Most duties are final at entry. Antidumping and countervailing duties are not. The rate collected at the border is a cash deposit, an estimate, and the final bill is calculated later, sometimes years later, after an administrative review the importer may not even know is happening. For goods under an AD or CVD order, the entry price of a product includes a liability nobody can state exactly on the day it lands.
How the deposit system works
When Commerce finds dumping or subsidised imports injuring a US industry, it issues an order covering defined products from defined countries. CBP collects cash deposits at the rate assigned to the exporter, which can range from a few percent to several hundred, and can differ sharply between exporters of the same product from the same country.
Later, interested parties can request an administrative review of entries from a given period. Commerce recalculates the actual margin, CBP liquidates the entries at the final rate, and the importer gets a bill or a refund for the difference, with interest. A deposit rate of 20 percent can settle at 4, or at 60. The importer of record owns that difference either way.
Scope is the first fight
Orders define covered goods by written scope, not by tariff code alone, and the scope rulings and circumvention inquiries around popular orders are a literature of their own. A product just outside the scope enters clean. A product just inside it, misjudged, enters with years of accumulating exposure, because uncollected AD duties do not expire quietly when discovered.
Importers in scope adjacent products need a documented scope analysis before the first shipment, kept in the entry file: the order text, the product's specifications, any scope ruling relied on. Confirm current order status and deposit rates with a licensed customs broker before sourcing, because rates change with each review and new shipper reviews add exporters mid stream.
Pricing with an unknowable duty
Honest landed cost for covered goods carries a range, not a point. Prudent importers price at a stressed rate, hold a reserve for the review outcome, and treat a favourable final rate as a windfall rather than the plan. Contracts with customers that fix prices for years, written against a deposit rate as if it were final, are how AD exposure turns from a cost into a crisis.
Pass through clauses, duty adjustment terms, and shorter price validity windows are the commercial tools. The importers who survive big upward reviews are rarely the ones who predicted the rate. They are the ones whose paperwork never promised the rate away.
Why the liability follows the importer
When the final bill arrives and the foreign exporter has vanished, CBP collects from the importer of record and, failing that, the surety on the bond. That is also why bonds for AD covered goods get extra scrutiny: a large potential assessment sits behind entries that looked routine. Anyone importing covered product on thin margins with a minimum bond is stacking two estimates and calling it a plan.
Keep reading
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Frequently asked questions
What is the difference between antidumping and countervailing duties?
Antidumping duties respond to sales below fair value, essentially exporting at unfairly low prices. Countervailing duties respond to foreign government subsidies. Both are collected as estimated cash deposits at entry and can be adjusted after administrative reviews.
Why are AD and CVD rates not final at entry?
Because the deposit rate is an estimate set in advance. Commerce can later review actual entries for a period and calculate the real margin, after which entries liquidate at the final rate and the importer pays or is refunded the difference, with interest.
How do I know if my product is covered by an AD or CVD order?
Check the order's written scope against your product's specifications, not just its tariff classification. Orders and current deposit rates are published by Commerce and applied by CBP. Given the liability involved, confirm with a licensed customs broker before importing scope adjacent goods.
Who pays if the final AD rate is higher than the deposit?
The importer of record owes the difference at liquidation, and the customs bond's surety stands behind that obligation. The liability cannot be passed to the foreign exporter after the fact unless a contract specifically provides for it.