US–China Trade Daily Hightlights | 2026-09-25

1) Executive Summary

– Today’s brief covers 6 events involving the U.S. International Trade Commission (ITC), the U.S. Department of Commerce’s International Trade Administration (DOC/ITA), and the Department of the Treasury’s Office of Foreign Assets Control (OFAC). Actions span Section 337 investigations, antidumping/countervailing duty reviews, and sanctions regulations updates. The ITC instituted a Section 337 investigation on DRAM devices and moved PVLT tire orders into full five-year reviews. DOC/ITA issued final results in AD administrative reviews for welded pipe (Türkiye) and superabsorbent polymers (Korea). OFAC created consolidated penalties regulations and updated terrorism list government regulations following the Syria rescission.

2) Updates by Authority

ITC (U.S. International Trade Commission)

– Headline (one line, bold):
DRAM devices (DDR5 DIMMs) — ITC Section 337 (Institution of Investigation)

Summary (2–3 sentences):
The ITC instituted a Section 337 investigation based on a complaint by Netlist, Inc. alleging infringement of certain claims of U.S. Patent Nos. 10,025,731; 10,217,523; 12,373,366; and 12,675,407 involving certain DRAM devices (specifically DDR5 generation DIMMs), products containing the same, and components thereof. The investigation will determine whether violations exist under 19 U.S.C. 1337(a)(1)(B) and whether a domestic industry exists or is in the process of being established. Netlist seeks a limited exclusion order and cease and desist orders.

Key Details (bullets):

  • – Authority: INTERNATIONAL TRADE COMMISSION
  • – Policy Type: ITC_337
  • – Event Type: TRADE_REMEDY
  • – Investigation No.: 337-TA-1523
  • – Scope description: “certain DRAM devices (specifically, DDR5 generation DIMM), and products containing the same (such as servers, computing systems, and storage systems), and components thereof”
  • – Complainant: Netlist, Inc., Irvine, CA
  • – Named respondents: Micron Technology, Inc.; Micron Semiconductor Products, Inc.; Hewlett Packard Enterprise Co.; Lenovo Group Ltd.; Lenovo (United States) Inc.; Super Micro Computer, Inc.
  • – Commission vote/order: September 22, 2026; Notice issued: September 23, 2026
  • – Response deadline: Within 20 days of service, per 19 CFR 210.13
  • – Requested remedies: Limited exclusion order; cease and desist orders

Source:
– Link: https://lawyerfanzhang.com/certain-dynamic-random-access-memory-dram-devices-products-containing-the-same-and-components-thereof-iii-notice-of-institution-of-investigation/

– Headline (one line, bold):
Passenger vehicle & light truck tires — AD/CVD Five-Year Reviews (Full Reviews)

Summary (2–3 sentences):
The ITC determined it will conduct full five-year reviews of the countervailing duty order on PVLT tires from Vietnam and the antidumping duty orders on PVLT tires from South Korea, Taiwan, and Thailand. The Commission found adequate responses from parties for South Korea, Thailand, and Vietnam and is also conducting a full review for Taiwan to promote administrative efficiency. A schedule for the reviews will be announced later.

Key Details (bullets):

  • – Authority: INTERNATIONAL TRADE COMMISSION
  • – Policy Type: AD_CVD
  • – Event Type: TRADE_REMEDY
  • – Investigation Nos.: 701-TA-647 and 731-TA-1517-1519 (Review)
  • – Determination date: September 4, 2026
  • – Countries/Orders: Vietnam (CVD); South Korea, Taiwan, Thailand (AD)

Source:
– Link: https://lawyerfanzhang.com/passenger-vehicle-and-light-truck-tires-from-south-korea-taiwan-thailand-and-vietnam-notice-of-commission-determination-to-conduct-full-five-year-reviews/

DOC (U.S. Department of Commerce, International Trade Administration)

– Headline (one line, bold):
Large diameter welded pipe (Türkiye) — Antidumping (Final Results, Admin Review 2024–2025)

Summary (2–3 sentences):
Commerce finalized its review and determined that subject welded pipe from Türkiye was sold in the United States at less than normal value during May 1, 2024–April 30, 2025. The final results are unchanged from the preliminary results. Assessment instructions will issue no earlier than 35 days after publication.

Key Details (bullets):

  • – Authority: DEPARTMENT OF COMMERCE, International Trade Administration
  • – Policy Type: AD_CVD
  • – Event Type: TRADE_REMEDY
  • – Case No.: A-489-833
  • – POR: May 1, 2024–April 30, 2025
  • – Final weighted-average dumping margins: HDM Celik Boru Sanayi Ve Ticaret A.S. — 1.89%; Cimtas Boru Imalatiral Ticaret Ltd — 1.89%
  • – Applicable date: September 25, 2026
  • – Commerce official: Dated September 21, 2026

Source:
– Link: https://lawyerfanzhang.com/large-diameter-welded-pipe-from-the-republic-of-turkiye-final-results-of-antidumping-duty-administrative-review-2024-2025/

– Headline (one line, bold):
Superabsorbent polymers (Korea) — Antidumping (Final Results, Admin Review 2023–2024)

Summary (2–3 sentences):
Commerce finalized its review and determined that certain superabsorbent polymers from Korea were not sold at less than normal value during December 1, 2023–November 30, 2024. The final results are unchanged from the preliminary results, with a zero percent margin for LG Chem, Ltd. Entries will be liquidated without regard to antidumping duties, and LG Chem’s cash deposit rate will be zero.

Key Details (bullets):

  • – Authority: DEPARTMENT OF COMMERCE, International Trade Administration
  • – Policy Type: AD_CVD
  • – Event Type: TRADE_REMEDY
  • – Case No.: A-580-914
  • – POR: December 1, 2023–November 30, 2024
  • – Final weighted-average dumping margin: LG Chem, Ltd. — 0.00%
  • – Applicable date: September 25, 2026
  • – Commerce official: Dated September 21, 2026

Source:
– Link: https://lawyerfanzhang.com/certain-superabsorbent-polymers-from-the-republic-of-korea-final-results-of-antidumping-duty-administrative-review-2023-2024/

OFAC (Office of Foreign Assets Control)

– Headline (one line, bold):
Sanctions Penalties Regulations — Procedural Rule (Final Rule, 31 CFR Part 505)

Summary (2–3 sentences):
OFAC issued the Sanctions Penalties Regulations, consolidating previously existing information on civil penalties and enforcement procedures applicable to multiple sanctions programs. The rule reproduces penalty and process information under IEEPA and the UNPA without substantive changes and standardizes references across 31 CFR chapter V. The rule is effective September 25, 2026.

Key Details (bullets):

  • – Authority: DEPARTMENT OF THE TREASURY, Office of Foreign Assets Control
  • – Policy Type: PROCEDURAL_NOTICE
  • – Event Type: SANCTIONS
  • – Citation: 31 CFR Part 505
  • – Effective date: September 25, 2026
  • – Noted penalty framework: IEEPA civil monetary penalties up to the greater of $377,700 or twice the value of the transaction; process includes pre-penalty notice, penalty notice, and findings of violation

Source:
– Link: https://lawyerfanzhang.com/sanctions-penalties-regulations/

– Headline (one line, bold):
Terrorism List Governments Sanctions Regulations — Amendment (Syria GL Removal)

Summary (2–3 sentences):
OFAC amended the Terrorism List Governments Sanctions Regulations to remove and reserve a Syria-specific general license at 31 CFR 596.505 following the rescission of Syria’s designation as a State Sponsor of Terrorism effective August 24, 2026. With the rescission, the Government of Syria is no longer a “Terrorism List Government” for purposes of these regulations. The amendment is effective September 25, 2026.

Key Details (bullets):

  • – Authority: DEPARTMENT OF THE TREASURY, Office of Foreign Assets Control
  • – Policy Type: SANCTIONS_LISTING
  • – Event Type: SANCTIONS
  • – Citation: 31 CFR Part 596; Section 596.505 removed and reserved
  • – Effective date: September 25, 2026
  • – Background dates: Presidential report July 8, 2026; rescission effective August 24, 2026; notice at 91 FR 55965 (August 31, 2026)

Source:
– Link: https://lawyerfanzhang.com/terrorism-list-governments-sanctions-regulations/

3) Key Takeaways (Factual)

  • ITC instituted a Section 337 investigation into certain DDR5 DRAM devices and related products based on Netlist’s patent infringement complaint, naming multiple U.S. and international respondents.
  • The Commission opted for full five-year reviews of PVLT tire AD/CVD orders for South Korea, Taiwan, Thailand, and Vietnam; a review schedule will follow.
  • Commerce’s final AD review results set a 1.89% dumping margin for two Turkish welded pipe producers and a zero percent margin for LG Chem on Korean superabsorbent polymers.
  • OFAC consolidated penalties and enforcement procedures into new Sanctions Penalties Regulations (31 CFR part 505) without substantive changes.
  • OFAC updated the Terrorism List Governments regulations by removing a Syria-specific general license following the August 2026 rescission of Syria’s State Sponsor of Terrorism designation.

4) Full Source Links (Index)

5) Legal Disclaimer

This article includes content collected and summarized from publicly available U.S. government materials, including the Federal Register (federalregister.gov). The content presented is not an official government publication and does not represent the views of any U.S. government authority.
This article is provided for informational and research purposes only and does not constitute legal advice, compliance advice, or recommendations for any specific entity or transaction. Readers should refer to the original official documents and consult qualified professionals before making decisions based on this information.