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.]
Timeline
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…”
