Legal & enforcement
U.S. sets preliminary AD rates on Indian graphite electrodes
Commerce preliminarily found that large diameter graphite electrodes from India are sold, or likely to be sold, in the U.S. at less than fair value and that critical circumstances exist for all producers and exporters. Margins are 12.22% for Graphite India Limited (GIL), 4.97% for HEG Limited (HEG) and 6.95% for all others; after export subsidy offsets, cash deposits are 9.88%, 1.15% and 3.53%. The notice is applicable September 30, 2026; the period of investigation is January 1 through December 31, 2025.
What changed
Critical circumstances cover GIL, HEG and all other producers and exporters, so suspension of liquidation reaches unliquidated entries made on or after the date 90 days before publication. If the exporter is not a listed respondent but the producer is, the producer's rate applies.
Deposits are offset for export subsidies found in the companion CVD investigation, whose preliminary determination was published July 30, 2026; if CVD provisional measures expire first, CBP collects the unadjusted margins.
The scope, preliminarily revised since initiation, covers furnace electrodes over 425 mm (16.7 inches) in diameter and pins of at least 228.6 mm (9 inches), with origin set by the country of graphitization; goods under the AD order on small diameter graphite electrodes from China and certain thermal energy storage graphite blocks, anchors and pins are excluded.
HTSUS 8545.11.0020 is the main number (also 3801.10.5090 or 3801.90.0050), but the written scope controls.
At the request of the petitioners, Resonac Graphite America Inc. and Tokai Carbon GE LLC, and of HEG, Commerce postponed the final determination to no later than 135 days after publication and extended provisional measures to up to six months. Case briefs are due seven days after the last verification report.
What an import team should check
- Match the producer and exporter on each invoice to Graphite India Limited, HEG Limited or the all-others rate; if the exporter is not a respondent but the producer is, the producer's rate applies.
- List unliquidated Indian graphite electrode entries made in the 90 days before September 30, 2026 and ask your customs broker how the retroactive suspension of liquidation applies to them.
- Follow the companion CVD case: deposits here are offset for export subsidies, and if CVD provisional measures expire first, CBP collects the unadjusted 12.22%, 4.97% or 6.95%.
- Compare diameter, pin size and country of graphitization with the written scope, and diary the final determination, due no later than 135 days after September 30, 2026.