Commerce Finds Chinese CGI Brake Drums Circumvent Duties

Introduction

The U.S. Department of Commerce has issued a preliminary affirmative determination in its circumvention inquiry into compacted graphite iron (CGI) brake drums from China. The notice was signed on September 17, 2026, and published in the Federal Register on September 22, the date it takes effect.

Commerce preliminarily finds that CGI brake drums are later-developed merchandise, a product that was not commercially available when the original investigation began but is otherwise the same as what the orders already cover, and that they belong inside the scope of the antidumping and countervailing duty orders on brake drums from China.

The finding is country-wide. It reaches every Chinese exporter of the inquiry merchandise, not one named company.

What the Determination Covers

The inquiry merchandise is CGI brake drums with an actual or nominal inside diameter of 14.75 inches or more but not over 16.6 inches, weighing more than 50 pounds, produced in China and exported to the United States. Commerce cites model M328D557, produced by PanAsia CVS (HK) Limited, as its example.

The Cash Deposit Rates Now in Effect

Commerce will direct U.S. Customs and Border Protection to suspend liquidation (to hold entries open rather than finalize the duty owed) on unliquidated entries of Chinese CGI brake drums entered, or withdrawn from warehouse for consumption, on or after January 27, 2026.

That is the publication date of the initiation notice, not the date of this determination. The look-back runs roughly eight months.

Cash deposits apply at the rates already established under the orders:

• AD cash deposit rate for the China-wide entity: 150.25%
• CVD cash deposit rate for all others: 11.94%
• Combined: 162.19%

The AD figure is worth a note. The China-wide dumping margin is 160.79%, but the cash deposit rate is lower because Commerce adjusts it downward to offset export subsidies already captured on the countervailing duty side. The 150.25% figure is what an importer actually posts.

Companies holding a company-specific rate under the orders pay that rate instead. That can cut either way: several Chinese producers carry an AD rate of 77.14%, while others carry a CVD rate of 446.83% assigned on adverse facts available. The rate that applies depends on the exporter and producer combination on the entry.

These requirements stay in effect until further notice.

Finishing the Drum Elsewhere Does Not Help

This is the part that catches importers out, and it predates the CGI question entirely.

The scope of the orders already reaches finished and unfinished Chinese brake drums that are further processed in a third country or in the United States, where that processing would not have removed the drum from scope had it been done in China. Machining a rough Chinese casting somewhere else does not change its origin. Neither does assembling it onto a hub.

Read alongside this week's determination, the pattern is consistent. Changing the iron did not move the drum outside the orders. Changing where the last operation happens does not either.

This Is Preliminary, and the Record Is Still Open

A preliminary determination is not the end of the proceeding. Interested parties can still contest the finding on the record, and Commerce can revise or reverse it.

Case briefs are due 14 days after publication, on or about October 6, 2026. Rebuttal briefs follow seven days later, on or about October 13. Any party wanting a hearing must request one within 30 days, on or about October 22.

Commerce will then issue a final determination. Its regulations set a 300-day target measured from the January 27 initiation, which points to late November 2026, though Commerce has already extended the preliminary deadline twice in this inquiry and can extend again. The notice does not state a final date.

Commerce will also notify the U.S. International Trade Commission. If the ITC believes the proposed inclusion raises a significant injury issue, it has 60 days from notification to provide written advice. A final determination can be challenged in court after it is issued.

What the preliminary status does not do is pause collection. Commerce is directing CBP to suspend liquidation and collect deposits on the strength of this preliminary determination, not the final one.

If the final determination affirms, that liability stands. If Commerce reverses, deposits come back, but that resolution is months out, and the cash is committed in the meantime.

What This Means for Sourcing From Vietnam

The argument for Chinese CGI drums was price. At a combined 162.19% cash deposit, that argument no longer works, and buyers who moved to CGI specifically to sit outside the orders now need a genuine alternative.

TBP Auto melts, casts, and machines heavy-duty brake drums at our own foundry in Hung Yen, Vietnam. Our drums are made under one roof in Vietnam, ship with a certificate of origin, and are outside the scope of the China and Türkiye orders and of this circumvention finding.