A U.S. antidumping or countervailing-duty case proceeds on a statutory timeline set by the Tariff Act of 1930: a domestic industry files a petition with both the Commerce Department and the International Trade Commission, provisional duties can attach within about seven months, and final duties typically order within 12 to 18 months. In recent years U.S. companies have filed dozens of these petitions annually — 231 new AD/CVD investigations were initiated in fiscal 2024, per the ITC's own count — and the duties, once imposed, can run for decades.
The two agencies split the work by question. Commerce determines whether dumping or subsidization occurred and calculates a margin; the ITC determines whether the U.S. industry was injured by it. Both must come back positive for duties to stick.
What are dumping and subsidizing?
Dumping means selling in the U.S. market below "normal value" — usually the price in the exporter's home market — and a subsidy is a financial benefit from a foreign government that Commerce counts under its rules. Neither is illegal as such. The U.S. system treats them as actionable only when they cause material injury to a U.S. industry producing a like product, a determination the ITC makes from data on shipments, prices, profits, and employment.
What is the timeline?
The clock is fixed by statute, and every deadline below is statutory, per the ITC's published procedural guide:
| Step | Deadline | Who acts |
|---|---|---|
| Petition filed | Day 0 | Domestic industry |
| Initiation decision | Within 20 days | Commerce |
| Preliminary injury vote | Within 45 days | ITC |
| Preliminary CVD determination | Within ~65 days | Commerce |
| Preliminary AD determination | Within ~140 days | Commerce |
| Final AD/CVD determination | Within ~75 days of prelim | Commerce |
| Final injury vote | Within 45 days of Commerce final | ITC |
| Order issued | Within 7 days of affirmative vote | Commerce |
Once Commerce issues a preliminary dumping determination, importers must post cash deposits on new entries — the point where the case starts to bite before it is decided.
What do importers face after an order?
Duties are assessed on the importer of record, and the rate is prospective: estimated deposits at entry, trued up in annual administrative reviews that can move the rate either way. New importers can get their own rate only by requesting a shipping-review inquiry, and the pattern of these reviews is why importers sometimes abandon a supplier mid-case rather than carry the deposit exposure.
The newest wrinkle in the system is the 2025 expansion of findings enforcement: Commerce and CBP have publicized criminal referrals against importers that undervalued entries or misclassified goods to dodge AD/CVD deposits, and CBP reported over $700 million in new AD/CVD collections in a single quarter of fiscal 2025, per its trade reporting. Enforcement now reaches the importer's paperwork, not just the exporter's pricing.
How do cases end?
Three exits exist. The ITC votes no at either stage and the case dies. The parties negotiate a suspension agreement — a price or volume undertaking in place of duties, as happened in some sugar and tomato cases. Or the order stands until a sunset review; by law the ITC must review every order every five years and revoke it unless dumping and injury would likely resume. Orders on steel products from the 1990s still survive on that test, which is why the durable duty list is long.
What the record establishes is a fixed statutory clock with two agencies and real money at the provisional stage. What it cannot establish in advance is any margin: that is computed case by case from respondents' verified cost and price data.
For more context, read Trump Cuts Steel Tariffs To 25%.
For more context, read sustainable.
For more context, read The Importance of Sustainability in Agriculture.