Antidumping and countervailing duty entries do not work like ordinary tariff entries, and the difference surprises importers exactly once. At entry, the importer posts cash deposits at the rate currently in effect for the exporter and product. That deposit is an estimate. The final duty is set later, when the Department of Commerce completes an administrative review of the period's sales and calculates the actual dumping margin or subsidy rate for that period. If the reviewed rate comes in above the deposit rate, the importer owes the difference on every entry in the period, with interest. If it comes in below, the excess is refunded, also with interest. Reviews take years, which means an importer can carry a contingent duty liability across several financial statements without any single entry looking wrong. It also means the deposit rate in a costing model is a placeholder with a distribution around it, and on products with a history of review swings, that distribution is wide enough to change whether the product should be imported at all.
The review system rewards importers who track exporters, not just orders
Deposit and review rates attach to the exporter or producer, in combination with the product and country, not to the importer's purchase order. The same product from two exporters can carry very different exposure, and an exporter's rate can move sharply between an investigation and its first review as Commerce replaces facts available estimates with calculated margins. Importers who know only their own deposit rate are missing the operative data: their exporter's review history, whether the exporter participated and cooperated, and whether a review has been requested for the current period. That information is public, in Federal Register notices and Commerce's records, and a half day of reading it beats any surprise assessment.
Related reading on this site: TariffWatch HQ and How to Read a Tariff Notice Without Getting the Date Wrong cover the neighbouring problems in more depth.
Evasion enforcement runs alongside the rate system
Because AD/CVD orders carry heavy rates, they attract evasion: transhipment through third countries, misdeclared origin, minor alterations claimed to take a product outside an order's scope. The Enforce and Protect Act gives CBP a formal investigation process for evasion allegations, with interim measures that can include suspending liquidation and requiring cash deposits on entries from importers under investigation. For honest importers the lesson is about sourcing hygiene. An offer to route an order covered product through a neighbouring country at a price that ignores the order is not a sourcing innovation. It is an invitation to become the importer of record on an EAPA case, with liability for the full duties the routing was built to dodge.
Bond sufficiency meets its hardest case here
AD/CVD exposure is also where continuous bond calculations strain, because the bond is sized on duties paid while the real exposure includes a review adjustment that has not been assessed yet. Importers with meaningful AD/CVD volume should discuss the contingent liability with their surety before the surety discovers it in a sufficiency review, and should carry the possible adjustment in their own numbers at a realistic rate, not the deposit rate that flatters the margin. The importers who get hurt are never the ones who knew the exposure and priced it. They are the ones whose model had one rate in it, labelled final, that never was.
Frequently asked questions
Are antidumping cash deposits the final duty owed?
No. Cash deposits at entry are estimates. The final liability is set by the Department of Commerce's administrative review of the period, and the difference between the reviewed rate and the deposit rate is billed or refunded with interest.
How long can an AD/CVD review adjustment take to arrive?
Years is normal. A review covers a defined period, is conducted after that period closes, and liquidation of the affected entries waits for the results, sometimes under court challenge. Importers should treat the exposure as a contingent liability in the meantime.
What is the Enforce and Protect Act?
The EAPA is the statute under which CBP investigates allegations that AD/CVD duties are being evaded, for example through transhipment or misdeclared origin. Investigations can lead to interim measures such as suspension of liquidation and additional cash deposit requirements.
Why does the exporter matter for AD/CVD rates?
Because dumping margins and subsidy rates are calculated for specific exporters and producers. Two exporters of the same product from the same country can carry very different deposit and review rates, so sourcing decisions are also duty exposure decisions.