Published April 17, 2026
Anti-dumping duties (ADD) and countervailing duties (CVD) are the most dangerous blind spot in the China import tariff picture. They're separate from Section 301 and IEEPA, they apply at the product level rather than the broad category level, and they can be enormous — 50%, 100%, 200%, sometimes higher. Importers who correctly calculate MFN + Section 301 + IEEPA and then get hit with an AD/CVD order they didn't know existed discover very quickly that their product is no longer importable at any workable margin.
This is not an edge case. Active ADD/CVD orders against Chinese goods cover hundreds of product categories involving billions of dollars in annual imports. If your product is a manufactured good in a category where US producers have lobbied for trade protection, there's a real chance an order exists.
Anti-dumping duties apply when the US Department of Commerce finds that foreign producers are selling goods in the US at less than fair value — in other words, below their cost of production or below the price they sell at in their home market. The legal rationale is that predatory pricing drives out US competition and constitutes unfair trade.
Countervailing duties apply when Commerce finds that foreign governments are subsidizing their producers in ways that give them an unfair advantage in the US market. This is common in sectors where China's government has provided direct subsidies, below-market loans, preferential land use, or other forms of support.
The two programs are often applied together — an investigation may find both dumping and subsidization, resulting in ADD + CVD on the same product. They're calculated separately and assessed separately, but the practical effect is that both apply at import.
The investigation process:
The cash deposit requirement is critical: you pay estimated duties at import at the preliminary or current deposit rate, then you may owe more or receive a refund after annual review depending on how Commerce calculates the actual margin. For some Chinese companies, rates are set on a country-wide basis when they haven't cooperated with the investigation — these "China-wide" rates are often punitive (100-200%+).
To illustrate the scale difference: Section 301 tariffs max out at 25% for most goods (with some Biden-era increases to 50-100% for specific categories). ADD/CVD rates can be multiples of that.
Selected active ADD/CVD orders against China as of 2026:
Steel and aluminum products:
Solar and clean energy:
Wood and furniture:
Other categories:
This is not an exhaustive list — hundreds of orders exist. The point is that for commoditized manufactured goods where there are US domestic producers, an ADD/CVD order is quite likely to exist.
There are two reasons ADD/CVD exposure catches importers:
First, ADD/CVD is product-specific, not program-wide. You can't check "is there ADD/CVD on Chinese goods" because the answer depends on the exact product. You have to check your specific product against the order database. A buyer importing steel wire and a buyer importing packaging materials will have completely different ADD/CVD exposure, and there's no shortcut.
Second, the rates are assessed at the producer level. ADD/CVD rates are set for specific Chinese exporters based on Commerce's investigation of their actual pricing. If your supplier has a low rate based on past cooperation with Commerce reviews, that rate may be significantly lower than the China-wide rate. If your supplier is new, unknown to Commerce, or has refused to cooperate with reviews, they may be assessed at the China-wide rate — which is typically the highest rate applied to any producer under the order.
This means switching suppliers within China doesn't necessarily mean your ADD/CVD exposure changes favorably. If you switch to a producer who hasn't been reviewed, they may be assessed at the China-wide rate until they go through an annual review.
Option 1: CBP's AD/CVD Search Tool CBP maintains an AD/CVD case reference search at cbp.gov. You can search by HTS code, country of origin, and case number. This will tell you whether an order exists for your product category.
Option 2: ITC's AD/CVD Duty Order Database The USITC maintains a searchable database of active duty orders. More detailed than CBP's tool, and useful for finding the full list of orders in a product category.
Option 3: lgistics.ai Lgistics.ai cross-references HTS codes against active duty orders and provides a combined rate view including ADD/CVD exposure. Faster than manual lookups through government databases.
Option 4: Customs broker review For any significant import program, a customs broker should review your HTS code against active orders. A good broker catches ADD/CVD exposure in their classification review; this is part of the value of using a licensed broker rather than self-filing.
The key lookup is by HTS code AND country of origin. ADD/CVD orders are country-specific — an order against China doesn't apply to the same product from Vietnam or Mexico, which is part of why country-of-origin strategies can be effective for ADD/CVD exposure (though subject to circumvention rules).
When you import goods subject to an ADD/CVD order, you pay a cash deposit at the applicable rate at time of import. This deposit rate is set based on the last published rate for your specific exporter or the China-wide rate if no exporter-specific rate exists.
The deposit rate is not the final rate. Commerce conducts annual administrative reviews where they recalculate the actual dumping margin for the prior period. After the review, they publish:
If the final rate is higher than the deposit you paid, you owe the difference. If lower, you get a refund (eventually — these processes take 12-18 months). The catch: if you're importing $500,000/year in goods at a deposit rate of 30%, and the annual review finds the actual rate should have been 60%, you owe $150,000 in additional duties retroactively.
This prospective liability is why large importers work with customs counsel to understand their exposure in categories with active ADD/CVD orders. It's also why getting your exporter's specific rate matters — the China-wide rate is often designed to be punitive to discourage importing from unreviewed producers.
These programs are additive. A product subject to all programs pays all of them:
Example: Chinese aluminum extrusion, HTS 7604.10:
At even conservative ADD/CVD rates, this product is effectively non-importable from China for most business cases. This is why aluminum extrusion is largely reshored or sourced from Mexico, India, or Southeast Asia in US supply chains.
For your import planning, ADD/CVD exposure isn't just a cost factor — at high enough rates, it's a binary: import from China is viable or it isn't. Know before you commit to a supplier.
Verify the deposit rate for your specific exporter. Not all Chinese producers are at the China-wide rate. If your supplier has cooperated with administrative reviews and has a lower producer-specific rate, that changes the calculus significantly.
Engage a customs attorney. For any product with meaningful ADD/CVD exposure, the $500-1,000 investment in a consultation is worth it. An attorney can review the applicable order, advise on deposit rates, explain the annual review cycle, and help you assess whether circumvention risk exists for any sourcing alternatives you're considering.
Consider third-country sourcing. ADD/CVD orders are China-specific. The same product made in Vietnam, Mexico, Thailand, or India doesn't carry the same orders (though those countries may have their own, separate orders in some categories). Country-of-origin shifting is a legitimate strategy — subject to CBP's substantial transformation rules and active circumvention investigations in some product categories.
Don't transship. CBP actively investigates transshipment of Chinese goods through third countries to evade ADD/CVD. If goods are Chinese-origin and the transformation in a third country is minimal, CBP will assess the original Chinese rates. The penalties are severe — the duties owed plus substantial civil penalties.
See our China tariffs overview for how ADD/CVD fits with the other tariff programs. For legal strategies to reduce your total duty burden, see our tariff engineering article.
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