U.S. Sets Preliminary 66.61% Countervailing Duty on Chinese Tin Mill Products

What did the U.S. Department of Commerce decide on September 10, 2026?

The U.S. Department of Commerce preliminarily determined a 66.61% countervailing duty on Chinese tin mill products on September 10, 2026. The determination is preliminary and affirmative, so it is not yet a final duty determination.

The published rate is the same preliminary rate for Shougang Holding Trade (Hong Kong) Ltd., Shougang Jingtang United Iron & Steel Co. Ltd., and all other Chinese companies. The rate is expressed ad valorem. An ad-valorem duty is stated as a percentage of an underlying customs value, but the supplied facts do not specify the customs value to be used for an individual entry.

The proceeding concerns Chinese tin mill products, meaning the tin mill products covered by the investigation, including the white tin-coated steel products commonly described as tinplate. The supplied information does not provide a complete list of tariff classifications, technical specifications, or product exclusions. An importer therefore cannot determine coverage solely from the general word “tinplate.”

What does a preliminary affirmative determination mean?

A preliminary affirmative determination means that Commerce has reached a positive preliminary finding in the countervailing duty proceeding. It does not mean that the 66.61% rate is final or that every shipment described commercially as Chinese tinplate will automatically receive that rate.

A countervailing duty is a trade remedy duty imposed in a proceeding addressing countervailable benefits received by foreign producers or exporters. The supplied facts identify the preliminary rate but do not identify the individual programs, financing arrangements, or other circumstances used to calculate it.

This distinction matters for planning. A preliminary determination can affect the risk assessment for U.S.-bound shipments before the proceeding is complete. It does not, however, provide a basis for treating the preliminary rate as an unchangeable final cost.

Which companies are identified?

Commerce identified Shougang Holding Trade (Hong Kong) Ltd., Shougang Jingtang United Iron & Steel Co. Ltd., and all other Chinese companies at the same preliminary 66.61% rate. Importers should keep these company categories distinct in their transaction records.

The phrase “all other Chinese companies” is a category used in the proceeding. It does not replace a case-specific review of the manufacturer, exporter, seller, product, and documents connected with a U.S. entry.

An importer should therefore review more than the name on a commercial invoice. The relevant file should connect the actual product with the companies involved in manufacturing, selling, and exporting it. The supplied sources do not provide a complete list of documents required for every U.S. entry, so this review is a risk-control measure rather than a definitive statement of customs requirements.

Is another proceeding still open?

Yes. The parallel antidumping investigation into Chinese tin mill products is still ongoing. An antidumping proceeding examines whether imported goods are sold at a dumped price and whether the imports cause or threaten material injury to the domestic industry. It is legally distinct from a countervailing duty proceeding, even where both proceedings concern similar products.

The preliminary 66.61% rate should therefore not be treated as a complete statement of every possible trade-remedy cost. The supplied facts do not state a final antidumping rate. A cost model that includes only the preliminary countervailing duty may be incomplete if the parallel proceeding later produces an additional or different amount.

No conclusion about the outcome of the antidumping investigation follows from the preliminary countervailing duty rate alone. Importers should keep the two proceedings separate in internal calculations and records.

When is the final determination scheduled?

The final countervailing duty determination has been aligned with the final determination in the parallel antidumping proceeding and is currently scheduled for December 1, 2026, unless the date is postponed. This is a current schedule, not a guarantee that the decision will be issued on that date.

The final rate, the final treatment of the covered goods, and the outcome of the parallel proceeding remain open. The supplied information does not establish a reason to predict an earlier or later date. Importers should therefore monitor direct publications from the responsible U.S. agencies before committing to transactions that depend on a specific duty assumption.

What did the USITC decide?

On May 22, 2026, the U.S. International Trade Commission found a sufficient indication of material injury to the U.S. industry from the investigated imports and continued the investigations. Material injury is a legally relevant injury to the domestic industry in this proceeding; the supplied facts do not provide further economic detail.

The USITC action is separate from Commerce’s preliminary countervailing duty determination of September 10, 2026. The USITC addressed the injury question, while Commerce announced the preliminary countervailing duty finding. Both actions form part of the wider proceeding, but they are not the same decision.

The USITC’s May 22 action confirms that the investigations continued. It does not establish a final 66.61% duty and does not replace the final Commerce determination that is still pending.

How should importers model the possible cost?

Importers shipping to the United States should run a temporary scenario using the published 66.61% ad-valorem rate. This is a planning scenario, not a conclusion that the final duty will remain unchanged.

A useful internal model should separate the following points:

Review area	What is established	What remains open
Proceeding	Preliminary affirmative countervailing duty determination on September 10, 2026	The final determination is pending
Preliminary rate	66.61% ad valorem for the identified company categories	The final amount and application may change
Product	Proceeding concerning Chinese tin mill products	The supplied facts do not include the complete product scope
Parallel case	Antidumping investigation continues	No final antidumping rate is provided
Timing	Final decision currently scheduled for December 1, 2026	The date may be postponed

The table separates established procedural facts from open issues. It is not a binding duty calculation for a particular entry.

Which contract terms should be reviewed?

Contracts for U.S.-bound shipments should clearly allocate the risk of a new preliminary or final duty. The supplied facts do not prescribe a particular contract clause; reviewing contract language is a practical recommendation, not a statement of applicable contract law.

First, check whether the price is fixed or can be adjusted when import duties change. Next, check whether the contract distinguishes countervailing duties, antidumping duties, and other import costs. Finally, identify who is responsible for accurate product descriptions, manufacturer information, and supporting records.

A contract should not silently assume that the preliminary 66.61% rate will become final. A pricing model should also not assume that the parallel antidumping investigation will create no additional exposure. For existing orders, review whether the contract links the allocation of costs to the order date, shipment date, entry date, or another event. The supplied sources do not identify which contractual event controls.

Which records should be checked?

Importers should check whether their records describe the manufacturer, seller, product, and Chinese origin consistently. The sources do not provide a complete document checklist for every U.S. entry, so this review should not be presented as an exhaustive list of customs requirements.

A practical internal matrix should include at least the supplier, manufacturer, product description, technical specification, invoice value, shipment reference, and connection to the U.S. proceeding. Each entry should be supported by existing business records rather than assumptions.

The distinction between a manufacturer and a trading company deserves particular attention. The Commerce announcement names both Shougang Holding Trade (Hong Kong) Ltd. and Shougang Jingtang United Iron & Steel Co. Ltd. This makes precise company identification relevant to the file. It does not mean that every transaction involving one of these names automatically receives identical legal treatment in every circumstance.

What should importers do before the final decision?

The following five steps help prevent outdated cost assumptions while preserving the distinction between preliminary and final findings:

1. Define the product: Compare the actual product description with the scope of the proceeding. Do not use “tinplate” alone as the coverage test.
2. Record the parties: List the manufacturer, seller, exporter, and other known parties separately, using the names appearing in the transaction records.
3. Run scenarios: Compare the shipment economics without the preliminary duty and with a 66.61% ad-valorem scenario. Label both calculations as planning scenarios.
4. Review the contract: Search for clauses covering duty changes, price adjustments, delivery timing, and responsibility for import records.
5. Monitor the proceeding: Check Commerce and USITC publications before making firm commitments, particularly around the currently scheduled December 1, 2026 final determination.

These steps do not replace individual customs or legal advice. They make the preliminary decision visible in procurement, sales pricing, contract review, and documentation.

What is still uncertain?

The final countervailing duty rate, the outcome of the parallel antidumping investigation, and the status of the December 1, 2026 schedule remain uncertain. The supplied information also does not include the complete tariff classification list, a transaction-specific calculation, or a final conclusion for every possible shipment.

The accurate working description is therefore “a preliminary 66.61% countervailing duty.” A final import or release decision should also consider the actual product scope, the companies involved, and the latest official agency publications.

Sources

• U.S. Department of Commerce: Preliminary Affirmative Countervailing Duty Determination of Tin Mill Products from China, published September 10, 2026.
• U.S. International Trade Commission: USITC Votes to Continue Investigations on Tin Mill Products from China, Taiwan, and Turkey, published May 22, 2026.

Sources

Research checked on 2026-09-12. The following original sources support the factual claims:

• U.S. Department of Commerce, International Trade Administration – Preliminary Affirmative Countervailing Duty Determination of Tin Mill Products from China (2026-09-10): Das Handelsministerium nennt die vorläufige positive Entscheidung und einen Ausgleichszollsatz von 66,61 % für Shougang Holding Trade, Shougang Jingtang und alle übrigen chinesischen Unternehmen; die endgültige Entscheidung ist derzeit für den 1. Dezember 2026 vorgesehen.
• U.S. International Trade Commission – USITC Votes to Continue Investigations on Tin Mill Products from China, Taiwan, and Turkey (2026-05-22): Die USITC stellte eine hinreichende Wahrscheinlichkeit einer materiellen Schädigung durch die untersuchten Importe fest und setzte die Untersuchungen zu chinesischen Tin Mill Products fort.