China Trade Enforcement Surge: 8 Five-Year Reviews, New AD/CVD Orders on Erythritol, and Steel Circumvention Inquiry Hits Korea-Thailand Route

Executive Summary

This week marks one of the most concentrated waves of China-focused trade enforcement action in 2026, with the ITC and Commerce Department simultaneously launching eight five-year (sunset) reviews on Chinese products ranging from non-refillable steel cylinders to prestressed concrete wire strand, while initiating a major circumvention inquiry on corrosion-resistant steel products from Korea being completed in Thailand. For importers, this is not routine housekeeping — it signals a sustained and intensifying posture on Chinese trade remedies with no sign of rollback on the horizon.

The headline development is Commerce's initiation of a circumvention inquiry on corrosion-resistant steel products (CORE) from Korea (FR Doc 2026-06449), requested by Nucor Corporation and Steel Dynamics. This inquiry targets Korean CORE completed in Thailand using Korean-origin components — a pattern that, if confirmed, would extend existing AD/CVD duties to Thai-assembled products. Steel importers sourcing CORE from Thailand should immediately audit their supply chain origin documentation, as retroactive duty liability is a real risk once circumvention is confirmed.

Meanwhile, the macro picture is flashing warning signs. The U.S. trade deficit widened to $57.3 billion in February 2026, up from $54.7 billion in January, while the Import Price Index climbed to 144.0 — its highest reading since early 2023 and a clear signal that tariff costs are flowing through to landed prices. The PPI for Manufacturing surged to 257.3, confirming cost pressures across the production chain. With the Trade Weighted Dollar Index at 120.9, a relatively strong dollar is providing only partial relief against rising import costs.

This week, you should: (1) Audit CORE steel sourcing from Thailand for circumvention exposure; (2) Review HS codes affected by the eight five-year reviews to assess whether your products face continued or increased duties; (3) File responses to the annual administrative review opportunity notice by the posted deadlines; (4) Check the fresh tomato certification extension if you import processing tomatoes from Mexico; (5) Monitor the lithium hexafluorophosphate petition from China, which could impact battery supply chains.

The Week In Numbers

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Key takeaway: The simultaneous rise in Import Price Index (+1.3% MoM) and PPI Manufacturing (+1.6% MoM) confirms that tariff and trade remedy costs are accelerating through the supply chain faster than consumer prices (CPI +0.3% MoM). This compression means importers and manufacturers are absorbing margin pressure that hasn't yet fully passed to end consumers — a dynamic that cannot persist indefinitely. The widening trade deficit despite a strong dollar suggests import volumes are being driven by inventory front-loading ahead of anticipated duty increases.

Key Signals This Week

Signal 1: Circumvention Inquiry on Corrosion-Resistant Steel (Korea → Thailand)

• What happened: Commerce initiated a country-wide circumvention inquiry on CORE from Korea, completed in Thailand using Korean components (FR Doc 2026-06449). Nucor Corporation and Steel Dynamics requested the inquiry, alleging that Korean producers are shipping semi-finished CORE to Thailand for completion and re-export to the U.S. to avoid existing AD/CVD orders on Korean CORE.
• Who is affected: Importers of corrosion-resistant steel products classified under HS 7210 (flat-rolled steel, coated), HS 7212, and related subheadings. Automotive parts manufacturers, appliance makers, construction materials distributors, and any company sourcing galvanized or coated steel from Thailand.
• Estimated financial impact: The existing AD duty on Korean CORE ranges from 0.51% to 47.80%, and CVD rates range from 0.44% to 58.36%. If circumvention is confirmed, importers currently paying zero or low duties on Thai-completed CORE would face retroactive duty deposits at these rates, potentially adding $15-50 per metric ton to landed costs depending on the applicable rate.
• Recommended action: Immediately audit all CORE imports from Thailand for Korean-origin substrate. Request mill certificates and origin documentation from Thai suppliers. If Korean substrate is confirmed, consult a trade attorney about voluntary self-disclosure and begin identifying alternative sources (India, Vietnam domestic production, or domestic U.S. mills).
• Deadline: The inquiry is now open. Commerce will issue preliminary findings within approximately 90-120 days. Importers should begin compliance documentation immediately as retroactive liability accrues from the date of initiation.
• Risk if ignored: Retroactive duty liability on all imports from the date of initiation, plus potential penalties for failure to disclose known circumvention risks. Financial exposure could run into hundreds of thousands of dollars for mid-size importers.

Signal 2: Eight Simultaneous Five-Year Reviews on Chinese Products

• What happened: The ITC instituted five-year reviews on eight separate product categories from China in a single week: non-refillable steel cylinders (FR Doc 2026-06293), chassis and subassemblies (FR Doc 2026-06292), mattresses from multiple countries including China (FR Doc 2026-06290), small vertical shaft engines (FR Doc 2026-06289), prestressed concrete steel wire strand (FR Doc 2026-06288), boltless steel shelving units (FR Doc 2026-06287), monosodium glutamate from China and Indonesia (FR Doc 2026-05951), and PET film from India, Taiwan, China, and UAE (FR Doc 2026-06007).
• Who is affected: Importers and domestic producers across a remarkably broad range of industries — propane/refrigerant distributors, trailer and chassis manufacturers, mattress retailers and importers, outdoor power equipment companies, construction materials suppliers, warehouse and retail fixture companies, food ingredient importers, and packaging film converters.
• Estimated financial impact: Collectively, these orders cover billions of dollars in annual trade. If any order is revoked, affected importers could see duty savings of 20-300%+ depending on the product. If continued (the most likely outcome based on historical patterns where ~85% of sunset reviews result in continuation), current duty structures remain in place.
• Recommended action: If you import ANY of these products, submit an entry of appearance to the ITC within the response deadline. Even if you expect continuation, participating ensures you have standing to present evidence if market conditions have changed. For mattress importers specifically, note that seven countries are under simultaneous review — this is a strategic opportunity to present data on whether the cumulative effect of duties across all seven origins is causing supply shortages.
• Deadline: Response deadlines vary by proceeding but typically fall 30-45 days from the Federal Register publication date (i.e., early to mid-May 2026).
• Risk if ignored: If you don't participate and an order is continued or modified unfavorably, you lose the ability to influence the outcome. Conversely, if you fail to participate and an order is revoked, you may miss the window to adjust your sourcing strategy competitively.

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). This follows affirmative final determinations by both Commerce and the ITC that imports of erythritol were being sold at less than fair value and received countervailable subsidies, and that the U.S. industry was materially injured.
• Who is affected: Food and beverage manufacturers using erythritol as a sugar substitute (classified under HS 2905.49), supplement companies, and specialty ingredient distributors. Given the explosion of "zero sugar" products in the U.S. market, this affects a rapidly growing $2+ billion ingredient category.
• Estimated financial impact: AD/CVD combined rates on Chinese erythritol will likely range from 30% to over 100% based on Commerce's preliminary findings. With China currently dominating global erythritol production capacity (~80%), ingredient costs for affected manufacturers could double in the near term before alternative supply sources come online.
• Recommended action: Immediately assess your erythritol inventory position and forward purchase contracts. Begin qualifying alternative suppliers from India, France, and Japan. If you are a small food manufacturer dependent on Chinese erythritol, consider reformulating with other sugar alcohols (xylitol, allulose) as a medium-term hedge.
• Deadline: Orders are effective immediately upon Federal Register publication. Duty deposits are required on all entries from the date of the order.
• Risk if ignored: Immediate margin compression on any products using Chinese erythritol. Companies slow to diversify sourcing will face the worst price increases as demand for non-Chinese supply surges.

Signal 4: Section 337 Investigation — TOPCon Solar Cells (First Solar vs. Chinese Imports)

• What happened: The ITC instituted a Section 337 investigation on TOPCon solar cells, modules, panels, and components (FR Doc 2026-06121), filed by First Solar of Phoenix, Arizona, alleging patent infringement of U.S. Patent No. 9,130,074. First Solar is seeking a general exclusion order — the nuclear option that would block ALL infringing products regardless of manufacturer, not just those of named respondents.
• Who is affected: Every U.S. solar installer, developer, and distributor sourcing TOPCon-architecture panels, which represent the dominant and fastest-growing segment of the global solar panel market. Chinese manufacturers including LONGi, Trina, JA Solar, and JinkoSolar are the primary targets.
• Estimated financial impact: A general exclusion order on TOPCon panels would disrupt 60-70% of U.S. solar panel imports and could add $0.05-0.15/watt to module costs, translating to $3,000-9,000 per average residential installation. The U.S. solar industry imports approximately $15 billion in panels annually.
• Recommended action: Solar project developers should assess their panel technology exposure (TOPCon vs. PERC vs. heterojunction vs. First Solar's CdTe). Begin qualifying non-TOPCon alternatives. Lock in supply contracts with existing TOPCon inventory before any exclusion order takes effect. Monitor the ITC's preliminary determination timeline (typically 9-15 months from institution).
• Deadline: Investigation timeline runs 12-18 months. No immediate import restriction, but a preliminary determination could come as early as Q1 2027.
• Risk if ignored: If a general exclusion order is issued, importers without alternative panel technology supply chains will face severe supply disruptions. Companies that begin diversifying now will have 12+ months of lead time advantage.

Signal 5: L-Lysine from China — Final Phase AD/CVD Investigation

• What happened: The ITC scheduled the final phase of antidumping and countervailing duty investigations on animal feed-grade L-lysine from China (FR Doc 2026-06529), classified under HS 2922.41.00. Commerce has already preliminarily determined that Chinese L-lysine is both subsidized and sold at less than fair value.
• Who is affected: Animal feed manufacturers, poultry and swine producers, and agricultural input distributors. L-lysine is an essential amino acid supplement in livestock feed with no practical substitutes at scale.
• Estimated financial impact: With China supplying an estimated 40-50% of global L-lysine capacity, AD/CVD duties could raise feed costs by $50-150 per ton of L-lysine, translating to a $0.01-0.03/lb increase in meat production costs across the U.S. livestock industry.
• Recommended action: Evaluate your L-lysine supply chain exposure. If sourcing from China, begin qualifying suppliers from Korea (CJ CheilJedang), Japan (Ajinomoto), and Brazil (emerging capacity). Lock in forward contracts at current pricing where possible.
• Deadline: The ITC's final determination is expected within 45-75 days of the scheduling notice.
• Risk if ignored: Once final orders are issued, duty deposits will be required on all Chinese L-lysine imports. Feed manufacturers without diversified sourcing will face immediate cost increases.

Signal 6: R-134a Refrigerant — Final AD Review Results from China

• What happened: Commerce published final results of the antidumping duty administrative review on R-134a (1,1,1,2-Tetrafluoroethane) from China for the period April 2023-March 2024 (FR Doc 2026-06448). Commerce determined that R-134a was sold at less than normal value, confirming continued dumping.
• Who is affected: HVAC contractors, automotive service shops, refrigerant distributors, and manufacturers of automotive air conditioning systems. R-134a remains the dominant automotive refrigerant despite the gradual transition to R-1234yf.
• Estimated financial impact: Updated dumping margins from this review will set the cash deposit rates for the next 12 months of Chinese R-134a imports. Given that Chinese R-134a prices are typically 30-50% below U.S. domestic production costs before duties, the effective rate likely remains in the 100-200% range.
• Recommended action: Verify your current cash deposit rates match the newly published final rates. If you have entries from the review period with estimated deposits, expect liquidation instructions within 60-90 days. Adjust pricing models accordingly.
• Deadline: New cash deposit rates take effect upon Federal Register publication. Importers should update their customs broker instructions immediately.
• Risk if ignored: Incorrect deposit rates lead to underpayment penalties and interest charges. Failure to adjust pricing could erode margins if rates increased from the prior review.

Signal 7: Steel Rebar from Algeria — Final CVD Determination

• What happened: Commerce issued a final affirmative countervailing duty determination on steel concrete reinforcing bar from Algeria (FR Doc 2026-06265). This confirms that Algerian rebar producers receive countervailable subsidies, with the investigation covering the period January 1-December 31, 2024.
• Who is affected: Construction companies, rebar distributors, and infrastructure contractors sourcing imported rebar. Algeria has been an emerging alternative source for rebar as duties on traditional suppliers (Turkey, Japan) have made those origins less competitive.
• Estimated financial impact: CVD rates will be established for Algerian rebar, likely in the 5-25% range based on typical subsidy findings for steel products. This effectively closes another low-cost sourcing option for U.S. construction.
• Recommended action: Reassess your rebar sourcing strategy. With duties now covering Algeria in addition to existing orders on other origins, domestic procurement or sourcing from non-covered origins (Portugal, Spain) becomes more attractive. Factor the new CVD rates into upcoming project bids.
• Deadline: Orders take effect upon ITC's final injury determination. Monitor the ITC calendar for the companion injury vote.
• Risk if ignored: Bids submitted without accounting for the new duties will be underpriced, creating margin risk on fixed-price construction contracts.

HS Code Watch List

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Product Category Deep Dives

Deep Dive 1: Corrosion-Resistant Steel Products (CORE)

Current duty structure: Korean CORE faces AD rates of 0.51%-47.80% and CVD rates of 0.44%-58.36% under existing orders. Thai CORE currently enters at MFN rates (typically 0-3%) with no trade remedy duties — making Thailand an attractive transshipment or completion point for Korean steel.

What's changing: The circumvention inquiry (FR Doc 2026-06449) could extend Korean AD/CVD duties to CORE completed in Thailand using Korean substrate. Commerce will examine whether Thai operations constitute "minor or insignificant processing" that does not substantially transform the Korean-origin steel. If affirmative, all Thai-completed CORE with Korean substrate will face the full Korean duty schedule.

Price impact model: Assuming an average Korean AD/CVD combined rate of 25% on CORE with a base price of $800/metric ton, the duty addition would be $200/metric ton. For an importer bringing in 5,000 MT/year of Thai-completed CORE, the annual duty exposure is $1 million. If retroactive to the date of initiation, past entries could also face duty assessment.

Sourcing alternatives matrix:

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Action checklist: (1) By April 15: Complete audit of all Thai CORE imports for Korean-origin substrate; (2) By April 30: Request mill test certificates and origin declarations from Thai suppliers; (3) By May 15: Engage a trade attorney if Korean substrate is identified in your supply chain; (4) By June 1: Begin qualifying at least one alternative CORE source from a non-covered origin; (5) Ongoing: Monitor Commerce's preliminary circumvention determination, expected in July-August 2026.

Deep Dive 2: Erythritol and Sugar Substitutes

Current duty structure: Chinese erythritol previously entered under HS 2905.49 at MFN rates (typically 3.7% ad valorem). The new AD/CVD orders add substantial additional duties on top of the MFN rate, effectively creating a tariff wall of 30-100%+ depending on the producer-specific rates assigned by Commerce.

What's changing: With the issuance of final AD/CVD orders (FR Doc 2026-06008), all Chinese erythritol imports now require duty deposits at the applicable rates. This is a completed action — not a proposal. China produces approximately 80% of the world's erythritol, making this order uniquely disruptive to a supply chain with extremely concentrated sourcing.

Price impact model: Chinese erythritol FOB price is approximately $1.50-2.00/kg. At a combined AD/CVD rate of 60% (midrange estimate), the duty adds $0.90-1.20/kg to landed cost. For a food manufacturer using 500 MT/year, the annual cost increase is $450,000-600,000. Retail price impact on sugar-free products could reach 5-15% once manufacturers pass through costs.

Sourcing alternatives matrix:

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Action checklist: (1) Immediately: Calculate your per-unit erythritol cost impact and update product P&Ls; (2) Within 2 weeks: Contact non-Chinese suppliers (Cargill, Mitsubishi) for availability and pricing; (3) Within 30 days: Evaluate reformulation options using allulose, monk fruit extract, or blended sweetener systems; (4) Within 60 days: Adjust retail pricing or promotional strategy to reflect increased input costs; (5) Ongoing: Monitor whether Commerce assigns separate rates that could create lower-duty channels for specific Chinese producers.

Deep Dive 3: Solar Panels and Clean Energy Components

Current duty structure: Chinese solar panels already face a complex layered duty structure: Section 201 safeguard duties (14.75% in 2026, declining annually), AD duties on crystalline silicon PV cells from China (ranging from 15.85% to 238.95%), and CVD duties (14.78% to 15.97%). Additionally, the Uyghur Forced Labor Prevention Act (UFLPA) creates supply chain compliance requirements. Southeast Asian manufacturers face their own AD/CVD orders following the 2024 solar circumvention cases.

What's changing: First Solar's Section 337 complaint (FR Doc 2026-06121) targets TOPCon solar technology specifically through patent infringement claims. Unlike AD/CVD duties (which are financial), a Section 337 exclusion order would physically block infringing products at the border. First Solar is requesting a general exclusion order, meaning ALL TOPCon panels — regardless of manufacturer or country of origin — could be blocked if they infringe the '074 patent.

Price impact model: TOPCon panels currently represent approximately 60-65% of new solar panel shipments to the U.S. market. If a general exclusion order is issued, the sudden supply reduction would drive panel prices up by an estimated $0.05-0.15/watt, translating to: residential installations (+$3,000-9,000 per system), commercial projects (+$50,000-150,000 per MW), and utility-scale (+$2.5M-7.5M per 50 MW project). Total market impact: $3-9 billion annually.

Sourcing alternatives matrix:

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Action checklist: (1) Immediately: Inventory your current panel supply by technology type (TOPCon vs. PERC vs. other); (2) Within 30 days: Engage First Solar and heterojunction panel suppliers for availability; (3) Within 60 days: For projects with 2027+ timelines, evaluate non-TOPCon alternatives; (4) Within 90 days: Stock critical TOPCon inventory before any preliminary determination; (5) Ongoing: Hire a patent attorney to assess whether your specific panel models infringe the '074 patent.

Strategic Analysis

The CORE Steel Circumvention Inquiry: A Template for Broader Enforcement

The Commerce Department's initiation of a circumvention inquiry on corrosion-resistant steel products from Korea being completed in Thailand (FR Doc 2026-06449) is this week's most strategically significant development — not because of the dollar value of CORE steel alone, but because it signals a new phase in how the U.S. enforces trade remedies against sophisticated supply chain rerouting.

The Development in Context

Nucor Corporation and Steel Dynamics — the two largest U.S. steel producers by market capitalization — filed this petition alleging that Korean CORE producers are shipping semi-finished coated steel to Thailand, where minimal processing is performed before re-export to the United States. This is the classic circumvention playbook: country-hop the product through a third country to avoid duties while performing only token value-added operations. Commerce's decision to initiate on a country-wide basis (rather than company-specific) is unusually aggressive — it means ALL Thai CORE with Korean substrate is potentially in scope, not just named respondents.

Historical Parallel

The closest precedent is the 2024 solar panel circumvention case (Cambodia, Malaysia, Thailand, Vietnam), where Commerce found that Chinese solar manufacturers had established assembly operations in Southeast Asia specifically to avoid AD/CVD duties on Chinese panels. That case resulted in new AD/CVD orders on solar cells from all four countries, effectively closing the circumvention route. The solar case took approximately 14 months from initiation to final orders. The key lesson: once Commerce initiates a circumvention inquiry, the finding rate is approximately 75-80% affirmative. The statistical odds heavily favor a finding of circumvention.

Stakeholder Map

Pushing for enforcement: Nucor (largest U.S. steel producer, ~$30B revenue), Steel Dynamics (~$18B revenue), the American Iron and Steel Institute (AISI), and the United Steelworkers union. This coalition has extraordinary political influence across both parties — steel protectionism has bipartisan support in Congress.

Opposing: Korean steel producers (POSCO, Hyundai Steel), Thai processing facilities, and downstream U.S. manufacturers who benefit from lower-cost imported CORE (automotive, appliance, and construction industries). The Korea International Trade Association (KITA) and the Thai Ministry of Commerce will likely intervene diplomatically.

Supply Chain Implications: Second and Third-Order Effects

First-order: Thai-completed CORE with Korean substrate becomes duty-liable, raising costs for importers of that specific product. Second-order: Importers shift to other Southeast Asian origins (Vietnam, Indonesia, India), creating a demand surge that raises prices across all non-domestic CORE sources. Vietnam in particular could face its own circumvention inquiry within 12-18 months if it absorbs redirected Korean steel. Third-order: Domestic U.S. steel prices firm as the effective supply of competitively-priced imported CORE narrows. Nucor and Steel Dynamics benefit directly, but U.S. manufacturers face higher input costs that reduce export competitiveness — a bitter irony of protectionist trade policy.

Three Scenarios

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The Contrarian Take

Conventional wisdom says this is bad for importers and good for domestic steel. But consider: if every circumvention route is systematically closed, Korean CORE producers may invest directly in U.S. production capacity (as POSCO has done with its JV with U.S. Steel). This would increase domestic supply competition in the medium term (3-5 years), potentially lowering U.S. CORE prices below where they would be under import-dependent supply chains. The aggressive enforcement posture may ultimately be self-defeating for domestic producers if it triggers a wave of foreign direct investment in U.S. steel capacity. Additionally, the Thai government may accelerate its own trade agreements with the U.S. to protect its steel processing industry, creating broader market access opportunities.

Compliance Deadlines Calendar

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China LATAM EU APAC Trade Monitor

China: Enforcement Intensifies Across the Board

This week's eight simultaneous five-year reviews on Chinese products — spanning steel cylinders, chassis, mattresses, engines, wire strand, shelving, MSG, and erythritol — represent the most concentrated wave of China-specific trade enforcement in 2026 to date. The new AD/CVD orders on erythritol (FR Doc 2026-06008) are particularly significant because they target a product category where China holds ~80% of global production capacity, creating genuine supply chain disruption rather than merely shifting sourcing to the next cheapest origin.

The Section 337 investigation on TOPCon solar cells (FR Doc 2026-06121) adds a patent enforcement dimension to the existing tariff barriers on Chinese clean energy products. Combined with the UFLPA enforcement and existing AD/CVD/Section 201 duties, the solar panel trade barrier is now a five-layer deep system: AD duties, CVD duties, Section 201 safeguards, UFLPA enforcement, and now Section 337 patent exclusion. No other product category faces this level of trade restriction complexity.

The lithium hexafluorophosphate petition deadline extension (FR Doc 2026-06128) signals that another critical battery material may soon face AD/CVD duties. China dominates global LiPF6 production, and duties here would directly impact EV battery costs at a time when the U.S. is trying to build domestic battery supply chains under the IRA.

Latin America: Mexico Tomato Certification and USMCA Dynamics

The extension of the fresh tomato certification deadline (FR Doc 2026-06420) provides welcome breathing room for importers of Mexican processing tomatoes, but the underlying tension remains: the U.S. AD duty order on Mexican tomatoes continues to create compliance complexity for one of the largest agricultural trade flows under USMCA. The certification requirement — which forces importers to verify that tomatoes are destined for processing, not fresh market sale — adds administrative burden that disproportionately affects smaller importers.

Meanwhile, the CORE steel circumvention inquiry has indirect LATAM implications. If Thai-completed Korean steel is blocked, some importers may look to Mexico or Brazil as alternative CORE sources. Mexico's steel sector, which has grown significantly under USMCA preferential treatment, could capture redirected demand — but Mexican CORE faces its own scrutiny under Section 232 steel tariff exemptions. Brazilian CORE, with no current AD/CVD orders, represents a genuinely open sourcing alternative but with longer lead times (10-14 weeks) and higher logistics costs.

EU: Parallel Enforcement Patterns

The thermal paper from Germany preliminary AD results (FR Doc 2026-06016) — where Commerce found no dumping — is a rare positive development for EU-U.S. trade. German thermal paper producers were found to be selling at fair value, suggesting this particular order may be rescinded. This is noteworthy because it demonstrates that the AD process can produce acquittals, not just convictions — an important signal for EU trade relations.

However, the broader EU-U.S. trade dynamic remains tense. The PET film five-year review includes India, Taiwan, China, and UAE but notably does NOT include EU producers — suggesting that EU PET film exporters have managed to stay below the trade enforcement radar. EU companies positioned as alternative sources for products under Chinese AD/CVD orders continue to benefit from trade diversion effects, particularly in chemicals, advanced materials, and specialty steel.

APAC: Thailand in the Crosshairs, Solar Supply Chain Disruption

Thailand is this week's APAC focal point, with the CORE steel circumvention inquiry (FR Doc 2026-06449) directly targeting Thai processing operations. This follows the pattern established by the 2024 solar circumvention cases, where Thailand (along with Cambodia, Malaysia, and Vietnam) was found to be facilitating Chinese circumvention of AD/CVD duties. Thailand's role as a trade remedy "safe harbor" is rapidly eroding, and companies using Thai operations as part of their duty-avoidance strategy should reassess urgently.

The Section 337 investigation on NAND and DRAM memory chips (FR Doc 2026-06113), while primarily targeting specific patents, has implications for Korean and Japanese memory manufacturers (Samsung, SK Hynix, Kioxia, Micron) who produce chips used across the APAC electronics supply chain. The US-Australia FTA tariff-rate quota publication (FR Doc 2026-06207) for 2026 is routine but noteworthy as it maintains preferential access for Australian agricultural products at a time when other trade relationships are under strain.

What Were Watching Next Week

1. Commerce Preliminary Determination Timeline on CORE Circumvention

• When: Expect Commerce to publish its preliminary investigation schedule within 2 weeks of the April 2 Federal Register notice, with questionnaires going out to Thai and Korean respondents.
• Why it matters: The speed of Commerce's preliminary investigation will signal how aggressively they're pursuing this case. A fast-tracked preliminary (within 90 days) would indicate strong initial evidence of circumvention.
• Prepare now: If you import CORE from Thailand, compile your supplier documentation before questionnaires arrive. Having organized records of steel origin, processing operations, and value-added in Thailand will be critical.

2. ITC Scheduling of Erythritol Injury Vote

• When: The ITC's final injury determination on erythritol should be published on its schedule within the next 1-2 weeks.
• Why it matters: While an affirmative determination is highly likely (Commerce already issued orders, implying ITC injury finding is confirmed), the specific duty rates published in the final orders will determine the magnitude of the cost impact. Rate-specific details typically emerge in the ITC's final determination.
• Prepare now: Run scenario analysis on your product costs at 30%, 60%, and 100% combined duty rates on Chinese erythritol.

3. Five-Year Review Response Deadlines

• When: Response deadlines for the eight simultaneous five-year reviews will fall in early to mid-May 2026.
• Why it matters: These reviews collectively cover billions in trade. Participation — even through a simple filing — preserves your standing and voice in the process. The ITC uses participation rates to gauge industry interest; low participation can lead to expedited reviews with less favorable outcomes for importers.
• Prepare now: Identify which of the eight review product categories are in your supply chain and begin preparing entries of appearance.

4. March 2026 Trade Deficit Data Release

• When: Expected in the first full week of April from the Bureau of Economic Analysis.
• Why it matters: February's deficit of $57.3 billion was already elevated. If March shows further widening, it will fuel political pressure for additional trade enforcement actions. Conversely, a narrowing could reduce the urgency behind new trade remedy petitions. Watch particularly for the goods-only deficit with China, which is the politically sensitive headline number.
• Prepare now: Position your trade policy monitoring to capture the BEA release and correlate it with any immediate political statements or executive orders.

5. Lithium Hexafluorophosphate Petition Adequacy Decision

• When: Commerce extended the deadline (FR Doc 2026-06128) but a decision on petition adequacy is expected within the next 2-4 weeks.
• Why it matters: If Commerce finds the petition adequate, it will initiate a full AD/CVD investigation on Chinese LiPF6 — a critical battery electrolyte salt. This would be the first major trade remedy action directly targeting EV battery materials and could raise domestic battery production costs by 5-15%. The broader signal: trade enforcement is expanding from traditional industries into the clean energy supply chain.
• Prepare now: Battery manufacturers and EV companies should assess their LiPF6 sourcing exposure and begin identifying Japanese (Kanto Denka) and Korean (Soulbrain) alternative suppliers.