September 22 Trade News: Polysilicon Restrictions, Section 301 Refunds and AD/CVD Changes

Section 232: polysilicon stockpiling can trigger an importer-specific ban

CBP’s September 22, 4:27 p.m. EDT guidance explains how it will enforce Commerce’s new anti-stockpiling measures for polysilicon and its derivatives. The filed temporary final rule states an effective period of September 22–December 3, 2026, although Federal Register publication is scheduled for September 24. As of this issue, the rule is on public inspection; it is not a proposal. CSMS #69994928 · Filed rule, pp. 1–4.

Commerce will identify existing importers of record (IORs) whose volumes substantially exceed their historical averages, considering post-August 6 imports, earlier 2026 and 2025 averages, and affiliate activity. Once Commerce notifies CBP of a restriction, the affected IOR is barred from further covered entries before December 4. CBP says goods may move to a bonded warehouse, but consumption entry must wait until December 4 unless relief is granted. This is a company-specific restriction, not a blanket ban on every polysilicon shipment. Monitoring criteria · CBP entry and warehousing guidance.

IORs registered with CBP on or after August 6, 2026 face the following weekly ceilings unless Commerce approves a waiver. Exceeding them can trigger a bar on further entries. Brokers must examine IOR registration, same-week imports, beneficial ownership and the ultimate consignee; splitting transactions among multiple IORs to evade the limits is prohibited. Supplement No. 1, paragraphs (g)–(h) and Table 1.

A waiver application must be a PDF of no more than 30 pages including attachments, with a non-confidential public version where confidential material is submitted. The application window runs through December 3. Commerce targets a response within 14 days, and CBP implements approved relief prospectively after receiving Commerce’s notice. Application requirements and review process.

The implementation chain is Proclamation 11052 → Commerce’s temporary rule → CSMS #69994928. The proclamation’s separate minimum-import-price and tariff program starts December 4; the September 22 development addresses stockpiling before then. The temporary rule also removes the former steel and aluminum inclusions-process provisions, implementing the earlier termination of that process. Proclamation 11052, clauses 2, 4 and 11 · Regulatory changes.

Date check: CBP’s background line pairs 91 FR 51975 with August 6. August 6 is the proclamation’s signing date; the official Federal Register issue is dated August 11. CBP notice · Official published proclamation.

Section 301: ACE acceptance and refund instructions for four exclusions

CSMS #69990649, released September 22 at 3:26 p.m. EDT, supplies filing instructions for USTR’s September 2 conforming amendments to four existing China exclusions. The legal code changes apply from July 1, 2026; CBP schedules ACE acceptance for noon September 23, without specifying a time zone in the bulletin. The new development is the operational filing and refund path. CBP implementation guidance · USTR amendment, 91 FR 56538.

Qualifying goods use 9903.88.69 and the appropriate ordinary statistical code. CBP says not to submit the corresponding China Section 301 duty heading when claiming that exclusion heading. Eligibility still depends on the exclusion’s written product description; the code transition alone does not expand the covered products. Entry instructions · Exclusion descriptions.

For eligible entries from July 1 through September 22 on which the China Section 301 duty was paid, CBP directs importers to file a post-summary correction (PSC) on or after September 23, within the PSC filing window. Where that window has passed, a liquidation protest may be available within its own filing deadline. These are requests for refunds of eligible paid duties, not automatic refunds. Refund instructions.

Fatty acids: new deposits begin, with a limited retroactive reach

The Commerce Department’s September 22 notices put preliminary antidumping measures on certain fatty acids from Malaysia and Indonesia into operation. The determinations were signed September 15. They are investigation preliminaries that trigger deposits, not final duty orders—and not administrative-review preliminaries that merely propose future rates. Malaysia determination · Indonesia determination.

The deposit column reflects export-subsidy offsets while the companion countervailing-duty provisional measures apply. These are AD deposits, not an all-in tariff calculation. If those CVD provisional measures expire first, Commerce says it will instruct CBP to collect the unadjusted AD rates. The exporter/producer hierarchy in each notice also matters when a trading company exports goods made by a named producer. 91 FR 60092 · 91 FR 60096.

Check product specifications before assigning a case. The written scope contains chemical-composition thresholds, exclusions and rules for third-country processing and blends. It lists HTSUS codes including 2915.70.0110 and 3823.19.4000, but classification alone does not establish coverage. Commerce will issue a separate preliminary scope decision; today’s notices do not amend the initiation scope. Scope, Appendix I and scope-comments section.

Two circumvention preliminaries reach earlier entries

Cambodian garment hangers: input origin drives the case number

Commerce preliminarily finds, country-wide, that hangers completed in Cambodia using Chinese or Vietnamese steel wire, or steel wire plus paper accessories, circumvent the China AD order or the Vietnam AD/CVD orders. The September 22 notice directs suspension and deposits for covered unliquidated entries from August 12, 2025. This is not a general duty on every Cambodian product. 91 FR 60086.

The default treatment specified is 220.68% AD under A-555-812 and 31.58% CVD under C-555-813. Eligible parties documenting Chinese inputs may instead use the China-order AD treatment under A-555-918. That certification changes which order applies; it does not eliminate AD liability. No exporter is presently allowed to certify that its inputs came from neither China nor Vietnam. Alpha Hanger, Everbrit and Kaining cannot use the Chinese-input certification program. Deposit and certification provisions.

For covered earlier non-AD/CVD entries, including those whose liquidation is not yet final, the notice calls for post-summary corrections, conversion to the proper AD/CVD entry type and deposits. Its transitional certification/document-upload window is 45 days after publication—November 6, 2026, calculated from September 22. Use the notice’s separate producer/exporter forms and upload supporting records into ACE’s Document Image System; a simple country-of-export statement is insufficient. Appendix II and suspension instructions.

Chinese CGI brake drums: a material change does not avoid the orders

The preliminary finding covers compacted graphite iron (CGI) brake drums made in China with an inside diameter of 14.75–16.6 inches and weight over 50 pounds. Commerce treats them as later-developed merchandise circumventing the brake-drum orders, on a country-wide basis. It will suspend covered unliquidated entries from January 27, 2026 and require applicable deposits. The default rates cited are 150.25% AD and 11.94% CVD; companies with their own rates use those company-specific rates. The finding remains preliminary, but its entry consequences are not postponed until a final determination. 91 FR 60082.

Company-specific deposit changes and an effective-date correction

Italy: forged steel fluid end blocks

The final CVD review for calendar 2024 sets the following deposit rates for covered consumption entries or warehouse withdrawals from September 22, 2026. They are company-specific, not a uniform Italian rate. 91 FR 60084.

The notice identifies cross-owned companies for Lucchini and Metalcam. If both exporter and producer have different company-specific subsidy rates, the higher one applies; if only one has a rate, use that rate. The fallback for other producers/exporters is 3.52%. Historical 2024 assessment instructions are a separate step, to be issued no earlier than 35 days after publication and subject to applicable litigation protections. Cash-deposit and assessment instructions.

Vietnam: frozen fish fillets

A court-related amendment published September 22, applicable September 14, raises the 2021–2022 review margin from $0.18/kg to $0.20/kg for CASEAMEX and four separate-rate companies. Commerce will revise current deposits to $0.20/kg for Cafatex, Hung Vuong, International Development and Investment Corporation (IDI), and Loc Kim Chi. CASEAMEX’s later review already superseded its deposit rate, so this amendment changes its historical result—not its present deposit. Entries in the litigated August 1, 2021–July 31, 2022 period remain subject to the court injunction during appeals. 91 FR 60099.

Oman: OCTAL’s 3.02% rate uses May 18, not September 2

Today’s correction changes the effective-date language in the September 2 PET-resin amended final results. The corrected reference is the publication date of the original final results, May 18, 2026, rather than the amended-results date. OCTAL’s 3.02% figure is not newly increased today; the operational change is which entries the amended deposit requirement covers. Review affected entries from May 18 onward against the corrected instructions. September 22 correction · September 2 amended rate · May 18 final results.

CBP publishes HSU 2622 for honey assessments and beef quota records

At 10:52 a.m. EDT on September 22, CBP published CSMS #69990151. HSU 2622 contains 16 tariff records and 93 ABI records for USDA Honey Board assessment changes and the Affordable Beef Quota HTS updates. CBP says the update was created August 31; today is the bulletin’s release date, not the creation date or a newly announced quota-opening date. CSMS #69990151.

For brokers, the new public implementation notice is a reason to reconcile the affected tariff/assessment records with the filing-software provider. It does not by itself announce a new tariff rate, enlarge the beef quota again, or establish a fresh honey-assessment effective date. Its beef reference is CAMS #69709647. Use the underlying program instructions for eligibility and entry timing, rather than substituting the HSU publication date. CSMS #69990151.

Softwood lumber: nominal-versus-net assessment calculations become explicit

USDA’s final rule, published September 22 and effective October 22, 2026, expressly distinguishes nominal lumber dimensions from the smaller actual dimensions after processing. This is a research-and-promotion assessment rule, not a Section 232 tariff action. 91 FR 59981.

The rule also specifies nominal volume for reporting and the first 15 million board feet assessment exemption. Importers should obtain the supplier’s measurement basis and use the corresponding published conversion and unit rate. Mixing a net-volume quantity with the nominal-volume charge can understate the assessment. The two rows are alternative measurement bases, not charges to add together. Revised 7 CFR 1217.52–.53 and reporting provisions.

Two procedural notices change the next decision point

Canadian large-diameter welded pipe: Commerce preliminarily finds Interpro Pipe & Steel Inc. is the successor to Evraz Inc. NA Canada. If confirmed in final results, Interpro would receive Evraz’s deposit treatment from publication of those final results. Today’s preliminary successor finding does not authorize filers to switch the rate now. Case briefs are due 14 days after the September 22 publication. 91 FR 60095.

Linear hydraulic cylinders from Canada, China, India, South Korea and Mexico: the corrected initiation notice measures the ITC’s 25-day preliminary-injury period from the date the ITC receives Commerce’s initiation notice—not from the petition filing date. This corrects the procedural clock; it does not impose deposits or amend product coverage. 91 FR 60091.

Cross-border policy: China licensing, EU–Philippines talks and Greenland investment

Two additional chemical precursors require Chinese export licenses

China’s five-agency Announcement 40/2026, issued September 22, adds methyl and ethyl 1-phenethyl-4-oxopiperidine-3-carboxylate to the list requiring export licenses for shipments to the United States, Mexico and Canada, effective upon publication. Appendix 1 includes their possible salts and gives Chinese commodity number 2933399075 as a declaration reference; chemical names control. This is Chinese export licensing, not a U.S. HTSUS classification or import ban. Confirm the supplier’s authorization before dispatch. Official announcement and Appendix 1.

EU–Philippines: a political agreement, not entry into force

On September 22, the European Commission announced substantial agreement on an FTA intended to liberalize over 94% of tariff lines, covering more than 97% of bilateral trade. Negotiators still must finalize technical details and implementation. The milestone supports supply-chain planning, but does not yet permit a new preferential-duty claim. Await the concluded text and implementation timetable before pricing shipments on the proposed preferences. Commission release · Joint statement.

Greenland agreement: investment screening and defense procurement

The United States, Denmark and Greenland signed a defense agreement in New York on September 22 with commercial consequences. Article X restricts states and investors from countries outside NATO, NATO partnerships and the EU from obtaining control, significant influence, or access to non-public information that may threaten national security or public order in particularly sensitive sectors, including critical infrastructure and resource extraction, unless the parties agree the activity poses no such threat. Implementation is through Greenland’s current or future investment-screening laws. Agreement, Articles III and X.

Article IV directs U.S. defense-area goods and services contracts toward Greenlandic sources to the maximum feasible extent, considering capability. Signature is not entry into force: Article XII requires a diplomatic note confirming completion of the necessary Danish and Greenlandic parliamentary procedures. Businesses should distinguish those treaty commitments from an immediately effective general import ban. Articles IV and XII.

Today’s working list and specific follow-ups

Editorial checklist based on the notices above; verify shipment-specific treatment with the responsible broker or counsel.

• For polysilicon, check the IOR registration date, this week’s entries and related-party ownership before booking further shipments; assemble volume evidence for any waiver application. BIS requirements.
• For the four Section 301 exclusions, reconcile eligible July 1–September 22 entries and the available PSC or protest window, then confirm ACE acceptance before submission. CBP instructions.
• Separate company identity, input origin, product specifications and entry date in the affected AD/CVD review. Do not apply a country-wide shortcut to a company-specific notice. 91 FR 60096 · 91 FR 60084.
• For Cambodian hangers, retrieve purchase, production and origin records before preparing certifications and post-summary corrections. Track the transitional 45-day deadline. 91 FR 60086.
• Reconcile honey and beef tariff records with the ABI provider; do not treat a newly released HSU as proof that its underlying legal measure began today. CSMS #69990151.
• Prepare the lumber quantity-conversion change for October 22, and verify export-license coverage on affected China-origin chemical orders before dispatch. 91 FR 59981 · MOFCOM Announcement 40/2026.

Near-term implementation: ACE acceptance is scheduled for noon September 23; the polysilicon rule is scheduled for Federal Register publication September 24. Greenland’s entry-into-force diplomatic note remains a separate legal step. CBP · BIS filed text · Agreement Article XII.

Next documents to watch: Commerce’s separate fatty-acid scope decision and final determinations; the final Interpro successor decision; and the completed EU–Philippines text and implementation arrangements. These are the next legal steps tied to today’s developments—not assumed outcomes. 91 FR 60092 · 91 FR 60096 · 91 FR 60095 · European Commission IP/26/1929.

Questions importers are likely to ask

Sources and publication dates

1. CBP polysilicon import-restriction guidance — September 22, 2026.
2. Commerce temporary final rule, public-inspection text — filed September 22; publication scheduled September 24, 2026.
3. Proclamation 11052: underlying authority — signed August 6; published August 11, 2026.
4. CBP Section 301 filing and refund guidance — September 22, 2026.
5. USTR conforming amendments underlying CBP instructions — September 2, 2026.
6. U.S.–Denmark–Greenland agreement — signed and released September 22, 2026.
7. Malaysia fatty acids, preliminary AD determination — September 22, 2026.
8. Indonesia fatty acids, preliminary AD and critical-circumstances findings — September 22, 2026.
9. Cambodian hanger circumvention and certification requirements — September 22, 2026.
10. Chinese CGI brake drums, preliminary circumvention finding — September 22, 2026.
11. Italy fluid end blocks, final CVD review — September 22, 2026.
12. Vietnam frozen fish fillets, court-related amendment — September 22, 2026.
13. Oman PET resin, effective-date correction — September 22, 2026.
14. Canada large-diameter welded pipe, preliminary successor review — September 22, 2026.
15. Linear hydraulic cylinders, ITC-clock correction — September 22, 2026.
16. CBP HSU 2622 — September 22, 2026.
17. USDA softwood lumber assessment final rule — September 22, 2026.
18. China chemical-precursor export licensing — September 22, 2026.
19. EU–Philippines substantial agreement — September 22, 2026.
20. EU–Philippines joint statement — September 22, 2026.
21. Supporting history for the Oman correction: amended results, September 2, 2026 and original final results, May 18, 2026.