Deadline For Scope Comments in AD/CVD Investigation of Linear Hydraulic Cylinders and Parts Thereof from Canada, China, India, Korea, And Mexico
On September 14, 2026, the Department of Commerce (“Commerce”) initiated an AD/CVD Investigation on certain Linear Hydraulic Cylinders (including certain cylinder parts) from Canada, China, India, the Republic of Korea, and Mexico. Linear Hydraulic Cylinders have many applications, notably in construction equipment (engineering vehicles), manufacturing machinery, elevators, and civil engineering. A hydraulic cylinder is a hydraulic actuator that provides linear motion when hydraulic energy is converted into mechanical movement. It can be likened to a muscle in that, when the hydraulic system of a machine is activated, the cylinder is responsible for providing the motion.
The scope of the investigation is very broad. It includes all cylinders produced in these five countries which are incorporated into machines classified in Chapter 84, HTSUS, regardless of the country in which the machine is produced. As such, the scope would include machines produced in non-subject countries such as Japan, EU, or United Kingdom, etc., if containing a covered cylinder. Thus, companies importing Ch 84 machines may be subject to substantial ADD/CVD liability, even if they do not currently know whether their imports incorporate a subject cylinder, the origin of that cylinder, or the cost of that cylinder. It is also unclear what combination of cylinder parts will be treated as subject merchandise. The scope of this proceeding has the potential to cover an expansive range of products.
Commerce has solicited comments on the scope of these investigations. These comments must be filed by September 28, 2026. In addition, if there is any possibility that imports contain subject cylinders or components thereof made in China, the exporter and/or producer may need to file a separate rate application with Commerce in the AD/CVD investigation regarding China.
If you have questions as to whether certain products are covered by the scope of the Investigation or would like to file comments with Commerce requesting revisions to the proposed scope, please contact one of our attorneys.
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Deadline For Scope Comments in AD/CVD Investigation of Linear Hydraulic Cylinders and Parts Thereof from Canada, China, India, Korea, And Mexico
On September 14, 2026, the Department of Commerce (“Commerce”) initiated an AD/CVD Investigation on certain Linear Hydraulic Cylinders (including certain cylinder parts) from Canada, China, India, the Republic of Korea, and Mexico. Linear Hydraulic Cylinders have many applications, notably in construction equipment (engineering vehicles), manufacturing machinery, elevators, and civil engineering. A hydraulic cylinder is a hydraulic actuator that provides linear motion when hydraulic energy is converted into mechanical movement. It can be likened to a muscle in that, when the hydraulic system of a machine is activated, the cylinder is responsible for providing the motion.
The scope of the investigation is very broad. It includes all cylinders produced in these five countries which are incorporated into machines classified in Chapter 84, HTSUS, regardless of the country in which the machine is produced. As such, the scope would include machines produced in non-subject countries such as Japan, EU, or United Kingdom, etc., if containing a covered cylinder. Thus, companies importing Ch 84 machines may be subject to substantial ADD/CVD liability, even if they do not currently know whether their imports incorporate a subject cylinder, the origin of that cylinder, or the cost of that cylinder. It is also unclear what combination of cylinder parts will be treated as subject merchandise. The scope of this proceeding has the potential to cover an expansive range of products.
Commerce has solicited comments on the scope of these investigations. These comments must be filed by September 28, 2026. In addition, if there is any possibility that imports contain subject cylinders or components thereof made in China, the exporter and/or producer may need to file a separate rate application with Commerce in the AD/CVD investigation regarding China.
If you have questions as to whether certain products are covered by the scope of the Investigation or would like to file comments with Commerce requesting revisions to the proposed scope, please contact one of our attorneys.
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