Aluminum AD/CVD Case Watch: Current Duty Rates on Chinese Aluminum Foodservice Products

The duty structure on Chinese aluminum foodservice products is the most complex tariff stack in US foodservice procurement. Section 301 tariffs, AD/CVD cases, and ongoing administrative reviews all stack into a combined effective rate that can exceed 130% on some products. This guide explains the AD/CVD-specific portion and how to track it.

For the broader Section 301 tariff overview see Section 301 Tariffs on Foodservice Packaging.

The four-layer duty stack

When Chinese aluminum foodservice products enter the US, they may face up to four separate duty assessments:

1. MFN (Most-Favored-Nation) tariff — the baseline ad valorem rate (typically 0-5% on aluminum products)
2. Section 301 tariff — additional 7.5-25% on Chinese goods (List 1-4 categories vary)
3. Antidumping duty (AD) — if the product is covered by an active AD order, additional 0-100%+ duty
4. Countervailing duty (CVD) — if the product is covered by an active CVD order, additional 0-150%+ duty

The four duties stack additively. For products covered by all four (like certain aluminum foil products), the combined effective rate can exceed 150% — meaning a $100 landed pre-duty value becomes a $250+ landed post-duty value.

Current AD/CVD coverage of foodservice aluminum

Aluminum foil (HTS 7607.11.30, 7607.11.60, etc.)

Covered by: Aluminum Foil from China AD/CVD orders (active since 2018, multiple administrative reviews since)

AD rates (most recent administrative review): 48% to 106% depending on producer CVD rates (most recent administrative review): 17% to 167% depending on producer

These ranges shift after each annual administrative review — always verify current rates against the Federal Register before finalizing landed-cost projections.

Plus Section 301 (7.5-25% depending on HTS subheading) and MFN baseline.

Practical effect: Chinese aluminum foil is generally not competitive vs Korean, Vietnamese, Turkish, or Mexican origin in 2026. Most US foodservice distributors have shifted aluminum foil sourcing away from China.

Aluminum extrusions (HTS 7616, 7610)

Covered by: Aluminum Extrusions from China AD/CVD orders (multiple cases, active since 2010)

These primarily affect industrial aluminum (window frames, etc.) — most foodservice aluminum products are not classified as extrusions. Foodservice aluminum trays, lids, and roll foil are not generally covered by the extrusion AD/CVD orders.

Aluminum food trays and pans (HTS 7615.10.71, 7615.10.91)

Currently NOT covered by AD/CVD orders specific to this category (as of 2026)

This is the key procurement distinction: aluminum foodservice pans face Section 301 tariffs (typically 7.5-15%) but not the heavy AD/CVD stack that hits aluminum foil. Chinese aluminum pans remain a competitive supply source, though pricing has shifted upward with the Section 301 tariff and base aluminum commodity price increases.

There is ongoing industry debate about whether to expand AD/CVD coverage to aluminum food trays. Watch the Department of Commerce Federal Register for new petition filings.

How to read AD/CVD rates

A “rate” published in the Federal Register or accessible via Customs and Border Protection (CBP) has three components:

1. Manufacturer name — duties are assessed at the producer level, not the importer level. The same HTS code can have different rates depending on which Chinese factory made the product.

2. Rate value — expressed as a percentage of customs value (FOB at port of export)

3. Effective period — rates apply to products entered during a specific window; rates can change with administrative reviews

To verify current rates:

• Check the Department of Commerce ACCESS database
• Customs ruling letters via CROSS database
• Your import broker or distributor can pull current rates for specific suppliers

Implications for foodservice procurement

For operations buying Chinese-origin aluminum (foil specifically)

1. Verify current landed cost — duty stacks change after each administrative review. Pricing from 12 months ago may be stale.

2. Calculate true cost-per-comparable-spec — Chinese foil at 130%+ effective duty may not be cheaper than Korean or Vietnamese foil at MFN-only rates, even though the pre-duty FOB price is lower.

3. Manage volatility risk — administrative reviews can shift rates significantly. Annual contracts with price escalation clauses are common.

For operations sourcing non-Chinese aluminum

1. Korea, Vietnam, Turkey, Mexico are the major alternatives for aluminum foil. Korean foil is the highest quality benchmark.

2. Country-of-origin verification matters — products with Chinese aluminum content rolled or finished elsewhere may face country-of-origin determinations that pull them back into Chinese duty status. Reputable suppliers verify CoO documentation.

3. USMCA preferences — products of Mexican or Canadian origin meeting USMCA rules of origin may enter US duty-free. Mexican aluminum foil is increasingly competitive.

For aluminum pans (currently lower-duty)

1. Section 301 tariff applies but the heavier AD/CVD stack doesn’t (as of 2026)
2. Pricing is more stable than aluminum foil pricing
3. Watch for new AD/CVD petitions — the industry could expand AD/CVD coverage if domestic producers file new cases

What this means for menu and procurement planning

For operations heavy on aluminum-foil use (catering, takeout-heavy, BBQ/smoker operations):

• Budget conservatively — foil pricing has been volatile 2023-2026 and may continue shifting
• Lock in pricing where possible — annual or quarterly contracts with consistent pricing reduce exposure
• Track origin — Korean foil, Vietnamese foil, and Turkish foil have meaningfully different price points and quality
• Don’t assume Chinese = cheaper — landed cost after duty stack often exceeds Korean/Vietnamese prices

For operations using mostly aluminum pans (catering operations, hot-holding service):

• Pricing has been more stable than aluminum foil
• Section 301 is the main duty exposure (7.5-15% on Chinese pans)
• Watch for new AD/CVD petitions that could change this

Tracking AD/CVD changes

Three resources for ongoing tracking:

1. Federal Register — final determinations and review results published with effective dates
2. Department of Commerce ACCESS database — historical and current AD/CVD orders
3. US International Trade Commission (USITC) — petition tracking and investigation status

For procurement teams: most foodservice distributors have import brokers monitoring these. The practical approach is to ask your distributor for “current landed cost including all duties” rather than trying to assemble the duty stack independently.

Decision cheat sheet