New Trade Case Could Raise Costs for Imported Air Compressors from China, Malaysia, and Vietnam

The Petitions

MAT Industries, LLC has filed petitions with the U.S. Department of Commerce (“DOC”) and the U.S. International Trade Commission (“ITC”) seeking the imposition of antidumping duties (“AD”) and countervailing (“CVD”) duties on imports into the United States of stationary and portable air compressors (“certain air compressors” or “air compressors”) from China, Malaysia, and Vietnam. The petitions allege that imported air compressors 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 covered air compressors could become subject to significant additional duties.

The petitions allege that these imports are being sold into the U.S. market at unfairly low prices and benefits from unfair government subsidies, causing material injury to the domestic industry.

The subject merchandise—certain stationary and portable air compressors—is widely used across diverse end-use sectors. In these applications, air compressors provide compressed air to power tools and equipment, including nail guns, sanding and painting systems, vehicle repair tools, cleaning and inflation equipment, and medical or dental devices.

For importers, distributors, retailers, purchasers, and companies that rely on air compressors in construction, agriculture, light manufacturing, automotive repair, medical, dental, and other commercial settings, the filing is important because these cases move quickly. If Commerce issues affirmative preliminary determinations, U.S. importers may be required to post cash deposits on covered imports within months.

Scope of the Investigation

The following language describes relevant aspects of the imported merchandise that the Petitioner intends to cover in these investigations:

The merchandise covered by these investigations consists of certain stationary and portable air compressors, electric, gas and battery powered, including electric motor and gasoline engine-powered air compressors with either oil-free or oil-lubricated reciprocating pumps. The compressors may be either direct drive or belt driven. Direct-drive air compressors included in the scope have a motor connected directly to the compressor element. Belt-driven air compressors included in the scope have a motor connected to the compressor crankshaft with a belt. Direct-drive air compressors are more often portable but can be stationary, while belt-driven air compressors are either portable or stationary.

The scope includes electric and engine-driven air compressors, with either oil-free or oil-lubricated reciprocating pumps, with an integrated pressure vessel that ranges in size from 4 gallons to 80 gallons.

The scope also includes battery-powered motor-driven air compressors, with either oil-free or oil-lubricated reciprocating pumps, with an integrated pressure vessel that ranges in size from 1 to 30 gallons.

Covered air compressors have a power level designation between 373 watts (.5 HP) and 22.37 kilowatts (30 HP). Specifically, portable air compressors often range in power from .5HP (373 watts) to 15HP (11.19KW). Reciprocating stationary air compressors range in power from .5HP (373 watts) to 25HP (18.64KW). However, a portable or stationary air compressor with a different power level, within the range of 373 watts to 22.37 KW, and otherwise meeting the language of the scope, is covered by the scope.

The scope includes only certain reciprocating (piston) compressors, which use a piston moving back and forth in a cylinder to compress the air. The scope does not include rotary compressors. Types of rotary compressors excluded from the scope include rotary screw, rotary vane, and scroll compressors. The scope also excludes dynamic compressors. Types of dynamic compressors excluded from the scope include centrifugal compressors and axial compressors. Subject merchandise also includes finished and unfinished compressors that are further processed in a third country or in the United States, including, but not limited to, assembly or any other processing that would not otherwise remove the merchandise from the scope of this order if performed in the country of manufacture of the in-scope air compressors.

For the purposes of this scope, “unfinished compressors” are compressors which require additional fabrication such as labeling, and packaging, and kitting operations adding accessories.

Specifically included in the scope are compressors which are imported as part of a package with accessories or other products, or kit. Such accessories include but are not limited to hoses, fittings, tool kits, oils, nail guns, pneumatic paint sprayers, air ratchet wrenches, air grease guns, air drills, air hammers, air sanders, air inflators, and air impact drivers. If such accessories or other products are imported separately from the air compressor, such products are not subject to the scope of this order.

Specifically excluded from the scope are AC, DC and battery-powered and battery-powered inflators. The excluded inflators do not have an integrated air tank or air reservoir. The excluded inflators have an output of 1 CFM or less.

The in-scope stationary air compressors are classified under subheadings 8414.80.16.15, 8414.80.16.25, and 8414.80.16.35 of the Harmonized Tariff Schedule of the United States (“HTSUS”) The in-scope portable air compressor is classified under subheading 8414.80.16.85 of the HTSUS. Although the HTSUS codes are provided for convenience and customs purposes, the written description of the covered merchandise is dispositive.

Key Facts

Petitioner: MAT Industries, LLC.

Foreign Producers/Exporters and U.S. Importers:  The petitions identify a number of companies. Businesses that may be affected could review the petitions carefully and assess whether they are named directly or implicated through supply-chain relationships. Please contact Clark Hill’s International Trade team for a listing of individual importers and exporters named in the petitions.

AD/CVD margins: The Petitioner alleged the following AD and CVD margins:

• China: AD Margin from 86.98% to 214.92% ad valorem, and a CVD margin above de minimis.
• Malaysia: AD Margin from 88.27% to 144.53% ad valorem, and a CVD margin above de minimis.
• Vietnam: AD Margin from 37.08% to 175.19% ad valorem, and a CVD margin above de minimis.

The Investigations

The DOC and ITC will conduct parallel investigations. The ITC examines whether the domestic industry is materially injured or threatened with material injury. The DOC determines whether dumping or subsidization exists and, if so, calculates the duty rates that importers must deposit.

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 July 24, 2026 (CVD) and October 7, 2026 (AD), although the schedule is subject to change. Importers may also be alert to the possibility of a critical circumstances finding, which in some cases can allow duty liability to reach back before the preliminary determination if the DOC finds that there is a surge of imports after the petitions were filed.

Next Steps

AD/CVD investigations are front-loaded. Key decisions are made early, and companies that wait until duties are imposed may lose important opportunities to shape the record.

Companies that import, purchase, sell, distribute, or use potentially covered air compressors should begin assessing their exposure now. Practical steps include confirming whether imported products fall within the proposed scope, identifying the country of manufacture and any third-country processing or assembly, reviewing whether the company is listed in the petitions, preserving import and sales records, and coordinating internally among legal, finance, procurement, sales, logistics, and operations teams. If your company imports certain air compressors, purchases products containing certain air compressors, or may otherwise be affected by these investigations, please contact Clark Hill’s International Trade team for additional details and strategic guidance.

A schedule of approximate key dates is below.

Approximate Key Dates*

Antidumping Duty Investigation
Event	No. of Days	Date of Action
Petition Filed	0	4/30/2026
DOC Initiation Date	20	5/20/2026
DOC Separate Rate Applications	41	6/10/2026
DOC Q&V Questionnaires	44	6/15/2026
ITC Preliminary Determination	45	6/15/2026
DOC Preliminary AD Determination	160	10/7/2026
DOC Final AD Determination	235	12/21/2026
ITC Final AD Determination	280	2/4//2027
DOC AD Publication of Order	287	2/11/2027
Countervailing Duty Investigation
Event	No. of Days	Date of Action
Petition Filed	0	4/30/2026
DOC Initiation Date	20	5/20/2026
DOC Q&V Questionnaires	44	6/15/2026
ITC Preliminary Determination	45	6/15//2026
DOC Preliminary CVD Determination	85	7/24/2026
Request for a DOC Hearing	122	8/31/2026
DOC Final CVD Determination	160	10/7/2026
ITC Final CVD Determination	205	11/23/2026
DOC CVD Publication of Order	212	11/30/2026

 

* 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

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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