U.S. Commerce Department Opens Inquiry on Aluminum Containers from UAE Using Chinese Foil
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On February 10, 2026, the U.S. Department of Commerce announced the start of a circumvention inquiry. This action examines if aluminum containers imported from the United Arab Emirates (UAE) are avoiding duties on similar Chinese goods.
The decision came after a request from the Aluminum Foil Containers Manufacturers Association (AFCMA) and eight of its members. These companies are: Durable Packaging International, D&W Fine Pack, LLC, Handi-foil Corp., Penny Plate, LLC, Reynolds Consumer Products, LLC, Shah Foil Products, Inc., Smart USA, Inc., and Trinidad/Benham Corp.
The companies asked Commerce to review whether aluminum containers made in the UAE use aluminum foil made in China. If so, these items may fall under existing antidumping (AD) and countervailing duty (CVD) orders.
Commerce is using section 781(b) of the Tariff Act of 1930 and 19 CFR 351.226 in this process. The target products include disposable aluminum containers, pans, trays, and lids. These are made mostly from flat-rolled aluminum and include both smooth and wrinkled types.
On January 6, 2026, the requesters filed their formal inquiry request. Commerce then asked for more information on January 20 and 27. The requesters submitted responses on January 21 and 28.
On January 26, Kari-Out LLC, an importer, submitted arguments against the inquiry. The original group replied on January 28 with rebuttal comments.
Commerce is now investigating whether:
- (A) The products sent to the U.S. are the same type as those already under orders on Chinese aluminum;
- (B) They are assembled in the UAE using foil from China;
- (C) That assembling step is minor or insignificant;
- (D) The Chinese foil makes up a large part of the product’s total value;
- (E) A ruling is needed to stop unfair trade.
In this process, the agency will also look at:
- How much UAE firms invested in production;
- The nature of the UAE production steps;
- How much of the total value is from UAE processing;
- Production setup and research levels in the UAE;
- Trade patterns and any increases in Chinese exports to the UAE during the investigation.
Because the requesters gave enough evidence, Commerce is opening a country-wide inquiry. This means the review covers all UAE firms sending these goods to the United States. Commerce has done this in past reviews when there was concern about broad activity.
Commerce will collect information from UAE companies. It will use U.S. Customs and Border Protection (CBP) data to choose which companies to contact. CBP data will be posted on the ACCESS website, and public comments on this data must be submitted within seven days of release.
If a company does not respond fully, Commerce may apply facts available, which can include using adverse inferences.
For now, Commerce is instructing CBP to continue suspension of liquidation on affected entries. This applies to entries that are already subject to suspension under the original orders. Should Commerce reach a preliminary or final finding of circumvention, it may expand suspension rules to cover additional entries and require cash deposits.
This process does not stop CBP from taking other enforcement steps under current rules.
Commerce expects to announce a preliminary decision within 150 days of this notice. A final decision is due within 300 days unless extended or canceled.
This action is officially listed under Federal Register No. 2026-02642. It remains in line with section 781(b) of the Act and 19 CFR 351.226.
For more details, contact Justin Enck at (202) 482-1614 or Shawn Gregor at (202) 482-3226.
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