U.S. Trade Policy in 2026: AD/CVD and Brazil Section 301 Tariffs

As U.S. trade policy continues to evolve in 2026, importers must closely monitor developments that could affect sourcing decisions, landed costs, compliance obligations and supply-chain planning. Two areas receiving particular attention are antidumping and countervailing duty proceedings—commonly referred to as AD/CVD—and the Section 301 action affecting imports from Brazil.

These trade actions can influence the cost and availability of imported products, alter the competitiveness of international suppliers and create additional risk for companies that rely on global sourcing. For manufacturers, distributors and industrial buyers, understanding both the policy process and its potential commercial impact is essential to making informed purchasing decisions.

This overview explains how AD/CVD measures function, examines the significance of the Brazil Section 301 action and outlines practical considerations for businesses navigating an increasingly complex trade environment.

Overview of AD CVD and Its Role in US Trade Policy

Antidumping and countervailing duties are trade-remedy measures used by the United States to address specific forms of unfair competition involving imported goods.

Anti-dumping duties may be imposed when the U.S. Department of Commerce determines that foreign merchandise is being sold in the United States at less than fair value and the U.S. International Trade Commission determines that the imports are materially injuring—or threatening to injure—a domestic industry.

Countervailing duties may be imposed when imported goods benefit from certain government subsidies in the exporting country and those subsidized imports cause or threaten material injury to a U.S. industry.

Unlike broadly applied tariffs, AD/CVD measures are generally tied to particular products, countries and exporters. The resulting duty rates can substantially affect landed costs, supplier selection and long-term sourcing strategies.

The AD/CVD Process Explained

Antidumping and countervailing duty investigations involve three federal agencies with distinct responsibilities. The U.S. Department of Commerce determines whether dumping or countervailable subsidization has occurred and calculates the applicable margins or subsidy rates. The USITC separately determines whether the imports materially injure—or threaten to materially injure—a U.S. industry. U.S. Customs and Border Protection then collects cash deposits and enforces the resulting duty instructions.

The process generally includes the following stages:

1. Petition and Initiation: A U.S. industry typically files a petition with both Commerce and the USITC alleging that a specific product from one or more countries is being dumped, subsidized or both. Commerce evaluates whether the petition satisfies the statutory requirements for opening an investigation.

   
   

2. Preliminary Injury Determination: The USITC conducts an initial review to determine whether there is a reasonable indication that the domestic industry is materially injured or threatened with material injury by the imports under investigation. A negative preliminary determination generally ends the proceeding.

   
   

3. Preliminary Commerce Determination: Commerce investigates foreign producers, exporters and—in a CVD proceeding—the relevant foreign government programs. When Commerce makes an affirmative preliminary determination, it generally instructs CBP to suspend liquidation of covered entries and collect estimated cash deposits.

   
   

4. Final Determinations and Orders: Commerce issues its final dumping or subsidy determinations, and the USITC completes its final injury review. When both agencies make affirmative final determinations, Commerce issues an AD or CVD order.

   
   

5. Collection and Enforcement: CBP collects the required cash deposits and later assesses final duties under Commerce’s instructions. Treatment can depend on the written product scope, country of origin, producer, exporter and date of entry. Cash deposits are estimates, and final liability may change through subsequent administrative proceedings.

AD/CVD measures are therefore different from broadly applied country tariffs. They are tied to defined merchandise from specified countries and may include company-specific rates. For importers, determining whether a product falls within the written scope of a proceeding is just as important as identifying its tariff classification.

A Major 2026 AD/CVD Development for the Wood Products Market

One of the most significant 2026 developments for the imported wood products industry involves hardwood and decorative plywood from China, Indonesia and Vietnam.

On July 16, 2026, Commerce announced final affirmative AD and CVD determinations covering hardwood and decorative plywood from all three countries. The calculated dumping margins, subsidy rates and cash-deposit requirements varied considerably by country and producer or exporter.

On August 19, 2026, the USITC made affirmative injury determinations regarding hardwood and decorative plywood—excluding all softwood structural plywood—from China, Indonesia and Vietnam. Those affirmative determinations cleared the way for Commerce to issue AD and CVD orders covering the products included in the determinations.

The USITC separately found imports of the two examined softwood structural plywood categories to be negligible and voted to terminate those portions of the investigations.

For manufacturers, distributors and importers, the commercial takeaway is clear: broad product labels such as “plywood” are not sufficient to determine duty exposure.

Businesses must examine the written scope, product construction, face and back veneers, core materials, dimensions, intended use, producer-exporter combination and applicable case rate before committing to a purchase or customer price.

Brazil Section 301 Action: What Businesses Need to Know in 2026

Section 301 of the Trade Act of 1974 authorizes the United States Trade Representative to investigate foreign acts, policies or practices that may be unreasonable or discriminatory and burden or restrict U.S. commerce. Unlike AD/CVD proceedings, a Section 301 action does not require a finding that a particular foreign producer dumped or subsidized a specific product.

--

Antidumping and countervailing duty investigations involve three federal agencies with distinct responsibilities. The U.S. Department of Commerce determines whether dumping or countervailable subsidization has occurred and calculates the applicable margins or subsidy rates. The U.S. International Trade Commission, or USITC, separately determines whether the imports materially injure—or threaten to injure—a U.S. industry. U.S. Customs and Border Protection then collects cash deposits and enforces the resulting duty instructions.

The process generally includes the following stages:

1. Petition and Initiation: A U.S. industry typically files a petition with both Commerce and the USITC alleging that a specific product from one or more countries is being dumped, subsidized or both. Commerce evaluates whether the petition satisfies the statutory requirements for opening an investigation.

   
   

2. Preliminary Injury Determination: The USITC conducts an initial review to determine whether there is a reasonable indication that the domestic industry is materially injured or threatened with material injury by the imports under investigation. A negative preliminary determination generally ends the proceeding.

   
   

3. Preliminary Commerce Determination: Commerce investigates foreign producers, exporters and—in a CVD case—the relevant foreign government programs. When Commerce makes an affirmative preliminary determination, it may instruct CBP to suspend liquidation of covered entries and collect estimated cash deposits.

   
   

4. Final Determinations and Orders: Commerce issues its final dumping or subsidy determinations, and the USITC completes its final injury review. When both agencies reach affirmative final determinations, Commerce issues an AD or CVD order.

   
   

5. Collection and Enforcement: CBP collects the required deposits and assesses duties under Commerce’s instructions. The applicable treatment can depend on the product scope, country of origin, producer, exporter and date of entry. Rates may also change through subsequent administrative proceedings.

AD/CVD measures are therefore different from broadly applied country tariffs. They are tied to defined merchandise from specified countries and may include company-specific rates. For importers, determining whether a product falls within the written scope of a proceeding is just as important as identifying its tariff classification.

A Major 2026 AD/CVD Development for the Wood Products Market

One of the most significant 2026 developments for the imported wood products industry involves hardwood and decorative plywood from China, Indonesia and Vietnam.

On July 16, 2026, Commerce announced final affirmative AD and CVD determinations covering hardwood and decorative plywood from all three countries. The calculated dumping margins, subsidy rates and cash-deposit requirements varied considerably by country and producer or exporter.

On August 19, 2026, the USITC made affirmative injury determinations regarding hardwood and decorative plywood—excluding all softwood structural plywood—from China, Indonesia and Vietnam. As a result, Commerce is set to issue AD and CVD orders covering the products included in the affirmative determinations.

The USITC separately found imports of the examined softwood structural plywood categories to be negligible and voted to terminate those portions of the investigations.

For manufacturers, distributors and importers, the commercial takeaway is clear: broad product labels such as “plywood” are not sufficient to determine duty exposure.

Businesses must examine the written scope, product construction, face and back veneers, core materials, dimensions, intended use, producer-exporter combination and applicable case rate before committing to a purchase or customer price.

Brazil Section 301 Action: What Businesses Need to Know in 2026

Section 301 of the Trade Act of 1974 authorizes the United States Trade Representative to investigate foreign acts, policies or practices that may be unreasonable or discriminatory and burden or restrict U.S. commerce. Unlike AD/CVD proceedings, a Section 301 action does not require a finding that a particular foreign producer dumped or subsidized a specific product.

Background and Purpose

USTR initiated its Brazil Section 301 investigation on July 15, 2025. The investigation examined Brazilian acts, policies and practices involving:

• Digital trade and electronic payment services

• Preferential tariff treatment

• Anti-corruption enforcement

• Intellectual property protection

• Ethanol market access

• Illegal deforestation

On June 1, 2026, USTR determined that certain Brazilian acts, policies and practices were actionable under Section 301 and proposed a responsive tariff action. Following public comments and a July 2026 hearing, USTR moved forward with final action.

Current Status as of August 2026

Effective July 22, 2026, USTR imposed an additional 25% tariff on imports from Brazil, subject to specified exemptions. USTR stated that exemptions were warranted for certain products because they were important raw materials, were not sufficiently available from domestic or alternative sources, could create broader economic disruption or were unlikely to contribute meaningfully to resolving the practices identified in the investigation.

The tariff action does not preclude continued negotiations between the United States and Brazil. USTR has stated that it will continue monitoring the issues raised in the investigation and consider whether modifications to the action are appropriate. For current sourcing and pricing decisions, however, companies should treat the tariff as an active requirement rather than a hypothetical policy risk.

How the Exemptions Affect Wood Products

The final action includes important—but not universal—exemptions for wood and wood products.

The exemption annex includes numerous wood-related HTSUS provisions covering specified tropical wood and veneer, continuously shaped tropical wood, certain plywood and veneered panels, laminated veneered lumber and certain blockboard, laminboard and battenboard products.

The notice also exempts articles already subject to Section 232 tariffs from the additional Brazil Section 301 duty. That treatment may prevent an additional Section 301 tariff layer from being imposed on those articles, but it does not eliminate an otherwise applicable Section 232 duty.

In discussing the exemption requests, USTR noted industry comments that certain Brazilian wood species and products have performance, durability, moisture-resistance or structural characteristics that may not be readily replaced with domestic or third-country alternatives. The discussion also addressed certain softwood plywood and engineered hardwood flooring products and the possible effects of tariffs on U.S. importers, distributors, builders and industrial users.

The exemptions should not be interpreted as a blanket exemption for all Brazilian wood products. Treatment depends on the precise HTSUS classification, applicable product description, country-of-origin determination and any limitations contained in the relevant tariff provision.

What These Trade Actions Mean for Importers and Manufacturers

The combined effect of AD/CVD proceedings, Section 301 tariffs and other trade measures makes landed-cost planning increasingly product-specific.

Greater Landed-Cost Exposure

A product may be subject to ordinary customs duties, AD/CVD cash deposits, Section 301 duties, Section 232 duties or another trade measure. Some duties may apply in addition to one another, while particular exclusions or tariff provisions may prevent stacking in defined circumstances.

Companies should calculate the potential duty treatment before finalizing supplier pricing, customer quotes or long-term purchasing commitments.

Supplier Identity Matters

In an AD/CVD proceeding, two visually similar products from the same country may receive different treatment based on the producer, exporter, product specifications or applicable scope determination.

Importers should confirm the complete manufacturer-exporter relationship rather than relying only on the name of the trading company appearing on an invoice.

Classification and Scope Are Separate Questions

An HTSUS number is an essential part of customs compliance, but an AD/CVD scope can include or exclude products based on physical characteristics and written scope language. A tariff number alone may not determine whether merchandise is covered by an AD/CVD order.

For Section 301 measures, the applicable HTSUS provisions and any stated limitations or exemptions are central to determining whether the additional tariff applies.

Pricing Requires More Flexibility

Long-term quotes issued without tariff-adjustment language can expose suppliers, importers and customers to unexpected costs. Businesses should consider contract provisions addressing:

• Changes in duties or cash-deposit rates

• Government-imposed tariffs

• Scope or classification determinations

• Material changes in freight or port costs

• Delays caused by customs reviews

• Alternative materials or country-of-origin options

Documentation Is Part of Supply-Chain Risk Management

Importers should maintain reliable records supporting country of origin, producer and exporter identity, product composition, veneer and core construction, dimensions, certifications and tariff classification.

Strong documentation helps customs brokers and trade professionals evaluate product treatment and reduces the risk of inconsistent entry declarations.

Best Practices for Importers in 2026

1. Review Scope and Classification Before Ordering

Evaluate both the product’s HTSUS classification and the written scope of any potentially applicable AD/CVD proceeding. This review should occur before purchase orders are issued—not after merchandise reaches a U.S. port.

2. Verify the Producer, Exporter and Country of Origin

Document who manufactured the product, who exported it and where the relevant production occurred. Do not assume that routing merchandise through a third country changes its country of origin or removes an otherwise applicable trade remedy.

3. Model Multiple Landed-Cost Scenarios

Prepare pricing scenarios that account for the ordinary duty rate, estimated AD/CVD cash deposits, Section 301 or Section 232 duties, brokerage costs, freight and possible rate changes. A low supplier price can become commercially unworkable when the full duty exposure is included.

4. Monitor Official Government Sources

Businesses should regularly review:

• Commerce AD/CVD proceedings and ACCESS records

• USITC injury investigations and determinations

• USTR Section 301 notices

• Federal Register publications

• CBP implementation guidance and entry instructions

Trade alerts from industry associations can be useful, but official notices and current customs instructions should remain the primary sources for compliance decisions.

5. Maintain Alternative Sourcing Options

Diversification should be based on qualified manufacturers and verifiable origin—not simply alternative shipping routes. Backup suppliers should be evaluated for quality, capacity, lead time, compliance history and trade-remedy exposure before they are needed.

6. Coordinate With Qualified Trade Professionals

Customs brokers, trade attorneys and classification specialists can help assess scope, tariff classification, country of origin and entry requirements. Technology can support the process, but automated tariff databases should not replace professional review when significant AD/CVD or Section 301 exposure is possible.

Conclusion

U.S. trade policy in 2026 demonstrates why importers cannot rely on broad assumptions about countries or product categories. AD/CVD exposure is product-, country- and often supplier-specific, while the Brazil Section 301 action applies a broad country measure with detailed exemptions.

The hardwood and decorative plywood proceedings involving China, Indonesia and Vietnam, together with the Brazil tariff action, can affect landed costs, supplier selection, inventory planning and customer pricing across the wood products market.

Companies that identify potential exposure early, document their supply chains and evaluate multiple sourcing scenarios will be better positioned to protect continuity and make informed purchasing decisions.

Supply Confidence Starts Here

At Argo Fine Imports, supply confidence begins with understanding how changing market and trade conditions may affect product availability, landed costs and lead times.

With decades of global sourcing experience, established supplier relationships and practical knowledge of the imported wood products market, Argo helps OEM manufacturers and distributors compare sourcing options, anticipate supply-chain challenges and make better-informed purchasing decisions.

Trade policies can change quickly, but material and production decisions still have to be made. Talk with Argo about your product requirements, supply priorities and the sourcing options available for your business.

---

Publication note: Information in this article is current as of August 28, 2026, and is provided for general informational purposes only. It is not legal, customs, tariff-classification or trade-compliance advice. Duties and product treatment may vary based on applicable scope language, HTSUS classification, country of origin, producer, exporter, entry date and subsequent agency action. Consult a qualified customs broker or trade attorney regarding specific products or transactions.