Tariff Notices · Tariffs · confirmed

Commerce opens spray-foam scope and Canada circumvention inquiries

Updated · Impact score 74/100 · Confidence 55%

Commerce is examining whether the ester-containing side of Chinese spray-foam systems falls within existing alkyl-phosphate-ester AD/CVD orders and whether Canadian systems assembled with Chinese-origin esters circumvent those orders. No affirmative circumvention finding has been made.

Why it matters

Covered unliquidated entries can face suspension and cash-deposit consequences if Commerce reaches affirmative scope or circumvention determinations. The Canada inquiry is country-wide and focuses on the ester-containing “B” side of spray-foam systems completed or assembled in Canada with Chinese-origin esters.

What to check next

Trace ester origin and Canadian processing for spray-foam systems, preserve entry and component records, review already-unliquidated entries with your broker, and monitor the A-570-168 and C-570-169 inquiry records before assuming Canadian assembly removes AD/CVD exposure.

Affected entities

  • China -> US
  • Canada -> US
  • Commerce
  • CBP
  • Spray-foam systems
  • Alkyl phosphate esters
  • AD/CVD scope and circumvention

Primary sources