U.S. Producer Files New Trade Case Against Imports of Certain Linear Hydraulic Cylinders and Parts Thereof from Canada, China, India, Mexico, and South Korea

The Petitions

Aggressive Hydraulics Inc.; Hol-Mac Corporation.; Ligon Hydraulics; Prince Manufacturing Corporation; PTC Alliance LLC; Rosenboom Machine and Tool Inc.; Scot Industries Inc.; Stillwell Inc.; and Texas Hydraulics Inc. (collectively, “Petitioners”) have filed new petitions with the U.S. Department of Commerce (“DOC”) and the U.S. International Trade Commission (“ITC”) seeking the imposition of antidumping (“AD”) and countervailing duties (“CVD”) duties on imports into the United States of certain linear hydraulic cylinders and parts thereof (“hydraulic cylinders”) from Canada, China, India, Mexico, and South Korea. The petitions allege that imported hydraulic cylinders from these countries are being sold in the United States at unfairly low prices and, in some cases, benefit from unfair government subsidies. If the federal agencies agree, imports of hydraulic cylinders could become subject to significant additional duties.

The subject merchandise—hydraulic cylinders—has many applications and can be used in any machine where significant forces are required to move a part. Common industrial applications for hydraulic cylinders are in (1) elevators, lifts, and jacks; (2) manufacturing machinery that requires pushing, pulling, shearing, compacting, or bending of materials; (3) mobile equipment such as dump trucks, garbage trucks, lift trailers, construction equipment, earth moving equipment (e.g., backhoes, bulldozers, road graders), and agricultural equipment; and (4) material handling equipment (e.g., forklift trucks, telehandlers and liftgates), among many other uses.

Companies that import, distribute, or purchase hydraulic cylinders should closely monitor these investigations. If Commerce reaches affirmative preliminary determinations, importers of hydraulic cylinder products from Canada, China, India, Mexico, and South Korea could become subject to significant cash deposit requirements within a matter of months, potentially affecting pricing, sourcing decisions, and product availability.

Scope of the Investigation

The following language describes the imported merchandise that the Petitioners intend to cover in these investigations:

The scope of these investigations covers certain linear-acting hydraulic cylinders (also known as hydraulic power engines) and certain barrel and piston rod components and assemblies of linear-acting hydraulic cylinders. Covered linear-acting hydraulic cylinders have barrels made of steel, a bore size (inner diameter) of 25.4 mm (one inch) or more, and a return (retracted) length of 102.1 mm (four inches) or more. For purposes of this scope, the return (retracted) length is the overall end-to-end measurement of the hydraulic cylinder unit when in the retracted position. The scope covers all such linear-acting hydraulic cylinders meeting the physical description above, including but not limited to the following linear hydraulic cylinder designs: tie-rod, welded body, telescopic, plunger, rodless, differential, position sensing, single acting, double acting, displacement, ram type, piggy-back, double rod, rod-fed, and spring return linear-acting hydraulic cylinders. All covered cylinders are hydraulically activated. The incorporation of a spring into the design of a hydraulic cylinder otherwise meeting the description above does not exclude a product from the scope.

The scope also covers (1) steel barrel components, (2) steel piston rod components, and (3) any component of a linear hydraulic cylinder that is attached to, assembled with, or shipped with a covered steel barrel or a covered piston rod.

Covered barrel components include processed welded or seamless steel tubes four inches or more in length with an inner diameter of one inch (25.4 mm) or more, that have had their inner diameter precision machined (such as through honing or skiving and burnishing), and have otherwise been processed to the point of having as their sole or predominant use a barrel for an in-scope hydraulic cylinder. Such processing may include but is not limited to cutting-to-length, end-finishing (e.g., machine-threading, chamfering, etc.), port drilling, and the addition of weldments, or any combination thereof.

Covered piston rods are solid or hollow bars or tubes that have been hard chrome-plated or chrome-coated, cut to length, and machined to be a piston rod.

Included in the scope are any attachments, parts, or components that are imported with, attached to, or invoiced with a linear hydraulic cylinder or covered component, including but not limited to cylinder mounting parts (e.g., flanges, trunnions, devises, lugs, etc.), connectors attached to pistons or piston rods, pistons, or hydraulic tubing or hydraulic lines (regardless of material) such as for connections to a hydraulic pump.

Also included in the scope are any hydraulic cylinders meeting the physical description above attached to or imported with any equipment or parts of equipment classified in Chapter 84 Harmonized Tariff Schedule of the United States. When a hydraulic cylinder is attached to or imported with any equipment or parts of equipment classified in Chapter 84 of the Harmonized Tariff Schedule of the United States, only the hydraulic cylinder is covered by the scope.

Subject merchandise also includes hydraulic cylinders, components, and subcomponents that undergo assembly or further working in a third country in any manner that would not otherwise remove the merchandise from the scope of the investigations if performed in the country of manufacture of the in-scope hydraulic cylinder. Subject merchandise also includes hydraulic cylinders, components, and subassemblies that are attached to any equipment or parts of equipment classified in Chapter 84, as discussed in the immediately preceding paragraph, if such attachment occurs in a third country.

Excluded from the scope are pneumatic power engines and motors.

All products that meet the written physical description are within the scope of the investigations unless specifically excluded or covered by the scope of an existing order.

The products subject to these investigations are currently classified in the Harmonized Tariff Schedule of the United States (HTSUS) under statistical reporting numbers 8412.21.0015, 8412.21.0030, 8412.21.0045, 8412.21.0060, 8412.21.0075, and 8412.90.9005. The HTSUS subheadings above are provided for convenience and Customs purposes only. The written description of the scope of these investigations is dispositive.

Key Facts

Petitioners: Aggressive Hydraulics Inc.; Hol-Mac Corporation.; Ligon Hydraulics; Prince Manufacturing Corporation; PTC Alliance LLC; Rosenboom Machine and Tool Inc.; Scot Industries Inc.; Stillwell Inc.; and Texas Hydraulics Inc

Foreign Producers/Exporters and U.S. Importers: Please contact Clark Hill’s International Trade team for a listing of individual importers and exporters named in the petitions.

AD/CVD margins: Petitioners alleged the following AD and CVD margins:

• Canada: AD Margin 248.33 % to 744.85% ad valorem.
• China: AD margin from 125.77 % to 511.41% ad valorem, and a CVD margin above de minimis.
• India: AD margin from 102.59% to 461.46%, ad valorem, and a CVD margin above de minimis.
• Mexico: AD margin from 60.15% to 163.42%, ad valorem, and a CVD margin above de minimis.
• South Korea: AD margin from 78.70% to 149.33%, ad valorem.

The Investigations

The DOC and the ITC will conduct parallel investigations. The ITC will first determine if there is a reasonable indication of material injury or threat of injury to the U.S. industry. The DOC will then determine whether imports are being dumped or unfairly subsidized and will calculate corresponding AD and CVD duty margins that importers will need to pay on their entries.

If the DOC issues an affirmative preliminary determination, importers will be required to deposit the estimated AD/CVD duties on their imports as of the date that the DOC publishes its affirmative preliminary determination in the Federal Register. In this case, the DOC’s preliminary determinations are currently expected by October 22, 2026 (CVD) and January 5, 2027 (AD), although the schedule is subject to change. Importers should be aware that cash deposits may apply earlier if the DOC finds that there is a surge of imports after the Petitions were filed.

Next Steps

Given the strict statutory deadlines, governing AD and CVD investigations, U.S. importers and foreign producers are advised to prepare as soon as possible.

If this product is of interest to your business, please contact Clark Hill’s International Trade team for additional details and strategic guidance.

A schedule of approximate key dates is below.

Contact Clark Hill

If you have questions regarding the content of this alert, please contact any member of Clark Hill’s International Trade practice:

• Mark Ludwikowski (mludwikowski@clarkhill.com; 202.640.6680)
• Kevin Williams (kwilliams@clarkhill.com; 312.985.5907)
• Kelsey Christensen (kchristensen@clarkhill.com; 202.230.9889)
• Aristeo Lopez (alopez@clarkhill.com; 202.552.2366)
• Ashley Gifford (agifford@clarkhill.com; 202.640.6655)
• Laura M. Quesada (Lquesada@clarkhill.com; 202.240.0170)
• Amal Sheheen (asheheen@clarkhill.com; 202.552.2354)
• Onjoly Purification (Opurification@clarkhill.com; 202.552.2361)

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Approximate Key Dates*
Antidumping Duty Investigation
Event	No. of Days	Date of Action
Petition Filed	0	7/29/2026
DOC Initiation Date	20	8/18/2026
DOC Separate Rate Applications	41	9/8/2026
DOC Q&V Questionnaires	44	9/11/2026
ITC Preliminary Determination	45	9/14/2026
DOC Preliminary AD Determination	160	1/5/2027
DOC Final AD Determination	235	3/22/2027
ITC Final AD Determination	280	5/5/2027
DOC AD Publication of Order	287	5/12/2027
Countervailing Duty Investigation
Event	No. of Days	Date of Action
Petition Filed	0	7/29/2026
DOC Initiation Date	20	8/18/2026
DOC Q&V Questionnaires	44	9/11/2026
ITC Preliminary Determination	45	9/14/2026
DOC Preliminary CVD Determination	85	10/22/2026
Request for a DOC Hearing	122	11/30/2026
DOC Final CVD Determination	160	1/5/2027
ITC Final CVD Determination	205	2/19/2027
DOC CVD Publication of Order	212	2/26/2027

 

* 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.

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