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U.S. Aluminum Foil Trade Enforcement Concerns

The Aluminum Association openly supports new actions by the U.S. Department of Commerce to strengthen U.S. aluminum foil trade enforcement against Chinese-origin foil routed through Thailand and South Korea. The group notes that these shipments attempt to dodge antidumping and countervailing duties (AD/CVD) imposed in April 2018 on unfairly traded aluminum foil from China.

Association President and CEO Charles Johnson praises Commerce for taking concrete steps to uphold U.S. trade laws. He also says the Association plans to cooperate closely with the department as the anti‑circumvention investigations move forward.

How U.S. Aluminum Foil Trade Enforcement Will Proceed

The Department of Commerce will send questionnaires to companies suspected of evading duties and invite other interested parties to submit data and written comments. After reviewing that information, Commerce will issue a preliminary determination, which should arrive within several months.

Overall, the agency expects the full investigation to take about one year before it publishes final decisions. This timeline reflects standard practice for complex trade enforcement cases.

Aluminum Foil Products Under Review

The current inquiry targets a specific category of flat‑rolled aluminum foil that:

  • Has a thickness of 0.2 mm or less

  • Ships in reels weighing more than 25 pounds

  • Is produced in China but finished in Thailand or South Korea before entering the U.S. market

Manufacturers use this foil in a wide range of applications, including packaging, insulation, household products, electronics, and cables. Therefore, any successful effort to bypass duties could impact a broad downstream supply chain.

Existing Duties and Shifts in Trade Flows

In 2018, Commerce set combined antidumping and countervailing duty rates ranging from roughly 55% to 176% on certain aluminum foil from China. Following those orders, direct U.S. imports of the covered foil from China declined significantly.

At the same time, imports of similar foil and sheet‑gauge products from Thailand and South Korea increased. Current U.S. aluminum foil trade enforcement inquiries aim to determine whether exporters now re‑route Chinese‑origin foil through these countries to sidestep the existing U.S. duties.

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