Legal & enforcement
U.S. sets preliminary AD rate on Chinese graphite electrodes
Commerce preliminarily found that large diameter graphite electrodes (LDGE) from China are sold, or likely to be sold, in the U.S. at less than fair value and that critical circumstances exist for the China-wide entity. No Chinese company qualified for a separate rate, so all exporters fall under the China-wide entity: a 98.79% margin, based on adverse facts available, and a 95.61% cash deposit rate from September 30, 2026. The period of investigation is July 1 through December 31, 2025.
What changed
The revised scope covers graphite electrodes of a kind used in furnaces, finished or not, with a nominal or actual diameter over 425 mm (16.7 inches), plus graphite pin joining systems (pins or nipples) at least 228.6 mm (9 inches) in diameter; origin is the country of graphitization.
Electrodes covered by the existing AD order on small diameter graphite electrodes from China and certain thermal energy storage (TES) graphite blocks, anchors and pins are excluded. The main HTSUS number is 8545.11.0020, and goods may also enter under 3801.10.5090 or 3801.90.0050, but the written scope controls.
Because of critical circumstances, suspension of liquidation also reaches unliquidated entries made on or after the date 90 days before publication.
The 95.61% deposit is offset for subsidies found in the companion CVD case; if CVD provisional measures expire first, CBP collects the unadjusted 98.79%. No verification will be conducted.
Case briefs are due 14 days after publication and hearing requests within 30 days; the final determination is due within 75 days of the September 22, 2026 signature.
What an import team should check
- Check the producer and exporter on each invoice: no Chinese company earned a separate rate, and a third-country exporter takes the rate of the China-wide entity that supplied it.
- List unliquidated graphite electrode entries from China made in the 90 days before September 30, 2026 and ask your customs broker how the retroactive suspension of liquidation applies to them.
- Compare diameter, product type (pin, finished or unfinished electrode) and country of graphitization with the revised scope and its exclusions, and diary the final determination due within 75 days of September 22, 2026.