TRADE LAW | 2026-09-24

Commerce Revokes the Aluminum Sheet Orders in Part for Certain Can Stock — Across Seventeen Countries, and Retroactively

A rare piece of trade news that removes duties rather than adding them: changed circumstances reviews covering 21 antidumping and countervailing duty case numbers, applicable September 24, 2026.

On September 24, 2026 the U.S. Department of Commerce issued the final results of changed circumstances reviews of the antidumping and countervailing duty orders on common alloy aluminum sheet from China, Bahrain, Brazil, Croatia, Egypt, Germany, India, Indonesia, Italy, Oman, Romania, Serbia, Slovenia, South Africa, Spain, Taiwan and Türkiye — revoking the orders, in part, with respect to certain aluminum can stock. Commerce found that changed circumstances warranted retroactive revocation, and

On September 24, 2026 the U.S. Department of Commerce published the final results of changed circumstances reviews of the antidumping and countervailing duty orders on common alloy aluminum sheet, revoking those orders in part with respect to certain aluminum can stock. The determination is applicable September 24, 2026.

Almost every trade remedy development an importer reads about adds cost. This one removes it, and it does so across an unusually wide front.

The scale: seventeen countries, twenty-one case numbers

The reviews cover the orders on aluminum sheet from the People's Republic of China, Bahrain, Brazil, Croatia, Egypt, Germany, India, Indonesia, Italy, Oman, Romania, Serbia, Slovenia, South Africa, Spain, Taiwan and the Republic of Türkiye.

Twenty-one separate antidumping and countervailing duty case numbers are named, including A-570-073 and C-570-074 for China, A-525-001 and C-525-002 for Bahrain, A-351-854 for Brazil, A-533-895 and C-533-896 for India, and A-489-839 and C-489-840 for Türkiye, among others.

An importer sourcing can stock from more than one of these countries has been carrying parallel exposure under several orders at once. A partial revocation that reaches all of them simultaneously is therefore worth more than the same relief in a single case would be.

What a changed circumstances review is, and why this one is unusual

A changed circumstances review is the mechanism by which Commerce revisits an order when the facts underlying it have moved. The most common trigger is that the domestic industry no longer has an interest in relief for a particular product — typically because it does not make that product, or no longer does.

What makes this one notable is the retroactive element. Commerce published its initiations and preliminary results on August 11, 2026, finding that changed circumstances warranted retroactive revocation of both the China orders and the Bahrain and others orders, in part, with respect to certain aluminum can stock. Interested parties were given the opportunity to comment and to request a public hearing on those preliminary results before these final results issued.

Prospective revocation changes what you pay going forward. Retroactive revocation reaches entries already made — which is why the first thing an affected importer should do is look backwards.

Scope is the whole question

The revocation is in part, and it is limited to certain aluminum can stock. Neither of those qualifiers is decorative.

The orders on common alloy aluminum sheet remain in force for everything the revocation does not reach. Whether a given shipment falls inside the revoked description or outside it is a scope question, and scope questions are decided on the precise product characteristics — alloy, temper, gauge, coating, width, and intended use — set out in the notice's own scope language, not on what the commercial invoice calls the goods.

The practical error to avoid is assuming that because you import "can stock," the revocation covers you. An importer should read the revoked description against its own mill certificates and specifications, product by product, before changing anything about how it enters merchandise.

What an affected importer should do, in order

First, determine whether your product is within the revoked scope. Do this from documentation — mill certs, specifications, purchase orders — rather than from category labels. Where the answer is not obvious, it is a scope ruling question, and getting it wrong in either direction is costly: treating covered goods as revoked invites a penalty, and treating revoked goods as covered means continuing to pay duties you no longer owe.

Second, identify your unliquidated entries. Retroactive revocation matters most for entries that have not yet liquidated, because those are the ones where the duty outcome is still open.

Third, look at entries that have already liquidated. Where a liquidated entry falls within a retroactive revocation, the questions become reliquidation and refund — and those run on their own deadlines under the customs laws. An importer who waits to see what happens will find the procedural window is the binding constraint, not the merits.

Fourth, check your cash deposit rates. Commerce will issue instructions to CBP, and deposits should stop being collected on revoked merchandise. Importers should confirm that what CBP is actually collecting matches what the revocation provides, rather than assuming the instruction propagated correctly.

Fifth, revisit your bond. Continuous bond sufficiency is calculated partly on duties paid. A material reduction in AD/CVD exposure can change what level of bond you need, and that is worth raising with your surety rather than leaving over-bonded.

Sixth, look at sourcing decisions made under the orders. Importers who moved away from a covered origin specifically because of these duties may now find the economics different. That is a commercial decision, but it should be made on current facts.

The documentation point, which is the one that decides refunds

Whether relief converts into money depends on whether an importer can prove, from its own records, that specific entries contained merchandise within the revoked description. That proof is built from mill certificates, specifications and entry documentation retained at the time — not reconstructed afterwards.

Importers who have been through a CBP audit or Focused Assessment will recognise the pattern: the entitlement and the recovery are separate problems, and the second one turns entirely on records. The same discipline that protects an importer in an audit is what makes a refund claim provable here.

The same is true of tariff classification. Scope and classification are distinct analyses, but both are decided on product characteristics, and an importer whose classification positions are documented and consistent is in a far stronger position to argue a scope question than one whose entries vary without explanation.

Context: this week ran both directions

It is worth setting this against the rest of the month. September 2026 brought final antidumping and countervailing determinations on solar cells from India at rates above 100 percent, a preliminary circumvention finding on brake drums from China reaching back to January, a third-country circumvention finding on garment hangers assembled in Cambodia reaching back thirteen months, and a new anti-stockpiling rule for polysilicon.

Against that, a seventeen-country partial revocation is a reminder that trade remedy orders are not permanent fixtures. They are reviewed, narrowed, and sometimes revoked, and an importer who treats an order as a fixed cost of doing business may be paying duties on merchandise that is no longer covered.

Trembach Law Firm advises importers on scope, changed circumstances reviews, refund and reliquidation claims and the entry records that make them provable. To review whether your can stock falls within this revocation, call (818) 514-7680 or contact a California customs attorney. Importers moving metal through the San Pedro Bay complex can reach our Los Angeles port customs practice directly.

Frequently Asked Questions

Which orders were revoked, and for what product?

Commerce revoked the antidumping and countervailing duty orders on common alloy aluminum sheet in part, with respect to certain aluminum can stock, across China, Bahrain, Brazil, Croatia, Egypt, Germany, India, Indonesia, Italy, Oman, Romania, Serbia, Slovenia, South Africa, Spain, Taiwan and Türkiye — twenty-one case numbers in total.

Is the revocation retroactive?

Commerce found that changed circumstances warranted retroactive revocation, in part, and said so in its August 11, 2026 initiation and preliminary results. That is why the first step for an affected importer is to look at entries already made rather than only at entries to come.

Does this mean aluminum sheet is no longer subject to duties?

No. The revocation is in part and limited to certain aluminum can stock. The orders remain in force for everything the revocation does not reach, and whether a given shipment falls inside the revoked description is a scope question decided on product characteristics in the notice's own scope language.

How would I get money back on entries that already liquidated?

Through reliquidation and refund, which run on their own deadlines under the customs laws. The entitlement and the recovery are separate problems, and the second one turns on whether your own records — mill certificates, specifications and entry documentation — prove that specific entries contained merchandise within the revoked description.

What should I check first?

Whether your product is genuinely within the revoked scope, determined from documentation rather than from the label can stock. Getting that wrong in either direction is costly: treating covered goods as revoked invites a penalty, and treating revoked goods as covered means continuing to pay duties you no longer owe.

This article is provided for general informational purposes only and is not legal advice. Reading it does not create an attorney-client relationship. Whether particular merchandise falls within a revoked scope, and whether any refund is available, depends on the specific products, entries and procedural posture involved. No particular outcome is guaranteed. Consult a qualified attorney about your own circumstances.

Contact Trembach Law Firm at (818) 514-7680 for a confidential consultation.

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