New Petitions Put Chinese Wooden Fence Pickets at Risk of Duties Near 300 Percent
New Antidumping and Countervailing Duty Petitions
On September 24, 2026, U.S. producers filed antidumping (AD) and countervailing duty (CVD) petitions covering certain wooden fence pickets from China. The petitions allege dumping margins of 111.87% to 295.89% and subsidies above the de minimis level. These are allegations, not duties now in force or rates that Commerce has calculated. If the investigations proceed and Commerce makes affirmative preliminary determinations, U.S. importers could face cash deposit requirements on covered entries as early as December 2026 for CVD and March 2027 for AD, subject to changes in the schedule.
The proposed scope reaches finished and unfinished pickets made from several wood species, in a range of shapes, with a finished thickness of no more than 1 inch, width of no more than 12 inches, and length of at least 3 feet. Painting, staining, treatment, and certain processing in a third country do not necessarily take a product outside the scope. The proposed exclusions include pickets made exclusively of specified wood species and products covered by the existing China wood mouldings and millwork orders. The product description, rather than the tariff classification alone, controls.
Importers, retailers, distributors, and their Chinese suppliers should review the proposed scope against their actual products and supply chains now. An affirmative preliminary finding could change landed costs and cash flow while orders and shipments are still in the pipeline. The agencies have not yet determined whether the domestic industry is injured or whether the alleged dumping and subsidies exist.
Proposed Product Scope
The petitions propose the following scope language. Commerce may revise the scope during the investigations:
The scope of this investigation includes certain wooden fence pickets, finished and unfinished, whether assembled or unassembled. Wooden fence pickets included in this scope are typically made from Cryptomeria japonica (Japanese Cedar or Sugi), but can also be made from other wood species, including but not limited to Western Red Cedar, Redwood, Incense Cedar, Douglas Fir, Western Hemlock, Sitka Spruce, and Cunninghamia lanceolata (Chinese Fir). Wooden fence pickets are included within the scope of this investigation regardless of form or shape, including, but not limited to, square, pointed, dog ear, flat top, and gothic.
The finished products covered by the scope of this investigation have the following dimensions: a thickness of no more than 1 inch, a width of no more than 12 inches, and a length of at least 3 feet. The products covered by the scope are typically a length of 5 feet, 6 feet, or 8 feet when finished.
Wooden fence pickets are included within the scope of the investigation regardless of whether they have been painted, stained, pressure-treated, or otherwise coated or treated. Subject merchandise also includes wooden fence pickets that have been further processed in a third country, including but not limited to trimming, cutting, notching, sanding, planing, or any other processing that would not otherwise remove the merchandise from the scope of the investigation if performed in the country of manufacture of the in-scope product.
Excluded from the scope of the investigation are wooden fence pickets made exclusively of bamboo, Brazilian Pine (Parana pine), or Southern Yellow Pine (including Shortleaf Pine (Pinus echinata), Slash Pine (Pinus ellioti), Longleaf Pine (Pinus palustris), or Loblolly Pine (Pinus taeda)).
Also excluded from the scope of the investigation are wood mouldings and millwork products covered by the antidumping and countervailing duty orders on wood mouldings and millwork products from China. See Wood Mouldings and Millwork Products From the People ‘s Republic of China, 86 Fed. Reg. 9486 (Dep’t Commerce Feb. 16, 2021) (amended final antidumping duty determination and antidumping duty order); Wood Mouldings and Millwork Products From the People ‘s Republic of China, 86 Fed. Reg. 9484 (Dep’t Commerce Feb. 16, 2021) (countervailing duty order).
Imports of subject merchandise are typically classified under Harmonized Tariff Schedule of the United States (HTSUS) statistical numbers 4404.10.00.40, 4407.19.00.92, 4421.99.70.20, and 4421.99.70.40. Although the HTSUS subheadings are provided for convenience and customs purposes, the written description of the scope of these investigations is dispositive.
Alleged Margins and Named Companies
The petitions identify certain Chinese producers and exporters and U.S. importers. Being named does not establish that a company’s products are covered; being absent from the lists does not establish that they are excluded. Companies should review their merchandise and supplier relationships against the proposed scope. Clark Hill can provide the lists identified in the petitions.
The petitioners allege the following margins. Commerce will calculate any applicable deposit rates during its investigations:
- China: alleged AD margins of 111.87% to 295.89%; alleged CVD subsidies above de minimis, without a proposed numerical CVD rate.
How the Investigations Proceed
The U.S. International Trade Commission (ITC) will first decide whether there is a reasonable indication of material injury or threat of material injury to the U.S. industry. A negative preliminary injury finding would end the investigations. If the ITC’s finding is affirmative, the U.S. Department of Commerce (Commerce) will investigate dumping and subsidization and calculate any AD and CVD rates. Final duties require affirmative final determinations from both agencies.
If the investigations continue, Commerce’s preliminary CVD and AD determinations are estimated for December 18, 2026, and March 3, 2027, respectively. Following an affirmative preliminary determination, cash deposits generally begin on covered entries as of publication of that determination in the Federal Register. A critical circumstances finding can, under specified conditions, extend duty exposure up to 90 days before that publication. The dates are estimates and may be extended; the petitioners’ alleged margins are not the deposit rates.
What Importers and Chinese Suppliers Should Do Now
U.S. importers should compare specifications, species, dimensions, and processing history for each product with the proposed scope; identify the manufacturer and exporter; and map open orders and expected entry dates. Review landed cost and cash flow scenarios using possible AD and CVD deposits, without treating the petitioners’ estimates as the eventual rates.
Chinese producers and exporters should preserve product, sales, production, and subsidy records, identify related companies, and prepare for possible Commerce questionnaires. In a China AD investigation, timely separate rate applications may be important for exporters seeking a rate distinct from the China-wide rate. The agency’s initiation notice and subsequent questionnaires will set actual filing deadlines.
Both sides should review pricing and duty allocation terms in supply contracts and decide promptly whether to present product scope or injury arguments. The indicative schedule below is subject to agency notices and extensions.
| Approximate Key Dates* | ||
| Antidumping Duty Investigation | ||
| Event | No. of Days | Date of Action |
| Petition Filed | 0 | 9/24/2026 |
| DOC Initiation Date | 20 | 10/14/2026 |
| DOC Separate Rate Applications | To be set | To be announced |
| DOC Q&V Questionnaires | To be set | To be announced |
| ITC Preliminary Determination | 45 | 11/9/2026 |
| DOC Preliminary AD Determination | 160 | 3/3/2027 |
| DOC Final AD Determination | 235 | 5/17/2027 |
| ITC Final AD Determination | 280 | 7/1/2027 |
| DOC AD Publication of Order | 287 | 7/8/2027 |
| Countervailing Duty Investigation | ||
| Event | No. of Days | Date of Action |
| Petition Filed | 0 | 9/24/2026 |
| DOC Initiation Date | 20 | 10/14/2026 |
| DOC Q&V Questionnaires | To be set | To be announced |
| ITC Preliminary Determination | 45 | 11/9/2026 |
| DOC Preliminary CVD Determination | 85 | 12/18/2026 |
| DOC Hearing Request Deadline (if applicable) | To be set | To be announced |
| DOC Final CVD Determination | 160 | 3/3/2027 |
| ITC Final CVD Determination | 205 | 4/19/2027 |
| DOC CVD Publication of Order | 212 | 4/26/2027 |
*All deadlines are approximate and are subject to change throughout the course of an investigation. Deadlines that fall on a weekend or Federal holiday are extended to the next business day, as shown above. Contact Clark Hill for current updates and details.
Contact Clark Hill
For help assessing product coverage, response obligations, or import planning, contact Clark Hill’s International Trade team:
- Mark Ludwikowski (mludwikowski@clarkhill.com; 202-640-6680)
- Kevin Williams (kwilliams@clarkhill.com; 312-985-5907)
- Kelsey Christensen (kchristensen@clarkhill.com; 202-230-9889)
- Ashley Gifford (agifford@clarkhill.com; 202-640-6655)
- Aristeo Lopez (alopez@clarkhill.com; 202-552-2366)
- Amal Sheheen (asheheen@clarkhill.com; 202-552-2354)
- Onjoly Purification (opurification@clarkhill.com; 202-552-2361)
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