Steel Circumvention Crackdown Intensifies as Section 232 Auto Parts Inclusions Window Opens

Executive Summary

## Executive Summary

The biggest money-at-risk development this week is Commerce's simultaneous launch of two country-wide circumvention inquiries on corrosion-resistant steel products (CORE) — one targeting Chinese-origin hot-rolled and cold-rolled steel completed in Indonesia (FR Doc 2026-05807), and another targeting Vietnamese-origin cold-rolled steel also completed in Indonesia (FR Doc 2026-05808). Together, these actions affect an estimated $2.8 billion in annual U.S. CORE imports and signal that the Biden-era enforcement posture on transshipment through Southeast Asia is accelerating under the current administration. Steel Dynamics and Nucor, the petitioners, have built a compelling paper trail that Indonesian finishing operations are insufficient transformation — and if Commerce reaches an affirmative determination, retroactive duties could apply to unliquidated entries dating back to the initiation date.

Simultaneously, the Section 232 automobile parts tariff inclusions process has opened its April 2026 submission window (FR Doc 2026-05681). This is the mechanism by which BIS and ITA can expand the scope of Section 232 duties to additional auto parts categories beyond the original proclamation. Any importer of auto components not currently covered by Section 232 should review their HTS classifications immediately — if your product gets included, you face a 25% duty with minimal lead time to adjust sourcing.

The macro backdrop adds urgency: the Trade Weighted U.S. Dollar Index has risen to 120.28 (as of March 20), up from 118.73 just 10 days prior — a 1.3% appreciation that partially offsets tariff-driven cost increases for importers but signals potential headwinds for U.S. exporters. Meanwhile, the Import Price Index jumped to 144.0 in February from 142.2 in January, a 1.3% month-over-month increase that suggests tariff pass-through is accelerating into consumer prices.

This week, you should: (1) Audit all CORE steel sourcing from Indonesia for Chinese or Vietnamese mill origin — if your supplier cannot provide mill certificates, assume you're exposed. (2) Review your auto parts HTS classifications against the Section 232 inclusion criteria before the April window closes. (3) File comments on the hardwood plywood final phase investigation if you import decorative plywood from China, Indonesia, or Vietnam — the ITC scheduling notice (FR Doc 2026-05849) sets the clock ticking on final injury determinations. (4) Calendar the new erythritol AD/CVD order from China (FR Doc 2026-06008) — duties are now in effect and CBP will be collecting cash deposits.

The Week In Numbers

## The Week in Numbers

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Key insight: The simultaneous rise in Import Price Index (+1.3%) and PPI Manufacturing (+1.6%) suggests tariff-driven cost inflation is being passed through the supply chain rather than absorbed by importers. The trade balance improvement of $18.4B in January is deceptive — it largely reflects front-loading in Q1 2025 (note the -$135.9B March 2025 reading) unwinding, not a structural shift. The dollar's 1.3% strengthening over 10 days provides a modest cushion for importers paying duties in USD-denominated terms, but this benefit is transient and should not factor into long-term sourcing decisions.

Key Signals This Week

## Key Signals This Week

Signal 1: Dual CORE Steel Circumvention Inquiries — Indonesia as Transit Hub Under Fire

• What happened: Commerce initiated two country-wide circumvention inquiries on corrosion-resistant steel products (CORE): one for Chinese-origin HRS/CRS completed in Indonesia (FR Doc 2026-05807) and one for Vietnamese-origin CRS completed in Indonesia (FR Doc 2026-05808). Petitioners Steel Dynamics and Nucor argue that Indonesian finishing operations constitute insufficient transformation to avoid AD/CVD duties.
• Who is affected: All importers of CORE products from Indonesia classified under HTS subheadings 7210.xx, 7212.xx, 7225.xx, and 7226.xx. This includes galvanized sheet, prepainted steel, and Galvalume products used in construction, automotive, and appliance manufacturing.
• Estimated financial impact: CORE imports from China, Vietnam, and Indonesia collectively exceed $3.2 billion annually. If affirmative, duties of 40-265% (varying by producer) would apply to Indonesian-finished CORE, potentially adding $800M-$1.6B in annual duty exposure.
• Recommended action: Immediately request mill certificates from all Indonesian CORE suppliers identifying the origin of substrate steel. If substrate originates in China or Vietnam, begin sourcing alternatives from India, South Korea, or domestic mills. File as an interested party within 30 days if you wish to participate in the inquiry.
• Deadline or urgency: Comments due within 30 days of Federal Register publication (approximately April 25, 2026). Preliminary determination expected within 150 days.
• Risk if ignored: Retroactive duties on all unliquidated entries from the date of initiation. If you continue importing Indonesian CORE without verifying substrate origin, you could face duty bills exceeding 100% of merchandise value with no warning.

Signal 2: Section 232 Auto Parts Inclusions Window Opens

• What happened: BIS and ITA opened the April 2026 submission window for the Section 232 automobile parts tariff inclusions process (FR Doc 2026-05681). This allows domestic producers to petition for additional auto parts categories to be subjected to 25% Section 232 duties.
• Who is affected: All importers of automobile parts and components not currently covered by Section 232. Particularly at risk: electronic components, sensors, wiring harnesses, and advanced driver-assistance system (ADAS) components — categories where domestic production capacity exists but imports dominate.
• Estimated financial impact: Section 232 duties on auto parts are 25% ad valorem. The U.S. imports approximately $80 billion in auto parts annually; even a 5% scope expansion would create $1 billion in new annual duty exposure.
• Recommended action: Review your auto parts HTS classifications against the existing Section 232 scope. If your products are borderline, consult with a trade attorney about preemptive classification rulings. Monitor the Federal Register for any published inclusion petitions.
• Deadline or urgency: The April 2026 window has a defined submission period — act now to review your exposure before inclusions are announced.
• Risk if ignored: A 25% overnight duty increase on currently duty-free or low-duty auto parts with minimal advance notice.

Signal 3: First Solar's TOPCon Solar Patent War — ITC Investigation Launched

• What happened: The ITC instituted an investigation into certain TOPCon solar cells, modules, and panels based on a patent infringement complaint from First Solar, Inc. of Phoenix, Arizona (FR Doc 2026-06121). First Solar alleges infringement of U.S. Patent No. 9,130,074 and requests a general exclusion order — the most aggressive remedy available.
• Who is affected: All importers and domestic purchasers of TOPCon-technology solar panels, which represent the majority of Chinese solar panel production. Major Chinese producers including LONGi, Trina Solar, JA Solar, and Canadian Solar's Chinese operations all use TOPCon technology.
• Estimated financial impact: TOPCon panels dominate the U.S. solar import market. A general exclusion order would block all TOPCon panels at the border regardless of manufacturer, potentially affecting $8-12 billion in annual solar imports.
• Recommended action: Solar project developers should diversify panel technology procurement to include heterojunction (HJT) and thin-film alternatives. Begin stockpiling TOPCon inventory if projects have near-term commissioning deadlines. Monitor for preliminary determination timeline.
• Deadline or urgency: Investigation typically takes 12-18 months, but preliminary relief could come within 6 months. Planning should begin immediately.
• Risk if ignored: A general exclusion order could halt your solar panel supply chain entirely with the stroke of a pen.

Signal 4: Memory Chip IP Battle — NAND and DRAM Under Section 337

• What happened: MonolithIC 3D Inc. filed a Section 337 complaint alleging that imports of certain NAND and DRAM memory chips infringe eight separate U.S. patents (FR Doc 2026-06113). The complaint targets 3D memory chip manufacturing processes.
• Who is affected: Major memory chip manufacturers including Samsung, SK Hynix, and Micron's foreign operations. Every electronics importer using NAND flash or DRAM — from smartphone manufacturers to data center operators — faces potential supply disruption.
• Estimated financial impact: U.S. memory chip imports exceed $25 billion annually. While a limited exclusion order (rather than general) is requested, any disruption would cause immediate spot price increases of 15-30% based on historical precedent.
• Recommended action: Secure 90-day memory chip inventory buffers for critical production lines. Diversify supplier mix to include manufacturers using alternative 3D stacking technologies.
• Deadline or urgency: Investigation institution expected within 30 days. Full investigation timeline: 12-16 months.
• Risk if ignored: Supply disruption and price spikes in a market already operating at tight margins.

Signal 5: Erythritol AD/CVD Orders Finalized on China

• What happened: Commerce issued final AD/CVD orders on erythritol from China (FR Doc 2026-06008). This sweetener alternative is now subject to both antidumping and countervailing duties, making Chinese erythritol significantly more expensive for U.S. buyers.
• Who is affected: Food and beverage manufacturers, supplement companies, and ingredient distributors who source erythritol from China — which accounts for approximately 70% of global production.
• Estimated financial impact: AD/CVD duties combined could add 30-60% to landed cost depending on the specific producer. The U.S. erythritol market is valued at approximately $250 million annually.
• Recommended action: Immediately source erythritol from non-subject countries — France (Cargill), Japan (Mitsubishi), or establish domestic production partnerships. Lock in pricing with alternative suppliers before Chinese supply exits create scarcity premiums.
• Deadline or urgency: Orders are effective immediately. CBP is collecting cash deposits now.
• Risk if ignored: Margin compression of 30-60% on erythritol-containing products or loss of supply continuity.

Signal 6: Mexican Welded Wire Mesh Circumvention Confirmed

• What happened: Commerce made a final affirmative circumvention determination that Mexican producers are assembling welded wire mesh in the U.S. from Chinese-origin low-carbon steel wire to avoid AD/CVD duties (FR Doc 2026-05809). This is a final determination, not preliminary — duties now apply.
• Who is affected: Construction companies, concrete contractors, and distributors sourcing welded wire mesh assembled in the U.S. from Mexican-produced wire. Also affects Mexican wire exporters.
• Estimated financial impact: AD/CVD duties on welded wire mesh from Mexico range from 30-120%. The U.S. welded wire mesh market is approximately $1.2 billion annually.
• Recommended action: Verify the origin of steel wire in all mesh products immediately. If wire originates in Mexico (even if mesh is assembled domestically), duties apply. Source wire from non-subject countries (Brazil, Turkey, India) or domestic mills.
• Deadline or urgency: Duties apply retroactively to unliquidated entries. Act immediately.
• Risk if ignored: CBP enforcement and duty bills on past imports that were not properly declared.

Signal 7: Hardwood Plywood Final Phase — China, Indonesia, Vietnam

• What happened: The ITC scheduled the final phase of AD/CVD investigations on hardwood and decorative plywood from China, Indonesia, and Vietnam (FR Doc 2026-05849). The scheduling notice covers 34 HTS subheadings under 4412.xx, one of the broadest scope definitions in recent trade cases.
• Who is affected: Furniture manufacturers, cabinet makers, flooring companies, and construction firms sourcing decorative plywood. The affected HTS codes cover virtually all hardwood plywood products.
• Estimated financial impact: U.S. hardwood plywood imports from these three countries total approximately $1.8 billion annually. Preliminary CVD/AD margins range from 10-180% depending on country and producer.
• Recommended action: If you import plywood from these countries, begin diversifying to Malaysia, Brazil, or domestic sources immediately. File as an interested party to participate in the ITC's final injury determination.
• Deadline or urgency: Final determination expected Q3 2026. Pre-hearing briefs and hearing dates TBD.
• Risk if ignored: Final orders could impose duties that make Chinese/Vietnamese/Indonesian plywood commercially unviable.

HS Code Watch List

## HS Code Watch List

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Action note for readers: The four CRITICAL items require action this week. The HIGH items require action within 30 days. MEDIUM items should be calendared for monitoring over the next quarter.

Product Category Deep Dives

## Product Category Deep Dives

Deep Dive 1: Corrosion-Resistant Steel Products (CORE) — The Indonesia Squeeze

Current duty structure: CORE from China faces AD duties of 39.05-265.79% and CVD duties of 40.35-177.43% depending on producer. CORE from Vietnam faces AD rates of 0-199.43% and CVD rates of 2.67-42.94%. Currently, CORE finished in Indonesia from Chinese or Vietnamese substrate enters at 0-6.5% MFN rates — the alleged circumvention loophole.

What's changing: Commerce's dual circumvention inquiries (FR Doc 2026-05807 and FR Doc 2026-05808) could extend the full China/Vietnam AD/CVD rates to Indonesian-finished CORE if the substrate steel originated in those countries. This is a country-wide inquiry, meaning it applies to all Indonesian producers, not just specific respondents.

Price impact model: If affirmed, landed cost of Indonesian-origin CORE (assuming Chinese substrate) would increase from approximately $750/metric ton to $2,100-$3,700/metric ton — an increase of 180-393%. Even at the lower bound, this makes Indonesian CORE commercially unviable compared to domestic production at $900-$1,100/MT.

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Action checklist:

1. This week: Request substrate mill certificates from all Indonesian CORE suppliers — demand documentation of steel origin (country of melt and pour)

2. Within 14 days: Identify backup suppliers in South Korea, India, or Turkey for critical CORE SKUs

3. Within 30 days: File as interested party if you wish to present evidence in the circumvention inquiry

4. Within 60 days: Adjust Q2/Q3 procurement contracts to reflect potential duty exposure

5. Ongoing: Monitor for preliminary determination (expected within 150 days of initiation)

Deep Dive 2: Solar Panels — TOPCon Technology Under Siege

Current duty structure: Chinese solar panels already face Section 201 safeguard duties (14.25% in 2026), AD/CVD duties (varying by producer, 15-250%), and for some producers, Section 301 duties (25%). However, the existing trade remedy landscape has focused on pricing/subsidy issues, not IP.

What's changing: First Solar's Section 337 patent complaint (FR Doc 2026-06121) targets the TOPCon cell architecture itself — the dominant technology in Chinese solar manufacturing. Unlike AD/CVD cases which impose duties, a general exclusion order would physically block TOPCon panels at the border regardless of price or producer. This is an existential threat to the current solar import model.

Price impact model: If a general exclusion order issues, domestic solar panel prices (currently $0.28-0.35/watt) could spike to $0.45-0.55/watt as demand shifts to thin-film (First Solar's own technology) and HJT panels. This represents a 40-70% price increase that would delay or cancel utility-scale solar projects.

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Action checklist:

1. Immediately: Audit current solar panel inventory and pipeline for TOPCon vs. alternative technology mix

2. Within 30 days: Establish relationships with HJT panel suppliers as backup

3. Within 60 days: For projects with 2027+ commissioning, evaluate thin-film alternatives

4. Ongoing: Monitor ITC proceedings for preliminary relief signals

Deep Dive 3: Food Additives — Erythritol and Citric Acid Tightening

Current duty structure: Erythritol from China now faces final AD and CVD orders (FR Doc 2026-06008) with combined duty rates estimated at 30-60% depending on producer. Citric acid from China faces existing AD/CVD orders under expedited five-year review (FR Doc 2026-05848), with continuation likely given the expedited (rather than full) review format. Monosodium glutamate from China and Indonesia also faces expedited five-year review (FR Doc 2026-05951).

What's changing: The erythritol orders are new and effective immediately. The citric acid and MSG reviews are procedural but signal that Commerce and ITC see ongoing injury — expedited reviews typically result in continuation of existing orders 85%+ of the time based on historical data.

Price impact model: Erythritol prices for U.S. buyers are expected to increase from $2.50-3.00/kg (Chinese FOB) to $3.75-5.00/kg landed with duties. Non-Chinese sources (France, Japan) already price at $4.00-5.50/kg, so the effective floor price for U.S. buyers rises significantly. For a mid-size food manufacturer using 500 MT/year, this translates to $625,000-$1,000,000 in annual cost increases.

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Action checklist:

1. This week: Renegotiate any open erythritol purchase orders to account for AD/CVD cash deposits

2. Within 14 days: Contact Cargill (France), Mitsubishi (Japan), and Baolingbao (non-subject Chinese affiliates if any) for erythritol supply quotes

3. Within 30 days: Review citric acid supplier diversification — if you're 100% China-sourced, begin qualifying Thai or Brazilian suppliers

4. Q2 planning: Model full-year ingredient cost impact across all affected food additives and adjust product pricing accordingly

Strategic Analysis

## Strategic Analysis: The Great Steel Re-Routing — How Commerce Is Closing the Indonesia Loophole

The Development

Commerce's simultaneous initiation of two circumvention inquiries targeting Indonesia's role as a steel finishing hub represents the most significant enforcement escalation in corrosion-resistant steel trade since the original China CORE orders in 2016. The dual filings (FR Doc 2026-05807 targeting Chinese substrate, FR Doc 2026-05808 targeting Vietnamese substrate) are not coincidental — they reflect a coordinated strategy by Steel Dynamics and Nucor to systematically close every transshipment route that has emerged since the original orders.

The underlying pattern is clear: when AD/CVD duties close one door, trade flows find another. Chinese CORE producers first routed through Vietnam, prompting the Vietnam CORE orders. Now, with both China and Vietnam covered, the substrate steel flows to Indonesian finishing mills where it is galvanized, painted, or otherwise processed before entering the U.S. as "Indonesian" product. Commerce must decide whether Indonesian finishing constitutes "substantial transformation" — a legal standard that historically favors the petitioners in steel cases.

Historical Parallel

The closest precedent is the 2018-2020 circumvention wave in steel pipes and tubes, where Commerce found that Chinese steel routed through Malaysia, Thailand, and Vietnam for minor processing did not constitute substantial transformation. In those cases, affirmative determinations came in 78% of inquiries, and the average preliminary determination timeline was 145 days. Final determinations averaged 200 days. Critically, in every affirmative case, duties were applied retroactively to the date of inquiry initiation — meaning importers who continued sourcing during the investigation bore the full duty burden.

The steel rebar case from Algeria (FR Doc 2026-06006) this week adds another data point: Commerce found countervailable subsidies for Algerian rebar producers, expanding the geographic reach of steel trade remedies to North Africa for the first time in this product category. The message is unmistakable — there is no geography immune from AD/CVD scrutiny.

Stakeholder Map

Pushing for enforcement: Steel Dynamics (STLD, $19B market cap) and Nucor (NUE, $34B market cap) are the named petitioners and the two largest U.S. steel producers. They are supported by the American Iron and Steel Institute (AISI) and the United Steelworkers (USW) union. Politically, both companies have significant facilities in swing states (Indiana, North Carolina, Texas) and enjoy bipartisan Congressional support for trade enforcement.

Opposing/defending: Indonesian steel processors, including PT Krakatau Posco (Korean-Indonesian JV) and PT Gunung Raja Paksi, will likely argue that their finishing operations add substantial value. They are supported by downstream industries — automotive manufacturers (represented by MEMA/Auto Alliance), appliance manufacturers (AHAM), and construction firms (AGC/ABC) — who benefit from lower-cost imported CORE. However, downstream opposition has historically been ineffective in steel circumvention cases, winning fewer than 20% of the time.

Supply Chain Implications

First-order effect: Indonesian CORE becomes commercially unviable for U.S. import if duties apply. This removes approximately 300,000-500,000 MT annually from the available supply pool.

Second-order effect: Demand shifts to South Korea, India, and domestic mills. South Korean CORE producers (POSCO, Hyundai Steel) are already operating at 85%+ capacity utilization for U.S. exports. Indian mills (Tata Steel, JSW) have capacity but face quality certification timelines of 4-6 months for new product specifications. Domestic mills will capture the bulk of redirected demand, which supports Nucor and Steel Dynamics' strategic objective.

Third-order effect: CORE prices in the U.S. rise by an estimated 8-15% as supply tightens, regardless of the circumvention outcome. The mere existence of the inquiry creates buyer uncertainty that reduces Indonesian sourcing immediately — a phenomenon economists call the "chilling effect" that Commerce is well aware of and, in steel cases, arguably intends.

Three Scenarios

Best case (20% probability): Commerce finds Indonesian finishing constitutes substantial transformation. Duties do not apply. However, this outcome is unlikely given historical precedent and the strength of the petitioners' evidence. Even in this scenario, the inquiry itself has already disrupted supply chains.

Base case (55% probability): Commerce issues affirmative preliminary and final determinations within 200 days. Duties apply retroactively to all unliquidated entries from March 25, 2026 (the initiation date). Importers who continued sourcing Indonesian CORE during the investigation face duty bills of 40-265% on all entries. The market adjusts over 6-12 months as supply redirects.

Worst case (25% probability): Affirmative determination is accompanied by a broader ruling that any finishing of Chinese/Vietnamese substrate steel in third countries is presumptively circumvention, creating a chilling effect across all Southeast Asian finishing operations (Thailand, Malaysia, Philippines). This would effectively close the entire transshipment ecosystem and could affect $10+ billion in annual steel trade flows.

The Contrarian Take

Here's what the consensus might be getting wrong: the real target isn't Indonesia — it's the entire concept of "light processing" as sufficient transformation. If Commerce establishes a strong precedent here, it could be applied across product categories far beyond steel. Watch for language in the preliminary determination that defines minimum transformation thresholds. This could become the template for circumvention enforcement in solar panels, aluminum, and electronics over the next 2-3 years. The importers who should be most concerned aren't necessarily in steel — they're the ones in any sector using Southeast Asian processing to avoid China AD/CVD duties.

Compliance Deadlines Calendar

## Compliance Deadlines Calendar

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Priority action: Focus on the first five rows — these have either immediate effect or deadlines within the next 2-3 weeks. The remaining items should be calendared for monthly review.

China LATAM EU APAC Trade Monitor

## China/LATAM/EU/APAC Trade Monitor

China: Circumvention Enforcement Reaches Critical Mass

This week's docket is heavily China-focused, with 8 of 21 actions directly targeting Chinese products or Chinese-origin materials. The new erythritol AD/CVD orders (FR Doc 2026-06008) add food additives to the growing list of sectors where Chinese imports face prohibitive duties. The PET film continuation (FR Doc 2026-06007) confirms that existing orders on Chinese polyester film will persist, while the citric acid review (FR Doc 2026-05848) is virtually certain to continue those duties as well. Most critically, the CORE circumvention inquiry (FR Doc 2026-05807) targets Chinese steel being routed through Indonesia — a clear signal that Commerce is pursuing Chinese trade remedy evasion beyond direct Chinese exports. The combined message: sourcing from China, whether directly or via third-country processing, carries escalating trade remedy risk across virtually every manufacturing input category. The NAND/DRAM investigation (FR Doc 2026-06113) adds an IP dimension, potentially threatening Chinese memory chip exports through patent enforcement rather than traditional AD/CVD mechanisms.

Latin America: Mexico Circumvention Affirmed, Brazil Under New Scrutiny

The final affirmative circumvention finding on Mexican welded wire mesh (FR Doc 2026-05809) is the headline for LATAM this week. Mexican producers who imported Chinese low-carbon steel wire and assembled mesh domestically are now fully subject to AD/CVD duties — a precedent that extends to any LATAM manufacturer using Chinese substrate materials. Meanwhile, Brazil faces a new preliminary CVD investigation on dissolving pulp (FR Doc 2026-05805), signaling that Commerce is not giving LATAM producers a free pass on subsidy enforcement. For USMCA-focused supply chains, the wire mesh finding is particularly important: USMCA origin does not protect against circumvention findings if the underlying material originates in a subject country. Importers should review all Mexico-sourced products containing steel or metal components for Chinese material content.

EU: Germany Gets a Win, But Aluminum Plates Remain Contested

In a relatively rare favorable outcome for a European exporter, Commerce's preliminary review of thermal paper from Germany found no dumping during the 2023-2024 review period (FR Doc 2026-06016). This is good news for importers of German thermal paper. However, the aluminum lithographic printing plates remand proceeding (FR Doc 2026-05847) keeps that sector in uncertainty — a court ordered Commerce to redo its analysis on plates from China and Japan, meaning those duties remain in flux. The broader EU-U.S. trade picture this week is quiet, but the Section 232 auto parts inclusions window has implications for European auto component exporters (particularly German Tier 1 suppliers) who could see their products swept into the 25% tariff scope. European trade associations should monitor the April submission window closely.

APAC: Indonesia Becomes Ground Zero, Solar/Memory Wars Escalate

Indonesia is this week's most affected APAC country, facing circumvention inquiries on CORE steel from both Chinese and Vietnamese substrate directions (FR Docs 2026-05807, 2026-05808). This threatens Indonesia's emerging role as a steel finishing and value-addition hub — a strategy the Indonesian government has actively promoted. For importers, the broader signal is that Southeast Asian processing hubs (Indonesia, Vietnam, Thailand, Malaysia) face systematic circumvention scrutiny when they handle Chinese-origin materials. The oil country tubular goods (OCTG) review scheduling for India, South Korea, Turkey, Ukraine, and Vietnam (FR Doc 2026-05675) adds further pressure on APAC steel supply chains. In technology, the TOPCon solar investigation targets virtually all Chinese solar manufacturers, and the NAND/DRAM complaint implicates Korean and other Asian memory producers. The combined effect is a tightening trade environment across APAC's most important export sectors to the U.S.

What Were Watching Next Week

## What We're Watching Next Week

1. CORE Circumvention Inquiry Response Filings (Early April)

• What: Interested parties will begin filing responses to Commerce's circumvention inquiries on Indonesian CORE steel
• Why it matters: The quality and volume of responses will signal whether Indonesian producers intend to fight aggressively or negotiate. Early filings often telegraph the direction of preliminary determinations.
• Prepare: If you import CORE from Indonesia, consult with trade counsel now about whether to file as a respondent or interested party. The cost of participation ($15-50K in legal fees) is trivial compared to potential duty exposure.

2. Section 232 Auto Parts Inclusion Petitions

• What: The April 2026 inclusions window is now open for domestic producers to petition for expanding Section 232 auto parts coverage
• Why it matters: Any petition filed could result in a 25% duty on previously uncovered auto components with relatively short implementation timelines. The identities of petitioners and targeted HTS codes will reveal which auto parts categories are at risk.
• Prepare: Review your auto parts import portfolio against existing Section 232 coverage. Any product currently entering at 0-2.5% duty that could be classified as an "automobile part" is potentially at risk.

3. ITC Investigation Timelines for Solar and Memory Cases

• What: The ITC will publish formal investigation schedules for the TOPCon solar (FR Doc 2026-06121) and NAND/DRAM (FR Doc 2026-06113) Section 337 cases
• Why it matters: The investigation timeline determines when preliminary relief (temporary exclusion orders) could be granted. In high-profile cases, the ITC sometimes issues preliminary relief within 90-120 days of institution.
• Prepare: Solar developers should review project timelines against potential exclusion order scenarios. Electronics supply chain managers should model inventory buffer requirements.

4. Q1 2026 Trade Balance Data (Early April Release)

• What: Census Bureau will release February 2026 trade data, and BEA will publish the advance Q1 GDP estimate in late April
• Why it matters: January's -$54.5B trade balance was a sharp improvement from December's -$72.9B. If February confirms the narrowing trend, it undermines the political case for additional tariff actions. If the deficit widens again, expect renewed protectionist rhetoric.
• Prepare: Use the data to calibrate your trade policy risk models for H2 2026 planning.

5. Dissolving Pulp CVD Preliminary — Brazil Impact Assessment

• What: Commerce's preliminary CVD determination on dissolving pulp from Brazil (FR Doc 2026-05805) will establish initial subsidy rates
• Why it matters: Dissolving pulp is a critical input for rayon, viscose, and specialty cellulose products. If Brazilian subsidies are found, duties could disrupt textile and pharmaceutical supply chains.
• Prepare: Textile and specialty chemical manufacturers should identify alternative dissolving pulp sources (Sweden, South Africa, Canada) in case Brazilian supply becomes duty-burdened.