An Administrative Review is the annual review of an antidumping or countervailing duty order conducted by the Commerce Department under section 751(a) of the Tariff Act of 1930 (19 U.S.C. § 1675(a)). Procedures are at 19 CFR § 351.213.
Each year, in the anniversary month of the order, Commerce publishes an opportunity-to-request notice. Interested parties (domestic industry, foreign producers, importers, or foreign governments) can request review of specific exporters for the prior 12-month period of entries. Without a request, CBP automatically liquidates entries at the prevailing cash-deposit rate.
The review serves two purposes:
- Retrospective assessment — Commerce calculates the actual dumping margin or subsidy rate for the period of review. The resulting rate is applied to the entries during that period — meaning importers may owe additional duty or receive refunds (with interest).
- Prospective cash deposit — The newly calculated rate becomes the cash deposit rate for future entries until the next review.
This retrospective assessment system is unique to the United States — most other WTO members use prospective duty systems. A practical consequence is that an importer's true AD/CVD liability isn't fixed at entry. Liquidation of entries is suspended during the review (sometimes for years), and final duty can be substantially higher or lower than the deposit.
Reviews typically take 360–540 days from initiation. They produce voluminous, fact-intensive determinations that often become the basis for litigation at the Court of International Trade.