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Foil Tariff Preliminary Update: March 2023

Per a Federal Register notice published Mar. 22, 2023, the U.S. Department of Commerce preliminarily determines that imports of certain aluminum foil from the Republic of Korea and from the Kingdom of Thailand are circumventing duties.

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In November 2022, we reported on potential foil tariffs from the Department of Commerce (DOC) which could have supply chain continuity effects on the healthcare packaging community. [Editor's note: this is a report on a preliminary determination, presented without comment.] 


In December, the DOC extended its deadlines for circumvention inquiry as follows.

  • Preliminary determination: February 28, 2023
  • Final determination: July 18, 2023

However on February 27, 2023, the DOC further extended these dates to March 15, 2023, and August 2, 2023, for preliminary and final determination, respectively.

Preliminary affirmative determination

Per a notice by the International Trade Administration, “We preliminarily determine that aluminum foil, assembled or completed in Korea and Thailand by the entities identified in Appendix II to this notice, using Chinese-origin aluminum foil and/or sheet, that is subsequently exported from Korea or Thailand to the United States, is circumventing the Orders. For a detailed explanation of our determinations with respect to the entities identified in Appendix II, see the Preliminary Decision Memoranda and the “Use of Adverse Facts Available” section…”

For more detail, please visit the Federal Register Notice:

Antidumping and Countervailing Duty Orders on Certain Aluminum Foil From the People's Republic of China: Preliminary Affirmative Determinations of Circumvention With Respect to the Republic of Korea and the Kingdom of Thailand

From the Notice: Appendix II, Companies Found to Be Circumventing the Orders


1. Dong-IL Aluminium Co., Ltd.

2. Lotte Aluminium Co., Ltd.

3. Dongwon Systems Corp.


5. Korea Aluminium Co., Ltd.

6. Sam-A Aluminium Co., Ltd.


1. Dingheng New Materials Co., Ltd.

2. Ding Li New Materials Co., Ltd.

3. Sankyu Thai Co., Ltd. (based on adverse facts available)



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