centralized Electronic Service System (ACCESS). ACCESS is available to registered users at https://access.trade.gov . In addition, a complete version of the Initiation Decision Memorandum can be accessed directly at http://access.trade.gov/public/FRNoticesListLayout.aspx .
Scope text quoted verbatim from the Federal Register notice. Scope text retrieved: 2026-10-19T16:17:45Z. Record last fetched: 2026-10-16T15:58:05Z. Verify against the official notice before relying on it.
| HTSUS (dotted) | 8-digit | Description (USITC reference) |
|---|---|---|
| 7019.90.11 | 70199011 | Woven |
| 7019.90.51 | 70199051 | Other |
The scope text also references HS prefix(es) 701940, 701951, 701952, 701959 that we do not yet resolve against our USITC HTS reference table; they are shown verbatim instead of being guessed.
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At a glance
The antidumping and countervailing measure covers Certain Amorphous Silica Fabric, imported from China. Case number C-570-039 is one of 540 active orders tracked in the database and was established 2021-11-24; the described product range determines which ten-digit lines inherit the cash-deposit obligation. Scope language in the Federal Register document controls.
As of dataset vintage 2026-10-16T16:09:24Z, yes: importers entering covered goods post a cash deposit at the current rate until Commerce's next administrative review publishes revised margins in the Federal Register. Deposit rates can change every review cycle, so confirm the latest Federal Register notice before you quote a figure to your customs broker.
These HTS headings are recorded in the case linkage: 7019.90.11, 7019.90.51. Confirm the exact ten-digit code against the published scope language, because product descriptions rather than codes alone define the legal boundary of the order, and scope rulings occasionally widen or narrow which lines inherit the deposit obligation.
Primary sources: Federal Register — C-570-039 · USITC Harmonized Tariff Schedule — republished with provenance by exportsonar.com