TRADE LAW | 2026-09-23

Five New Antidumping Investigations on Linear Hydraulic Cylinders — Alleged Margins Run From 56 Percent to 744 Percent

Commerce has initiated less-than-fair-value investigations covering Canada, China, India, Korea and Mexico, with parallel countervailing duty petitions on China, India and Mexico.

On September 14, 2026 the U.S. Department of Commerce published the initiation of antidumping investigations covering certain linear hydraulic cylinders and parts thereof from Canada, the People's Republic of China, India, the Republic of Korea, and Mexico — case numbers A-122-879, A-570-240, A-533-952, A-580-923 and A-201-870. The petitions, filed July 29, 2026 by the Hydraulic Cylinders Fair Trade Coalition and nine named domestic producers, allege dumping margins ranging from 56.79 percent on

On September 14, 2026 the U.S. Department of Commerce published the initiation of less-than-fair-value investigations on certain linear hydraulic cylinders and parts thereof from Canada, the People's Republic of China, India, the Republic of Korea, and Mexico. The investigations carry case numbers A-122-879 (Canada), A-570-240 (China), A-533-952 (India), A-580-923 (Korea) and A-201-870 (Mexico), and are applicable September 8, 2026.

For California distributors, equipment manufacturers, and the agricultural, construction and material-handling businesses that buy cylinders as components, this is the stage of a trade remedy proceeding where decisions are still cheap and information is still gettable.

Who filed, and what they allege

Commerce received the antidumping petitions on July 29, 2026, filed on behalf of the Hydraulic Cylinders Fair Trade Coalition and its individual members: Aggressive Hydraulics Inc., Hol-Mac Corporation, Ligon Hydraulics, Prince Manufacturing Corporation, PTC Alliance LLC, Rosenboom Machine & Tool Inc., Scot Industries Inc., Stillwell Inc., and Texas Hydraulics Inc. — all domestic producers of linear hydraulic cylinders. Countervailing duty petitions accompanied the antidumping petitions for imports from China, India and Mexico.

Based on comparisons of export price to normal value under sections 772 and 773 of the Act, Commerce reports the estimated dumping margins alleged in the petitions as:

Canada — 248.33 to 744.85 percent.
China — 149.86 to 394.07 percent using a Malaysia surrogate; 103.05 to 197.07 percent using a Mexico surrogate; 299.38 to 440.48 percent using a Türkiye surrogate.
India — 85.31 to 370.67 percent.
Korea — 73.09 to 158.74 percent.
Mexico — 56.79 to 157.12 percent.

Read those numbers correctly

These are alleged margins drawn from the petitions. They are not findings, and they are not what anyone will necessarily pay. Commerce's role at initiation is to determine that the petitions meet the requirements of section 732 of the Act — not to test whether the alleged margins survive scrutiny.

The recent record shows how wide the gap can be. In the fatty acids investigation from Malaysia, where both examined respondents cooperated and Commerce calculated real margins, the rates came out at 4.47 and 7.07 percent. In the solar cells investigation from India, where every examined rate rested on adverse inferences, they came out at 123.04 percent. Petition allegations sit at the top of the range by design; where a case lands depends heavily on whether respondents participate.

Note also the three surrogate-country figures for China. Because China is treated as a non-market economy, normal value is constructed using surrogate values, and the choice of surrogate moves the answer by hundreds of percentage points — 103 percent using Mexico, 440 percent using Türkiye. Surrogate country selection is a live, contestable issue in every NME case, and it is one where importers and their suppliers have something useful to say.

The periods of investigation

Under 19 CFR 351.204(b)(1), the period of investigation for the Canada, India, Korea and Mexico investigations is July 1, 2025 through June 30, 2026. Because China is a non-market economy country, the period for the China investigation is January 1, 2026 through June 30, 2026.

Those windows define the sales Commerce will examine. Importers reconciling their own purchase history against this proceeding should use the right period for the right country.

Scope is still moving — and that is the opportunity

The scope has already been revised once. Between August 3 and September 2, 2026 Commerce requested information and clarification from the petitioners to ensure the proposed scope accurately reflected the products for which the domestic industry sought relief. Between August 11 and September 4, 2026 the petitioners provided clarifications and revised the scope. The description in the appendix to the initiation notice reflects those revisions.

That history matters. Scope language is drafted by petitioners, and petitioners draft broadly. The description of covered merchandise routinely captures products the domestic industry does not make and did not intend to reach — particular bore sizes, particular applications, parts and sub-assemblies, cylinders built into finished equipment.

The window for comment on scope is early in a proceeding, and it is the single most valuable contribution an importer can make. An argument that a specific product falls outside the scope is far more effective before the scope is fixed than in a scope ruling request years later, after entries have been suspended and deposits collected.

What happens next, and how fast

The investigations now run on a statutory schedule. The U.S. International Trade Commission makes a preliminary injury determination, and if that is negative the proceedings terminate. If it is affirmative, Commerce proceeds to preliminary determinations — in accordance with section 733(b)(1)(A) of the Act and 19 CFR 351.205(b) — at which point suspension of liquidation and cash deposits begin.

Commerce and the ITC apply the same statutory definition of the domestic like product under section 771(10) of the Act, but for different purposes and under separate authority, and the notice observes that this can produce different definitions without either agency being contrary to law. Importers should not assume that a favorable read from one agency settles the question at the other.

What importers and OEMs should do this month

First, read the scope in the appendix to the initiation notice against your actual part numbers. Do not rely on a summary, and do not assume that because you buy a finished machine you are outside it — "and parts thereof" is in the title of these investigations.

Second, identify your producers by name and country. Five countries are covered. A distributor sourcing across several of them has several different exposures maturing on the same schedule.

Third, decide now whether to participate. Importers can enter appearances, comment on scope, and engage on surrogate country selection in the China case. Each of those is far cheaper now than litigating a scope ruling later.

Fourth, ask your suppliers whether they intend to respond to Commerce's questionnaires. That single answer is the best available predictor of the rate you will eventually pay, because a non-cooperating respondent's adverse-inference rate flows through to the all-others rate that uninvestigated producers receive.

Fifth, model the cash flow. If preliminary determinations are affirmative, deposits begin on entries made from that date. At the alleged margins, that is a working-capital event, and bond capacity should be discussed with your surety before it is needed rather than after.

Sixth, get classification settled. Scope disputes and tariff classification questions are closely related but not identical, and a documented, consistent classification position is the foundation for arguing either. Where sourcing may shift in response to these cases, the country of origin and substantial transformation analysis should be done before goods move, not after — the garment hanger circumvention determination published this month is a reminder of what happens when a route change is made without one.

The strategic read

A five-country filing with parallel countervailing petitions on three of them is a comprehensive action. It is designed to close the alternative sourcing routes simultaneously rather than sequentially, which is what importers learned the hard way in the solar and steel proceedings, where each new order simply moved production to the next jurisdiction.

Importers whose response to a duty order has historically been to change country should assume that option is narrower here, and should plan around price and contract terms rather than around geography.

Trembach Law Firm advises importers, distributors and equipment manufacturers on trade remedy investigations, scope comments and the entry consequences that follow. To discuss participation or exposure in these investigations, call (818) 514-7680 or contact our Los Angeles port customs practice.

Frequently Asked Questions

Which countries and case numbers are covered?

Canada (A-122-879), the People's Republic of China (A-570-240), India (A-533-952), the Republic of Korea (A-580-923) and Mexico (A-201-870). Countervailing duty petitions accompanied the antidumping petitions for imports from China, India and Mexico.

Are the 56 to 744 percent figures what I will actually pay?

No. Those are margins alleged in the petitions, not findings. Commerce's role at initiation is to determine that the petitions meet the requirements of section 732 of the Act, not to test whether the alleged margins survive scrutiny. Petition allegations sit at the top of the range by design, and where a case lands depends heavily on whether respondents participate.

Why does China show three different ranges?

Because China is treated as a non-market economy, normal value is constructed using surrogate values, and the choice of surrogate moves the answer substantially: 149.86 to 394.07 percent using Malaysia, 103.05 to 197.07 percent using Mexico, and 299.38 to 440.48 percent using Türkiye. Surrogate country selection is a live, contestable issue in every NME case.

What are the periods of investigation?

Under 19 CFR 351.204(b)(1) the period for the Canada, India, Korea and Mexico investigations is July 1, 2025 through June 30, 2026. Because China is a non-market economy country, the period for the China investigation is January 1, 2026 through June 30, 2026. Importers reconciling their purchase history should use the right period for the right country.

Is it worth doing anything now, before any duties exist?

This is the stage where decisions are cheapest. The scope has already been revised once — Commerce sought clarification from petitioners between August 3 and September 2, 2026, and petitioners revised the scope between August 11 and September 4, 2026. Scope language is drafted by petitioners and routinely captures products the domestic industry does not make. An argument that a product falls outside the scope is far more effective before the scope is fixed than in a scope ruling request years later.

When do cash deposits actually start?

The ITC makes a preliminary injury determination first, and if that is negative the proceedings terminate. If it is affirmative, Commerce proceeds to preliminary determinations under section 733(b)(1)(A) and 19 CFR 351.205(b), at which point suspension of liquidation and cash deposits begin.

This article is provided for general informational purposes only and is not legal advice. Reading it does not create an attorney-client relationship. The margins described above are allegations contained in petitions, not findings, and outcomes depend on the specific record of each proceeding. 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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