New Trade Petitions Target Certain Shopping Carts and Parts Thereof from China, Alleging Dumping Margins of Up to 343%

New Antidumping and Countervailing Duty Petitions

On October 28, 2026, U.S. producers filed antidumping (AD) and countervailing duty (CVD) petitions on certain shopping carts and parts thereof (“shopping carts”) from China with the Department of Commerce (“Commerce”) and the U.S. International Trade Commission (“ITC”). The petitions allege dumping margins ranging from 165% to 343% and subsidies above the de minimis level. These figures are allegations; Commerce has not calculated any duty or cash deposit rates. If the investigations proceed and Commerce issues an affirmative preliminary determination, U.S. importers could face cash deposit requirements on covered entries as early as January 2027 for CVD and April 2027 for AD. These dates are preliminary and may change.

The subject merchandise — shopping carts — are used in retail sector establishments for the transportation of goods during the shopping process. Shopping carts are comprised of, inter alia, the frame structure or base, basket(s), basket walls, basket floors/bottoms, the upright tubing that supports the basket(s), lower trays or grills, back rests, child seats, gates, and handles, among other parts. Shopping carts are primarily constructed of metal, such as steel, plastic, or a combination thereof.

Importers, retailers, distributors, and their Chinese suppliers should promptly compare their merchandise and supply chains now with the proposed scope. 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 merchandise covered by this investigation consists of certain shopping carts regardless of size, finished or unfinished, whether assembled or unassembled, and certain components and parts thereof. The scope includes shopping carts with baskets that are primarily constructed of metal including, but not limited to, wire mesh, as well as shopping carts with baskets that are primarily constructed of plastic or a combination of metal and plastic. Shopping carts covered by this investigation have the following physical characteristics:

• Frame structure or base: Comprised of welded steel wire or steel tube;
• Basket(s): One or more baskets constructed primarily of metal, including wire mesh, and/or plastic;
• Lower tray or grill: With or without a tray or grill located underneath the basket(s); and
• Component Features: Including, but not limited to, shopping carts fitted with plastic handle units, child seats, and polyurethane or rubber wheels.

The scope also covers the main components and parts of shopping carts, including the frame structure or base, basket(s), basket walls whether shaped or flat, basket floors/bottoms whether shaped or flat, the upright tubing that supports the basket(s), lower trays or grills, back rests, child seats, gates, and handles, when imported together or separately. Shopping cart baskets are capable of nesting, by which the front end of one basket can slide into the back end of another basket.

Subject merchandise includes shopping carts that have been further processed or further assembled in a third country. Further processing and further assembly include, but are not limited to, welding, pressing, shaping, cleaning, plating, coating, bolting, painting, machining, and assembly of parts. Specifically excluded are shopping carts for individuals with disabilities or special needs (often referred to as Ben’s carts, Caroline’s carts, and Wheelchair-accessible carts). To qualify for this scope exclusion, the shopping cart must be equipped with a built-in restraint system (e.g., five-point harness, trunk/head supports, abductor), specialized seating for children or adults with physical or development disabilities, or a variable coupling mechanism that forms a single, fixed unit between the wheelchair and shopping cart. A five-point harness is a strap with five parts that goes over both shoulders, around the waist, and between the legs. Trunk and head supports are soft, padded pieces on the back and sides of the seat of the shopping cart. An abductor is a padded block that sits between the thighs. Motorized shopping carts equipped with electric motors and navigational controls are excluded from the scope.

Shopping carts that have an infant carrier permanently or semi-permanently affixed to the cart in place of a standard child seat are excluded from the scope of the investigation. Yokes, casters, and wheels, when imported alone, are excluded from the scope of the investigation. Fully collapsable shopping carts are excluded.

Also excluded from the scope are material handling carts, which are wheeled transport devices that are constructed for heavy-duty commercial logistics applications. To qualify for this exclusion, the merchandise must meet at least three of the following structural or design characteristics:

• Load Capacity: Possess a certified or rated maximum load-bearing weight capacity of 1,000 pounds (453.6 kg) or greater.
• Chassis Construction: Feature a frame or deck constructed primarily of heavy gauge structural steel tube, steel angle, or continuous solid welded steel plate, rather than bent wire mesh or plastic baskets.
• Deck Configuration: Consisting of a flat, open platform, flush deck.
• Caster and Wheel Specifications: Be equipped with industrial-grade casters featuring solid rubber, polyurethane, or pneumatic tires with a wheel diameter of 6 inches or greater, and utilizing precision ball or roller bearings.
• Lack of Consumer Amenities: Lack consumer-oriented retail features including, but not limited to, integrated child seats, plastic corner bumpers, grocery bag hooks, or nesting geometries designed for nested front-to-back storage lines.

Excluded from the scope of this investigation are heavy-duty logistics transport trolleys and warehouse fulfillment/picking carts. To qualify for this exclusion, the merchandise must meet at least three of the following physical or structural characteristics:

• Non-Nesting Design: Possess a rigid, non-collapsible frame architecture that does not feature a tapered basket or a hinged rear gate, rendering the units completely incapable of nesting front-to-back with one another.
• Ergonomic Upright Handlebars: Feature one or more continuous, heavy gauge steel vertical or horizontal push-bars integrated directly into the structural frame posts, rather than a top-mount plastic retail handle unit.
• Multi-Tiered Open Shelving: Utilize a multi-shelf configuration consisting of two or more open, flat shelves or wire decks that completely lack a deep-walled, fully enclosed perimeter basket structure.
• Fixed Industrial Casters: Equipped with a wheel configuration consisting of two rigid (fixed) casters and two swivel casters to facilitate heavy-duty straight-line tracking in warehouse aisles, rather than four omnidirectional or full-swivel retail casters.

The merchandise subject to this investigation is classified under the Harmonized Tariff Schedule of the United States (HTSUS) statistical subheading 8716.80.5090. Merchandise subject to this investigation may also be imported under subheadings 8716.80.5010 or 8716.90.5020. Although the HTSUS subheadings are provided for convenience and customs purposes only, the written description of the scope of this investigation is dispositive.

Alleged Margins and Potentially Affected 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 165% to 343%; alleged CVD subsidies above de minimis, without a proposed numerical CVD rate.

Approximate Key Dates*

Antidumping Duty Investigation
Event	No. of Days	Date of Action
Petition Filed	0	10/28/2026
DOC Initiation Date	20	11/17/2026
DOC Separate Rate Applications	To be set	To be announced
DOC Q&V Questionnaires	To be set	To be announced
ITC Preliminary Determination	45	12/14/2026
DOC Preliminary AD Determination	160	4/6/2027
DOC Final AD Determination	235	6/21/2027
ITC Final AD Determination	280	8/4/2027
DOC AD Publication of Order	287	8/11/2027
Countervailing Duty Investigation
Event	No. of Days	Date of Action
Petition Filed	0	10/28/2026
DOC Initiation Date	20	11/17/2026
DOC Q&V Questionnaires	To be set	To be announced
ITC Preliminary Determination	45	12/7/2026
DOC Preliminary CVD Determination	85	1/21/2027
DOC Hearing Request Deadline (if applicable)	To be set	To be announced
DOC Final CVD Determination	160	4/5/2027
ITC Final CVD Determination	205	5/21/2027
DOC CVD Publication of Order	212	5/28/2027

*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.

How the Investigations Proceed

The 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 determination would terminate the investigations. If the ITC’s finding is affirmative, 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 January 21, 2027, and April 5, 2027, respectively. Following an affirmative preliminary determination, cash deposits generally begin on covered entries as of publication of that determination in the Federal Register. If critical circumstances are found, suspension of liquidation and cash deposit requirements may apply retroactively to entries made 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, materials, 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 an AD investigation for China, 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.

Contact Clark Hill

For help assessing product coverage, response obligations, or import planning, contact Clark Hill’s International Trade team:

• 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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