CORE Steel Circumvention Inquiry, New Erythritol Orders, and Six China Sunset Reviews Mark Week of Accelerating Trade Enforcement

Executive Summary

The biggest money-at-risk story this week is Commerce's initiation of a circumvention inquiry on corrosion-resistant steel products (CORE) from Korea completed in Thailand (FR Doc 2026-06449). If Commerce finds circumvention, importers sourcing CORE steel through Thailand will face retroactive duties — potentially impacting an estimated $2.1 billion in annual steel imports flowing through Southeast Asian finishing operations. This is not a hypothetical: Nucor and Steel Dynamics filed the petition, and Commerce has a strong track record of affirmative circumvention findings when major domestic producers initiate the inquiry.

Simultaneously, the EPA's final rule on Renewable Fuel Standards for 2026-2027 (FR Doc 2026-06275) reshapes the biofuels landscape by eliminating renewable electricity as a qualifying renewable fuel (eRINs), effective June 15, 2026. While not a tariff action per se, this rule fundamentally alters the economics of renewable fuel imports and the associated Renewable Identification Number (RIN) market, with direct cost implications for importers of ethanol blends, biodiesel, and biomass-based diesel from Brazil, Argentina, and Southeast Asia.

On the trade remedy front, Commerce issued new AD/CVD orders on erythritol from China (FR Doc 2026-06008) and a final affirmative CVD determination on steel rebar from Algeria (FR Doc 2026-06265), while the ITC launched six separate five-year sunset reviews on Chinese products ranging from non-refillable steel cylinders to mattresses. The sheer volume of China-targeted actions this week — combined with a new Section 337 investigation on TOPCon solar cells filed by First Solar (FR Doc 2026-06121) — signals an acceleration in the multi-front trade enforcement campaign against Chinese manufacturing.

This week, you should: (1) Audit your corrosion-resistant steel supply chain for any Thailand-routed Korean steel — request certificates of origin and mill test certificates immediately; (2) Review your RFS compliance obligations if you import or blend renewable fuels ahead of the June 15 effective date; (3) File entry of appearance for any of the six China sunset reviews where you have commercial interests (deadline: 15 days from Federal Register publication); (4) Check whether your fresh tomato imports require updated certification under the extended April 15 deadline (FR Doc 2026-06420).

The Week In Numbers

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Key takeaway: The Import Price Index rose 1.3% month-over-month to 144.0 — the steepest single-month increase since March 2025, suggesting tariff pass-through effects are accelerating. Combined with PPI Manufacturing jumping 1.6%, importers face a double squeeze: higher input costs from abroad and rising domestic production costs. The strengthening dollar (up 0.9% in two weeks to 120.89) provides a partial offset for importers but hurts exporters and could further widen the trade deficit in Q2. The trade balance improvement in January (-$54.5B vs. -$72.9B in December) is likely a seasonal adjustment artifact — the underlying trend over the past 12 months shows persistent deficits averaging -$65B monthly.

Key Signals This Week

Signal 1: Circumvention Inquiry — Corrosion-Resistant Steel (Korea via Thailand)

• What happened: Commerce initiated a country-wide circumvention inquiry to determine whether CORE steel from Korea, completed in Thailand, is circumventing the existing AD/CVD orders on CORE from Korea (FR Doc 2026-06449). The petition was filed by Nucor Corporation and Steel Dynamics, Inc. — the two largest U.S. steel producers by market share.
• Who is affected: Importers of corrosion-resistant steel products (HS 7210.30, 7210.41, 7210.49, 7210.61, 7210.69, 7210.70, 7210.90, 7212.20, 7212.30, 7212.40, 7212.50, 7212.60, 7225.91, 7225.92, 7225.99, 7226.99) sourced from Thailand where the substrate originates in Korea.
• Estimated financial impact: U.S. CORE imports from Thailand totaled approximately $780 million in 2025. If circumvention is found, retroactive duties of 15-25% (matching the Korean order rates) could apply, adding $120-195M in annual duty exposure.
• Recommended action: Immediately audit your supply chain for any CORE steel routed through Thailand. Request mill test certificates and certificates of origin from all Thai CORE suppliers. If your supplier uses Korean substrate, begin sourcing qualification from domestic mills or alternative suppliers in India/Vietnam now — don't wait for the preliminary finding.
• Deadline or urgency: Comments due within 30 days of publication (approximately May 2, 2026). Preliminary determination expected within 150 days.
• Risk if ignored: Retroactive duty liability from the date of initiation. If you continue importing without documentation, CBP may demand additional cash deposits at the border.

Signal 2: EPA Eliminates eRINs in Final RFS Rule

• What happened: The EPA finalized the Renewable Fuel Standard (RFS) program standards for 2026 and 2027 (FR Doc 2026-06275), a significant final rule that removes renewable electricity (eRINs) as a qualifying renewable fuel and revises biogas provisions. The rule also partially waives the 2025 cellulosic biofuel volume requirement due to production shortfalls.
• Who is affected: Renewable fuel importers, ethanol blenders, biodiesel producers, and any company holding or trading Renewable Identification Numbers (RINs). Also affects electric vehicle charging networks that were positioning to generate eRINs.
• Estimated financial impact: The eRIN elimination removes an estimated $3-5 billion in potential RIN value that the EV and renewable electricity sector expected to capture. For traditional biofuel importers (particularly Brazilian ethanol and Argentine biodiesel), the revised volume mandates for 2026-2027 will set new floor prices for D4 and D6 RINs.
• Recommended action: Review your RFS compliance strategy before the June 15, 2026 effective date. If your RIN generation relied on eRIN pathways, immediately switch to traditional fuel pathways. Biofuel importers should lock in supply contracts now to meet the 2026 volume mandates before spot prices adjust.
• Deadline or urgency: Effective June 15, 2026 (primary rule), with amendatory instruction 47 effective April 28, 2026 and instruction 17 effective January 1, 2027.
• Risk if ignored: Non-compliance with revised RFS obligations triggers penalties of up to $50,000/day per violation under the Clean Air Act.

Signal 3: New AD/CVD Orders on Erythritol from China

• What happened: Commerce issued final antidumping and countervailing duty orders on erythritol from China (FR Doc 2026-06008), following affirmative injury determinations by both Commerce and the ITC.
• Who is affected: Food and beverage manufacturers, supplement companies, and ingredient distributors importing erythritol (HS 2905.49, 3824.99) from China. China dominates global erythritol production with approximately 85% market share.
• Estimated financial impact: Combined AD/CVD duties are expected to range 35-65% depending on the exporter, effectively doubling the landed cost of Chinese erythritol. U.S. erythritol imports from China were approximately $180 million in 2025.
• Recommended action: Diversify sourcing immediately — qualified alternative producers exist in Japan (Mitsubishi Chemical), France (Cargill), and South Korea. File for exclusion if you believe your specific product falls outside the scope. Renegotiate contracts with Chinese suppliers to account for duty absorption or pass-through.
• Deadline or urgency: Orders are effective immediately upon Federal Register publication. Cash deposits required on all entries from the publication date.
• Risk if ignored: Full duty assessment on all entries without cash deposits will result in CBP liquidation at the full combined rate plus interest.

Signal 4: Six Simultaneous Five-Year Sunset Reviews on Chinese Products

• What happened: The ITC initiated six five-year reviews on Chinese products in a single week: non-refillable steel cylinders (FR Doc 2026-06293), chassis and subassemblies (FR Doc 2026-06292), mattresses (FR Doc 2026-06290, also covering Cambodia, Malaysia, Serbia, Thailand, Turkey, Vietnam), small vertical shaft engines (FR Doc 2026-06289), prestressed concrete steel wire strand (FR Doc 2026-06288), and boltless steel shelving units (FR Doc 2026-06287).
• Who is affected: Importers of consumer products, industrial hardware, construction materials, and automotive components from China and the listed third countries.
• Estimated financial impact: The combined annual import value of these six product categories from China exceeds $4.2 billion. Continuation of orders maintains current duty rates; revocation would reduce duties by 20-120% depending on the product.
• Recommended action: File an entry of appearance within 15 days if you import any of these products and want to participate in the review. Domestic producers seeking continuation should submit adequacy responses. If you currently source from alternative countries, monitor for potential circumvention findings that may expand order coverage.
• Deadline or urgency: 15 days from publication to submit required information for participation. The ITC will determine within 25 days whether to conduct expedited or full reviews.
• Risk if ignored: Missing the participation deadline means you cannot submit arguments for or against revocation, leaving the outcome entirely in the hands of domestic producers and other respondents.

Signal 5: Section 337 — TOPCon Solar Cells (First Solar)

• What happened: The ITC instituted an investigation on certain TOPCon solar cells, modules, panels, components thereof, and products containing same (FR Doc 2026-06121), based on a complaint by First Solar, Inc. alleging infringement of U.S. Patent No. 9,130,074. First Solar requested a general exclusion order — meaning ALL imports of infringing TOPCon cells would be blocked, not just those from named respondents.
• Who is affected: Every importer of TOPCon solar cells and modules — the dominant next-generation solar technology. Major Chinese manufacturers (LONGi, Trina Solar, JA Solar, Jinko Solar) all produce TOPCon cells. This also impacts solar project developers and EPC contractors who have committed to TOPCon installations.
• Estimated financial impact: TOPCon cells represent an estimated $8-12 billion in annual U.S. solar imports. A general exclusion order could halt the majority of solar module imports and trigger project delays worth tens of billions in installed solar capacity.
• Recommended action: Immediately assess your solar supply chain exposure to TOPCon technology. If you have contracts for TOPCon module delivery, add force majeure and tariff escalation clauses. Consider hedging with non-TOPCon alternatives (heterojunction or traditional PERC modules) for projects with 2027+ delivery dates.
• Deadline or urgency: Investigation typically takes 12-18 months. However, preliminary relief could be granted within 6-8 months.
• Risk if ignored: If a general exclusion order issues, all TOPCon imports stop at the border regardless of whether your supplier was a named respondent.

Signal 6: Steel Rebar from Algeria — Final CVD Determination

• What happened: Commerce issued a final affirmative CVD determination on steel concrete reinforcing bar (rebar) from Algeria (FR Doc 2026-06265), finding that countervailable subsidies are being provided to Algerian rebar producers. The POI covers January 1 - December 31, 2024.
• Who is affected: Construction companies, rebar distributors, and infrastructure contractors importing rebar from Algeria (HS 7213.10, 7214.20, 7215.90, 7227.90, 7228.30, 7228.60).
• Estimated financial impact: Algeria is a growing source of rebar imports as buyers diversified away from Turkey and other countries already subject to AD/CVD orders. Final CVD rates will determine the net duty margin — preliminary rates ranged from 5-20%.
• Recommended action: Verify your rebar sourcing and check whether Algerian suppliers are named in the determination. Begin qualifying Brazilian, Mexican, or domestic sources as alternatives. Factor the final duty rate into upcoming infrastructure project bids.
• Deadline or urgency: Final duties effective upon ITC final injury determination (expected within 45 days).
• Risk if ignored: Cash deposit requirements apply immediately; failure to post deposits results in CBP holds at the port of entry.

Signal 7: R-134a from China — Final AD Review Results

• What happened: Commerce completed the administrative review of the AD order on 1,1,1,2-Tetrafluoroethane (R-134a) from China for the April 2023 - March 2024 POR (FR Doc 2026-06448), confirming that R-134a was sold at less than normal value.
• Who is affected: HVAC/R equipment manufacturers, automotive parts distributors, and refrigerant wholesalers importing R-134a (HS 2903.39) from China.
• Estimated financial impact: R-134a is a critical refrigerant for automotive and commercial applications. Continued AD duties of 150-250% on Chinese R-134a maintain price pressure on the approximately $400M annual U.S. refrigerant import market. Buyers are effectively locked out of Chinese supply.
• Recommended action: Continue sourcing from non-Chinese producers (India, Mexico, EU). If you have entries during the POR that haven't liquidated, prepare for potential assessment rate adjustments. Review your 2024-2025 POR entries for exposure.
• Deadline or urgency: Assessment instructions to CBP will issue 15 days after publication. Importers with unliquidated entries should review their exposure now.
• Risk if ignored: Unliquidated entries will be assessed at the final calculated rate, which may differ significantly from the cash deposit rate, resulting in unexpected duty bills.

HS Code Watch List

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Product Category Deep Dives

Deep Dive 1: Corrosion-Resistant Steel Products (CORE) — The Thailand Circumvention Question

Current duty structure: The AD/CVD orders on CORE from Korea carry combined duty rates of approximately 15.4-25.2% depending on the producer/exporter. Korean steel shipped directly to the U.S. already faces these duties. However, CORE completed in Thailand from Korean substrate has been entering duty-free — a loophole that Nucor and SDI argue constitutes circumvention under 19 USC §1677j.

What's changing: Commerce's initiation of a country-wide circumvention inquiry (FR Doc 2026-06449) means all CORE imports from Thailand using Korean inputs are now under scrutiny. If affirmed, duties would apply retroactively to the date of initiation. Commerce will examine whether the processing in Thailand is "minor or insignificant" — the legal standard for circumvention.

Price impact model: Thai CORE steel currently prices at approximately $850-920/ton CIF U.S. port, compared to $1,050-1,150/ton for domestic CORE. A 20% duty would add $170-184/ton, pushing Thai-origin CORE to $1,020-1,104/ton — effectively eliminating the price advantage. Assumptions: current market prices as of Q1 2026, standard ocean freight rates.

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Action checklist:

1. This week: Request certificates of origin and mill test certificates from all Thai CORE suppliers — document the steel substrate origin

2. Within 30 days: File comments with Commerce if you have data supporting that Thai processing is substantial (not minor or insignificant)

3. Within 60 days: Complete qualification of at least one alternative CORE supplier (India or domestic)

4. Ongoing: Monitor the preliminary determination (expected ~150 days) and adjust sourcing accordingly

5. Immediately: Review all unbonded entries of Thai CORE for potential retroactive duty exposure

Deep Dive 2: Erythritol — Navigating the New AD/CVD Orders

Current duty structure: Prior to these orders, erythritol from China entered at most-favored-nation (MFN) duty rates of 5.5% under HS 2905.49. The new combined AD/CVD orders add 35-65% in additional duties on top of the MFN rate, depending on the specific Chinese exporter.

What's changing: The issuance of both AD and CVD orders (FR Doc 2026-06008) means Chinese erythritol is now subject to dual remedy duties. Cash deposits are required immediately on all entries. Given China's 85% global market share in erythritol production, this fundamentally reshapes the global supply landscape for this zero-calorie sweetener.

Price impact model: Chinese erythritol FOB price: $2,800-3,200/ton. With combined duties of 50% (midpoint estimate) plus existing 5.5% MFN: landed cost increases from ~$3,500/ton to ~$5,100/ton — a 46% increase in total landed cost. This pushes Chinese erythritol above the current price of non-Chinese alternatives at $4,200-4,800/ton.

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Action checklist:

1. Immediately: Contact your erythritol supplier to confirm the applicable duty rate for your specific exporter

2. This week: Begin sourcing conversations with Japanese, French, and Korean producers — supply will tighten as the entire market pivots

3. Within 30 days: Review your product formulations — evaluate whether allulose or monk fruit extract could partially substitute at lower cost

4. Before next quarter: Lock in 6-12 month supply contracts with non-Chinese producers before prices adjust upward

Deep Dive 3: Hardwood and Decorative Plywood — Final Phase Looming

Current duty structure: The AD/CVD investigations on hardwood and decorative plywood from China, Indonesia, and Vietnam (FR Doc 2026-05849) are in the final phase, meaning Commerce has already made preliminary affirmative determinations of dumping and subsidization. Current cash deposit rates apply on all entries during the investigation period.

What's changing: The ITC has scheduled the final phase of investigations (Nos. 701-TA-764-766 and 731-TA-1747-1749). The sheer number of HS codes affected — spanning 34 tariff subheadings under 4412 — makes this one of the broadest plywood trade actions in years. It covers virtually all types of hardwood plywood including veneered panels, bamboo panels, and tropical hardwood plywood.

Price impact model: Imported hardwood plywood from the three countries averages $550-750/sheet (4x8). Preliminary AD margins of 20-80% (varying by country and producer) would add $110-600/sheet. For cabinet-grade plywood (the primary U.S. market application), this effectively prices out Chinese plywood and significantly disadvantages Indonesian and Vietnamese product.

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Action checklist:

1. This week: Review your plywood sourcing mix and identify exposure to the three subject countries

2. Within 30 days: Begin qualification of Brazilian and Malaysian plywood suppliers as alternatives

3. Within 60 days: Submit prehearing briefs if you are an interested party — this is your last opportunity to present evidence

4. Long-term: Evaluate domestic plywood producers (Georgia-Pacific, PotlatchDeltic) for cabinet-grade supply

Strategic Analysis

The Circumvention Playbook: Why the Korea-Thailand Steel Inquiry Signals a Broader Enforcement Wave

The development: Commerce's initiation of a circumvention inquiry on corrosion-resistant steel products from Korea completed in Thailand (FR Doc 2026-06449) is far more significant than a single product inquiry might suggest. Filed by Nucor Corporation — the largest U.S. steelmaker with $36.4 billion in 2025 revenue — and Steel Dynamics, Inc. — the fifth-largest with $18.1 billion — this petition targets the precise mechanism that has allowed Asian steel to flow into the U.S. market through third-country processing for the past five years.

Historical parallel: The closest precedent is Commerce's 2019-2021 circumvention findings on Vietnamese steel that originated in China, Korea, and Taiwan. In that wave, Commerce found circumvention in corrosion-resistant steel from Vietnam (using Korean/Taiwanese substrate) and imposed retroactive duties that caught importers with $340 million in unexpected duty liability. The key lesson: once Commerce initiates, the finding rate is approximately 78% — meaning the odds strongly favor Nucor and SDI.

An even more instructive parallel is the wire mesh from Mexico circumvention finding in 2025, where Commerce determined that Mexican producers were assembling U.S.-bound welded wire mesh from Chinese low-carbon steel wire. That finding expanded the China AD/CVD orders to cover Mexican-assembled product — a template that could now be applied to Thailand-assembled Korean CORE steel.

Stakeholder map: On the petitioner side, Nucor and SDI are joined by the American Iron and Steel Institute (AISI) and the Steel Manufacturers Association (SMA), which together represent over 70% of U.S. steel production capacity. The political environment is favorable: both parties in Congress have supported aggressive steel trade enforcement, and the current administration has maintained and expanded Section 232 tariffs.

On the opposing side, Thai steel processors (Sahaviriya Steel Industries, G Steel Public Company) and their U.S. customers will argue that the Thai processing — which includes cold-rolling, galvanizing, and coating — constitutes substantial transformation rather than minor finishing. The Korean steel producers (POSCO, Hyundai Steel) may also weigh in, as a circumvention finding could redirect their exports away from Thailand entirely, reducing their indirect U.S. market access.

Supply chain implications: The first-order effect is straightforward: Thai-origin CORE steel becomes 15-25% more expensive if circumvention is found. But the second-order effects are more consequential. If Thai steel is effectively closed off, approximately $780 million in annual imports must find new channels. This volume will likely shift to: (a) domestic production (benefiting Nucor and SDI — which is precisely why they filed the petition), (b) Indian CORE producers (who are already ramping capacity), and (c) Vietnamese processors (who may themselves become targets of the next circumvention inquiry).

The third-order effect is the chilling impact on all third-country processing arrangements. Every importer sourcing steel, aluminum, or other metals through Southeast Asian finishing operations must now ask: "Am I next?" This inquiry establishes the template for Commerce to investigate any product where the substrate originates in a country subject to AD/CVD orders and is finished in a third country.

Three scenarios:

Best case (20% probability): Commerce finds that Thai processing constitutes substantial transformation — cold-rolling, galvanizing, and coating change the fundamental character of the steel. No duties applied. This would require strong evidence that Thai value-added exceeds 40% of the final product cost, which is unlikely given the capital-intensity of steelmaking versus finishing.

Base case (55% probability): Commerce finds circumvention for some but not all CORE products from Thailand. Specifically, products where Thai processing is limited to coating or galvanizing (minor alteration) would be covered, while products involving cold-rolling from hot-rolled coil (more substantial transformation) might be excluded. Importers face partial retroactive duties and must restructure sourcing for the affected product categories.

Worst case (25% probability): Commerce issues a blanket circumvention finding covering all CORE products from Thailand containing Korean-origin substrate, regardless of the extent of Thai processing. Full retroactive duties of 15-25% apply to all entries from the date of initiation. This triggers a cascading effect as Commerce receives similar petitions for other products and other third countries.

The contrarian take: Most market participants are focused on the duty impact, but the real story is capacity allocation. If $780 million in Thai CORE imports shift to domestic producers, Nucor and SDI gain the pricing power they've been seeking. The circumvention petition is as much about market control as trade law compliance. Importers who fixate on duty rates while ignoring the supply-demand rebalancing will miss the bigger picture: domestic steel prices may rise 5-8% regardless of the circumvention outcome, simply because the inquiry creates uncertainty that shifts procurement toward domestic sources in the interim. The smart play is to lock in domestic steel contracts now at current prices, before the market fully prices in the supply shift.

Compliance Deadlines Calendar

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China LATAM EU APAC Trade Monitor

China: The Enforcement Squeeze Intensifies

This week's six simultaneous five-year reviews on Chinese products (steel cylinders, chassis, mattresses, engines, wire strand, shelving) — all initiated on the same date — represent a coordinated enforcement posture, not coincidence. Commerce is simultaneously initiating sunset reviews (FR Doc 2026-06326) covering dozens of additional Chinese products. The message is clear: existing orders on Chinese goods will be maintained, not revoked.

The new AD/CVD orders on erythritol (FR Doc 2026-06008) and the continuation of PET film orders (FR Doc 2026-06007) covering China, India, Taiwan, and the UAE confirm that Commerce is not softening its stance. Meanwhile, the Section 337 investigation on TOPCon solar cells (FR Doc 2026-06121) — filed by First Solar seeking a general exclusion order — could be the most impactful single trade action of 2026 if it succeeds, potentially blocking the dominant solar cell technology from U.S. import. The lithium hexafluorophosphate petition (FR Doc 2026-06128) targeting Chinese battery materials adds another front in the critical minerals trade war. Net assessment: China trade enforcement is accelerating across consumer, industrial, and clean energy sectors simultaneously.

Latin America: Tomato Tensions and Nearshoring Complications

The fresh tomato certification extension (FR Doc 2026-06420) highlights ongoing tensions under the suspended AD investigation on Mexican tomatoes. The extended deadline to April 15 gives processors more time to comply, but the underlying dispute — whether Mexican tomato growers are pricing below fair value — remains unresolved and could re-escalate if the suspension agreement is terminated.

The CORE steel circumvention inquiry (FR Doc 2026-06449) has indirect LATAM implications: as importers diversify away from Thailand, Brazilian and Mexican steel producers stand to capture diverted volume. Brazil's Gerdau and Mexico's Ternium are well-positioned to supply CORE steel to the U.S. market without AD/CVD exposure — for now. However, the precedent of investigating third-country finishing operations means that any LATAM producer using Korean or Chinese substrate could face similar scrutiny. The nearshoring narrative remains strong, but circumvention risk now attaches to any supply chain that touches Chinese or Korean inputs.

EU: Thermal Paper and Transatlantic Trade Dynamics

The preliminary AD results on thermal paper from Germany (FR Doc 2026-06016) found no dumping — sales were at or above normal value for the 2023-2024 POR. This is a relatively rare favorable outcome for a European exporter and suggests that German thermal paper producers are pricing competitively without subsidization. The partial rescission covering 14 companies further narrows the review's scope.

On the broader EU trade front, the continuation of PET film orders covering multiple countries (FR Doc 2026-06007) signals that transatlantic trade remedy disputes will persist. EU producers of PET film face continued U.S. market access challenges, though the primary targets remain Asian producers. The U.S.-Australia FTA tariff-rate quota publication (FR Doc 2026-06207) demonstrates ongoing management of bilateral trade agreements — a model that EU trade negotiators have sought to replicate in stalled U.S.-EU trade talks.

APAC: Thailand Under the Microscope, Solar Cells in the Crosshairs

Thailand is this week's focal point — the CORE steel circumvention inquiry (FR Doc 2026-06449) puts Thai finishing operations on notice. But the implications extend to all APAC finishing hubs: Vietnam, Malaysia, Indonesia, and the Philippines. If Thai CORE processing is deemed circumvention, Commerce has the template to investigate Vietnamese steel processing, Malaysian electronics assembly, and Indonesian plywood production — all of which involve Chinese or Korean inputs with APAC finishing.

The Section 337 investigations on NAND/DRAM memory chips (FR Doc 2026-06113) and in-vehicle infotainment systems (FR Doc 2026-06126) target products manufactured across APAC — primarily in South Korea, Japan, Taiwan, and China. The monosodium glutamate expedited review (FR Doc 2026-05951) covering China and Indonesia adds another APAC product to the enforcement queue. For the solar sector, First Solar's TOPCon investigation (FR Doc 2026-06121) effectively targets the entire Chinese solar manufacturing ecosystem, which has significant operations in Vietnam, Malaysia, and Thailand through companies like LONGi, Trina, and JA Solar. APAC supply chains face multi-vector trade risk from conventional AD/CVD, Section 337, and circumvention enforcement simultaneously.

What Were Watching Next Week

1. CORE Steel Circumvention — Industry Response Window Opens

When: Comments accepted starting this week, due approximately May 2, 2026

Why it matters: The quality and volume of industry comments will signal whether Commerce faces significant opposition to a circumvention finding. Watch for filings from Thai steel processors, Korean producers, and U.S. end-users (particularly automotive and appliance manufacturers who rely on Thai CORE supply). Early filings may indicate which way the preliminary determination will lean.

Prepare now: If you import CORE steel from Thailand, engage trade counsel immediately and begin preparing your factual submission documenting the extent of Thai processing.

2. ITC Five-Year Review Adequacy Determinations

When: Approximately 25 days from initiation (late April 2026)

Why it matters: The ITC will determine whether to conduct expedited or full reviews for the six China product categories. Expedited reviews typically result in continuation of orders because they indicate insufficient industry participation to warrant a full review. If all six proceed as expedited reviews, it signals that Chinese and third-country producers are not contesting continuation — meaning these duties are effectively permanent.

Prepare now: File entries of appearance by the 15-day deadline if you want any voice in the outcome.

3. EPA RFS Amendatory Instruction 47 — April 28 Effective Date

When: April 28, 2026

Why it matters: This is the first provision of the massive RFS final rule to take effect, specifically revising biogas provisions. Obligated parties — including renewable fuel importers and blenders — must be in compliance by this date. The broader rule (including eRIN elimination) follows on June 15, but April 28 is the first compliance trigger.

Prepare now: Review your current biogas-related RFS obligations and confirm your compliance pathway accounts for the revised provisions.

4. Hardwood Plywood Final Phase — Hearing Schedule

When: Expected scheduling announcement in early April

Why it matters: The ITC's final phase hearing for the hardwood and decorative plywood investigations covering China, Indonesia, and Vietnam will determine whether duties become permanent. With 34 HS codes at stake, this is one of the broadest plywood trade actions in U.S. history. The hearing schedule will set the timeline for final duty rates and order issuance.

Prepare now: If you haven't already retained trade counsel for this investigation, this is your last opportunity to prepare prehearing briefs and testimony.

5. Lithium Hexafluorophosphate Petition Adequacy Decision

When: Extended deadline — exact date TBD per FR Doc 2026-06128

Why it matters: This petition targets a critical EV battery material from China. If Commerce determines the petition is adequate and initiates an investigation, it would add lithium hexafluorophosphate to the growing list of Chinese battery supply chain inputs subject to trade remedies — alongside graphite, battery-grade lithium, and other materials. The EV supply chain implications are enormous: virtually all U.S. lithium-ion battery production depends on Chinese-origin LiPF6.

Prepare now: EV battery manufacturers and their suppliers should map their LiPF6 sourcing and identify whether Japanese or Korean alternatives could be qualified if duties are imposed.