U.S. Revokes Aluminum Sheet Duties for Can Stock in Part – What Aluminum Part Buyers Should Re-Verify on Scope and Liquidation

On September 24, 2026, the U.S. Department of Commerce published the final results of changed circumstances reviews and revoked, in part, the antidumping (AD) and countervailing duty (CVD) orders on common alloy aluminum sheet from China and 17 other countries, covering certain aluminum can stock. The notice is 91 FR 60591 (Doc 2026-19516), signed September 18, 2026, applicable September 24, 2026.

At first glance this reads like a narrow packaging-materials story. It is not: common alloy aluminum sheet is the feedstock behind a large share of machined and formed aluminum parts, and the way Commerce changed the scope – clarifying written language rather than adding or removing a product – carries a lesson for any buyer who relies on an HTSUS code to decide whether a purchase is inside a duty order.

What Commerce Actually Decided

This is a changed circumstances review (CCR), not an annual administrative review. Petitioners – the Aluminum Association’s Common Alloy Aluminum Sheet Trade Enforcement Working Group, joined by Jupiter Aluminum Corporation – asked Commerce to clarify that can stock meeting a written description has always been outside the orders, regardless of classification. The China orders are docketed A-570-073 (AD) and C-570-074 (CVD). Commerce issued preliminary results on August 11, 2026 (91 FR 51666, Doc 2026-16358), found the requesters represent over 85 percent of the domestic industry, received no opposing comments, and finalized the position unchanged.

• The old exclusion named can stock suitable for beverage cans, lids or tabs, produced to gauges of 0.200 mm to 0.292 mm, with an H-19, H-41, H-48 or H-391 temper, lubricated on the flat surfaces, generally classifiable under HTSUS 7606.12.3045 and 7606.12.3055.
• The revised exclusion adds temper H-39 to that list. Commerce described this as a scope clarification and noted H-39 should also have appeared in the earlier order language.
• The classification caveat is new. The revised text says can stock is “generally classifiable” under those HTSUS subheadings, but that “the written description … is dispositive, regardless of HTSUS classification.”
• Retroactive application. Commerce applied the final results to all unliquidated entries of aluminum can stock, retroactive to when suspension of liquidation began – April 23, 2018 and June 22, 2018 for the China CVD and AD orders, and August 14, 2020 and October 15, 2020 for the Bahrain et al. orders.
• Refunds. Commerce will instruct U.S. Customs and Border Protection (CBP) to liquidate those entries without regard to AD/CVD and to refund estimated AD/CVD duties already deposited.
• Shortened timeline. Commerce intends to issue CBP instructions within 15 days of publication, explicitly shorter than the usual 35-day window, citing broad domestic-industry support and no opposition.

Why “Scope Clarification” Is the Real Story

Commerce did not add a product, remove one, or change a rate. It changed the words that define the boundary – and declared those words, not the tariff code, control. That reverses the assumption many purchasing teams use when screening a supplier’s classification. HTSUS codes are administrative buckets; a scope order is a legal description, and when the two disagree, this notice says the description wins.

Where This Touches Machined and Formed Aluminum Parts

Aluminum can stock is a specific, thin-gauge product: 0.200 mm to 0.292 mm, heavily rolled, lubricated, and sold for high-speed can, lid and tab lines – not the stock most CNC shops buy, so the exemption’s direct reach is narrow.

The indirect reach is broader. Common alloy aluminum sheet in the 1xxx, 3xxx, 5xxx and 6xxx families is the parent material for many machined and fabricated parts – heat sinks, brackets, enclosures, panels, jigs, fixtures and thin-wall housings. Some end uses sit close enough to the can stock definition that a buyer or broker could confuse the two on a specification, especially when thickness, temper and lubricant condition are recorded loosely on a purchase order.

That ambiguity is the risk. If a supplier ships material that arguably meets a written scope exclusion and arguably does not, the buyer carries the duty question – and the retroactive-refund question – on their own entries.

What Buyers Should Re-Verify

None of the following is legal advice, and duty treatment depends on the merchandise, the entry documentation and current CBP guidance. These are practical checks a team can run:

• Stop treating the HTSUS code as the answer. For any aluminum sheet or coil purchase, confirm whether the material matches a written scope description or exclusion, not just whether a tariff code looks right.
• Record the physical spec precisely. Thickness in millimetres, temper designation, whether a forming lubricant is present, and the intended end use should appear on the PO and the mill certification. Vague entries like “aluminum sheet, 0.25 mm” cannot be tested against a scope that turns on gauge, temper and lubricant.
• Check whether your entries are still unliquidated. The refund applies only to unliquidated entries. If a broker already liquidated the entry, that refund path may be closed, making protest and post-entry timing critical.
• Reconcile with your customs broker. Ask the broker to confirm, for each affected HTSUS line, whether any AD/CVD case applies and what the cash deposit status is – in writing and dated.
• Trace the actual origin. The orders here span China plus Bahrain, Brazil, Croatia, Egypt, Germany, India, Indonesia, Italy, Oman, Romania, Serbia, Slovenia, South Africa, Spain, Taiwan and Türkiye. Country of origin, not the distributor’s location, drives which order applies – if any.
• Separate engineering from duty questions. Whether a 0.25 mm temper H-39 sheet suits a formed bracket is a manufacturability decision; whether it is inside a duty order is a customs one. Document them separately.

How This Fits Material Selection and Manufacturability

From a shop-floor view the tempers named in this scope are not interchangeable. H-19, H-41, H-48, H-39 and H-391 reflect different strain-hardening and stabilization histories and behave differently under bending, spinning and forming – and again under machining. A hardened temper that forms cleanly in a can line can be hard to bend tightly without cracking, while a softer temper that bends easily may not hold the stiffness a bracket needs.

That is why a written material specification belongs on the drawing before the duty question is asked. If your drawing names “aluminum sheet” and a temper only in a footnote, you have neither a reliable manufacturing input nor a reliable customs input. Whether a given temper or gauge suits a specific part depends on material, thickness, geometry, drawing quality and inspection requirements.

The same applies downstream. Anodizing and other surface treatments respond to alloy and temper, so a substitution made quietly to manage duty exposure can change appearance, corrosion performance and dimensional behaviour. When sourcing changes for commercial reasons, the engineering record should change with it.

What This Does Not Say

Commerce did not revoke the aluminum sheet orders broadly. It revoked them in part, for a defined category of can stock. Duties continue to apply to aluminum sheet outside that exclusion, no rates changed, and no products entered or left the orders apart from the revised exclusion language and the added H-39 temper. Commerce also did not rule on any individual importer’s entries.

Conclusion

The September 24, 2026 notice is narrow in product terms and significant in method. It confirms that a duty order’s boundary is defined by written scope language, that this language can be revised years after the fact, that the revision can reach back to unliquidated entries, and that the tariff code is not the final word. For buyers of machined and formed aluminum parts, the takeaway is to tighten the paper trail – precise specs, documented origin, written broker confirmations, and awareness of where each entry sits in the liquidation cycle. That is what makes a retroactive refund claimable rather than lost.

Need a manufacturability review before you commit a material specification? Send your drawing, the intended material and temper, the quantity, supplier country, and the critical tolerances to our engineering team for a DFM and RFQ assessment, and we will flag where material, geometry and inspection requirements must line up before production. For guidance on preparing parts for quotation, see our DFM guidelines, our reference on tolerance selection, and our notes on surface finish.

Sources: U.S. Department of Commerce, Enforcement and Compliance, ITA. Final Results of Changed Circumstances Reviews and Revocation of the Antidumping and Countervailing Duty Orders, in Part, 91 FR 60591 (September 24, 2026), Doc 2026-19516, federalregister.gov. Initiation and Preliminary Results, 91 FR 51666 (August 11, 2026), Doc 2026-16358, federalregister.gov. Retrieved September 25, 2026.