The U.S. Department of Commerce, through its International Trade Administration, published a notice in the Federal Register on December 8, 2025, announcing the opportunity for interested parties to request administrative reviews of various antidumping duty (AD) and countervailing duty (CVD) orders, findings, and suspended investigations. This annual process, tied to the anniversary months of November and December, allows stakeholders to seek reviews that could adjust duty rates on imported goods. The notice covers dozens of products from multiple countries, with requests due by December 31, 2025, following a tolling of deadlines due to a federal government shutdown. This development underscores Commerce's role in enforcing fair trade practices under the Tariff Act of 1930, potentially affecting importers, exporters, and domestic industries by recalibrating duties based on actual market conditions during specified review periods.
Background on Antidumping and Countervailing Duty Reviews
Administrative reviews are a core mechanism in U.S. trade law, established under section 751 of the Tariff Act of 1930, as amended. These reviews enable the Department of Commerce to examine the actual amount of dumping or subsidization occurring in the period following the issuance of an AD or CVD order. Dumping occurs when foreign producers sell goods in the U.S. at prices below their home market value or production costs, while countervailing duties address subsidies provided by foreign governments. The process is initiated upon request from interested parties, defined in section 771(9) of the Act, which include domestic producers, importers, exporters, and foreign governments.
Historically, this framework traces back to the Antidumping Act of 1921 and has evolved through amendments like the Trade Agreements Act of 1979 and the Uruguay Round Agreements Act of 1994. Key precedents, such as the Court of International Trade's ruling in Union Steel v. United States (2012), have emphasized the need for Commerce to base calculations on verifiable data, ensuring transparency and fairness. Politically, these reviews reflect ongoing tensions between free trade advocates and protectionist interests, with administrations often prioritizing domestic industry protection amid global supply chain disruptions.
In this notice, Commerce highlights its discretion in managing reviews, including respondent selection when the number of companies is too large for individual examination. This is governed by section 777A(c)(2) of the Act, where Commerce typically selects the largest exporters by volume, using U.S. Customs and Border Protection (CBP) data.
Listed Orders and Review Periods
The notice enumerates specific AD and CVD orders eligible for review, segmented by anniversary month. For November 2025 AD proceedings, items include aluminum foil from countries like Armenia, Brazil, and Oman; oil country tubular goods from Argentina, Mexico, and Russia; and various steel products from nations such as India, Indonesia, and China. Review periods generally span from November 1, 2024, to October 31, 2025, with some variations, such as Russia's ferrosilicon from June 28, 2024, to October 31, 2025.
CVD proceedings for November cover products like paper file folders from India and aluminum foil from Oman, with periods from January 1, 2024, to December 31, 2024. December 2025 listings expand to include non-oriented electrical steel from Germany, Japan, and others; forged steel fittings from India and Korea; and crystalline silicon photovoltaic cells from China. Periods here are typically December 1, 2024, to November 30, 2025, for AD, and January 1, 2024, to December 31, 2024, for CVD, with adjustments for certain shrimp products.
Suspended investigations, such as Ukraine's cut-to-length carbon steel plate and Mexico's sugar agreements, are also included. These lists reflect Commerce's broad oversight, covering commodities critical to industries like construction, energy, and manufacturing.
Procedural Details and Requirements
Commerce outlines precise procedures under 19 CFR 351.213. Requests must be filed electronically via the ACCESS system by December 31, 2025, specifying producers or exporters and reasons for the review. The notice accounts for a government shutdown from October 1 to November 13, 2025, tolling deadlines by 47 days, as detailed in a November 14, 2025, memorandum.
For respondent selection, Commerce intends to use CBP import data, released under administrative protective order (APO) within five days of initiation. Comments on this data are due within five days, with selections finalized within 35 days. The notice addresses 'collapsing' of companies—treating affiliated entities as one—only if previously determined, avoiding new analyses at this stage.
Withdrawal of requests is permitted within 90 days of initiation, extendable case-by-case. On particular market situations (PMS), introduced by the Trade Preferences Extension Act of 2015, allegations must be submitted within 20 days of initial Section D questionnaire responses, allowing Commerce to adjust cost calculations if market distortions are found, per section 773(e) of the Act.
For non-market economy countries like China, the notice clarifies that the entity as a whole is not automatically reviewed unless specifically requested, aligning with practices announced in 2013 Federal Register notices.
Updates to the Annual Inquiry Service List
A significant aspect is the maintenance of the annual inquiry service list (AISL), established under regulations finalized in September 2021. This list ensures interested parties receive notifications for scope rulings and circumvention inquiries. The notice invites updates within 30 days, with petitioners and foreign governments automatically retained. This enhances administrative efficiency, reducing oversights in trade remedy proceedings.
Implications and Perspectives
Short-term implications include potential duty adjustments that could increase costs for importers or provide relief to domestic producers facing unfair competition. For instance, reviews of Chinese steel products might lead to higher duties if dumping is confirmed, impacting sectors like infrastructure. Long-term, consistent enforcement could deter unfair practices but raise concerns about trade barriers, as voiced by organizations like the World Trade Organization.
Domestic industries view these reviews as essential for market protection, while exporters argue they can be overly burdensome. Legal experts note that outcomes often hinge on data accuracy, with appeals possible to the Court of International Trade.
In summary, this notice facilitates a structured review process critical to U.S. trade policy. Potential next steps include timely request submissions, followed by Commerce's initiation notice in early 2026. Ongoing debates may center on balancing enforcement with global trade relations, especially amid economic uncertainties. Challenges include verifying foreign data and addressing PMS claims, which could shape future methodologies.
