An administrative review is the annual process where Commerce recalculates the antidumping and countervailing duty rate for a specific exporter, and the new rate replaces the cash deposit rate on future entries. The rate can go up or down, and the change applies to entries going forward, not to entries already liquidated. Softwood lumber is the current example: the final AD/CVD rate reached 24.75 percent, and with the 10 percent Section 232 duty on top, the total is 34.75 percent.
The deposit is an estimate, and the review settles it
When goods subject to an antidumping or countervailing duty order enter the United States, the importer pays a cash deposit at the rate set in the investigation. That rate is an estimate, based on the exporter's pricing during the investigation period. It is not the final duty. The final duty is set later, in an administrative review, and the review can change the rate in either direction.
The review happens annually, for exporters who request it, and it recalculates the dumping margin from the exporter's actual sales and costs during the review period. If the margin fell, the rate falls, and the importer gets a refund of the difference. If the margin rose, the rate rises, and the importer pays the difference. The deposit is a down payment. The review is the settlement.
Softwood lumber: the number that keeps moving
Softwood lumber from Canada is the most watched AD/CVD case in the country, and its rate has moved at nearly every review. The final AD/CVD rate reached 24.75 percent, and with the 10 percent Section 232 duty added on top, the total duty on Canadian softwood lumber is now 34.75 percent. That is more than a third of the entered value, before the base MFN rate.
The rate matters because lumber is a volume business. A homebuilder importing a million dollars of lumber pays $347,500 in AD/CVD and Section 232 duties alone. The number moves at each review, and the movement is driven by the exporters' pricing, not by politics. A review that finds lower dumping margins cuts the rate. A review that finds higher margins raises it. The importers who watch the reviews price the change into their contracts. The ones who do not learn about it from the invoice.
Other rates that moved at review
Softwood is not the only case. The all-others countervailing duty rate, the rate that applies to exporters who were not individually investigated, was lowered from 14.19 percent to 12.80 percent at review. Vietnamese shrimp carries a countrywide rate of 25.76 percent, which applies to exporters who have not earned an individual rate. Each of these numbers came from a review, and each of them replaced a deposit rate that was different.
The lesson is that the rate on the order is not the rate you pay. The rate you pay is the rate from the most recent review, for your specific exporter, on your specific entries. An importer who prices a deal on the investigation rate is pricing on a number that may be years out of date.
What to do before the next review
The first step is to know your exporter's rate, and when the next review is due. The review schedule is public, and the Department of Commerce publishes the initiation notices in the Federal Register. If your exporter is under review, the rate you are paying now is the deposit rate, and the final rate will be set when the review concludes.
The second step is to budget for the range. A review can move the rate up or down by several points, and the change applies to entries going forward, not retroactively. A contract that prices the goods at the deposit rate, with no adjustment for a review, is a contract that absorbs the difference. Build the range into the price, or build the adjustment into the contract. Either way, do not pretend the rate is fixed, because it is not.
Keep reading
Related guides on this site: post-entry amendments and fixing a filed entry before liquidation protests, CBP Form 19, and the 180-day window reconciliation entries and fixing value, classification, and origin More from Tariff changes caught before they hit your margins.
Frequently asked questions
What is an administrative review?
The annual process where Commerce recalculates the AD/CVD rate for a specific exporter, based on that exporter's actual sales and costs during the review period. The new rate replaces the cash deposit rate.
Can the rate go down?
It can go either way. If the exporter's dumping margin fell, the rate falls. If it rose, the rate rises. The review is a recalculation, not a negotiation, and the number comes from the exporter's own data.
What is the current duty on softwood lumber?
The final AD/CVD rate reached 24.75 percent, and with the 10 percent Section 232 duty added, the total duty on Canadian softwood lumber is 34.75 percent.
What do importers pay while a review is pending?
They pay the cash deposit rate at entry, and the final rate is set at review. If the final rate is lower, the importer gets a refund. If it is higher, the importer pays the difference. The deposit is an estimate, and the review settles the account.