On 8 October 2026, the U.S. Department of Commerce published an affirmative preliminary countervailing-duty determination on N-Cyclohexylbenzothiazole-2-Sulfenamide (CBS) from China. It also preliminarily found critical circumstances for the listed companies and all other producers or exporters. The operational issue is therefore wider than future shipments: import teams need to identify potentially affected unliquidated entries within the 90-day lookback.
Start with three controls
Establish written-scope coverage, map the producer-exporter combination, and join entry dates to liquidation status. Keep unknown fields visible with an owner. Ask the U.S. importer, broker or trade counsel to confirm treatment against current Commerce and CBP instructions.
1. Record the procedural stage
This is the preliminary CVD determination in investigation C-570-235, effective 8 October 2026. The period of investigation is 1 January through 31 December 2025. Commerce preliminarily found countervailable subsidies.
The final CVD determination is aligned with the companion AD determination and is currently scheduled no later than 11 January 2027 unless postponed. Final CVD and AD results, the ITC injury decision and final liability for a particular entry remain unresolved.
2. Test the written product scope before the tariff code
The scope covers CBS and lists names such as Accelerator CZ, CBTS, Thiohexam and HIP4. It includes powder, oiled powder, granules and other colors or forms. The notice identifies CAS 95-33-0.
HTS 2934.20.8000 is listed, and imports may also enter under 3812.10.1000 or 3812.10.5000. These codes are provided for convenience; the written description controls. A China supplier should provide composition, chemical name, aliases, CAS, form and use. The U.S. importer should confirm scope and classification for the actual merchandise.
3. Label 107.57% as preliminary
| Record | Preliminary result | What it cannot establish |
|---|---|---|
| Derek, Huatai and non-responsive companies | 107.57%, based on facts available with adverse inferences | Final assessed duty |
| All Others | 107.57% | A rate without the producer-exporter check |
| Cash deposit and suspension | Applied under preliminary instructions | Final landed cost |
Commerce says it will not conduct verification because the examined respondents did not provide requested information and were preliminarily found uncooperative. Keep the methodology, stage, source and review date beside the number.
4. Understand what the 90-day rule controls
The normal preliminary determination suspends liquidation for subject entries from publication and requires a cash deposit. The affirmative critical-circumstances finding extends suspension to covered unliquidated entries entered, or withdrawn from warehouse for consumption, on or after the date 90 days before publication.
This does not pull every chemical from China into the lookback. Product scope, producer and exporter, entry timing, liquidation status and current instructions still matter.
5. Match the producer-exporter combination
The notice states that when both producer and exporter have different company-specific rates, the higher rate applies; when only one has a company-specific rate, that rate applies; when neither does, use All Others. Trading names, group relationships and quotation labels are not substitutes for legal-entity confirmation.
6. Build an entry-level review list
| Owner | Inputs | Output |
|---|---|---|
| China producer or exporter | Product description, CAS, composition, form, producer, exporter and quote revision | Scope and entity fact pack |
| U.S. importer or broker | Entry number, entry date, producer-exporter pair, liquidation status and current instructions | Entry-by-entry treatment list |
| Cost owner | Ordinary duty, possible AD, preliminary CVD deposit, fees, freight and contract responsibility | Versioned cost record with source dates |
The list identifies records for review and assigns ownership. It does not prove that merchandise is inside or outside scope, and it cannot guarantee cash-deposit, assessment or liquidation outcomes.
7. Set the next review triggers
Track the final CVD and AD determinations, the ITC injury determination, later CBP instructions and any change in entities, scope or liquidation status. When one changes, recalculate only the affected entries and quotations while preserving the previous version and correction reason.
Facts, analysis and unknowns
Source facts: Commerce published a 107.57% preliminary subsidy rate and an affirmative preliminary critical-circumstances finding, with suspension reaching certain unliquidated entries in the 90-day lookback. CZ Overseas analysis: teams should join scope, entities, entry date and liquidation status in one review chain. Unknown: final rates, injury, entry-specific treatment and final assessment remain unresolved.
Primary sources: Federal Register 2026-20692 and the official govinfo PDF, checked 9 October 2026. Review again at the final CVD/AD determinations, the ITC decision and relevant CBP instructions.
Frequently asked questions
Is 107.57% the final duty for every related entry?
No. It is the preliminary subsidy rate and cash-deposit basis in this investigation. Final assessment depends on later determinations, instructions, reviews and liquidation.
Does the 90-day lookback cover every chemical imported from China?
No. First establish written-scope coverage, then check the producer, exporter, entry date and whether the entry remains unliquidated.
Does a complete file prove that an entry is compliant?
No. A complete file supports review; it does not replace Commerce and CBP decisions on scope, entity combination, cash deposits or suspension of liquidation.
What this lets readers complete
U.S. importers, brokers and cost owners can identify entries needing review without treating a preliminary deposit as final liability. China suppliers can provide the product and entity facts required for the review without claiming the importer’s legal conclusion.
Continue the review
Use the AD/CVD product-scope guide to structure merchandise facts, then use the cash-deposit versus final-assessment guide to keep stages separate. For help organizing public information, contact Chris without sending confidential entry, customer or payment records.