The U.S. Department of Commerce has initiated antidumping (“AD”) and countervailing duty (“CVD”) investigations of Linear Hydraulic Cylinders and Parts Thereof from Canada, China, India, Mexico, and South Korea, effective September 8, 2026. The AD investigations cover imports from all five countries, while the CVD investigations cover imports from China, India, and Mexico.

The investigations stem from petitions filed on July 29, 2026 by the Hydraulic Cylinders Fair Trade Coalition and several U.S. producers. Commerce initially delayed its initiation determination after finding that the petitions did not clearly establish the required level of U.S. industry support and therefore polled the domestic industry. Based on the polling responses, Commerce determined that the statutory industry-support requirements were satisfied and that the petitions were filed on behalf of the domestic industry.

During that extended pre-initiation period, Commerce also continued to question the petitioners about the proposed scope, and in particular its inclusion of components used in third-country production. In a September 4, 2026 response to Commerce’s second supplemental questionnaire, the petitioners rejected several proposals from Commerce that would have narrowed the scope.

Petitioners Seek to Preserve Coverage After Third-Country Assembly

One of the most significant positions in the September 4 filing concerns hydraulic-cylinder components that are incorporated into finished cylinders in third countries.

Commerce asked the petitioners to consider language stating that covered steel barrels are within scope when imported or invoiced separately from a hydraulic cylinder. The petitioners declined, explaining that such language would narrow their intended scope. They stated that they also intend to cover steel barrels and piston rods from a subject country when those components are incorporated into hydraulic cylinders in a third country. The petitioners expressly gave the following example: a Chinese steel barrel incorporated into a hydraulic cylinder in Malaysia should remain subject to any China AD and CVD duties imposed as a result of the investigations when the finished cylinder enters the United States.

The practical consequence of the petitioners’ position is significant. Under their proposed approach, assembly of a hydraulic cylinder in a non-subject country does not remove covered subject-country barrels or piston rods from the investigations. Importers would be required to determine the origin of those components and apply the AD/CVD duties, if any, to those components’ relative value.

Petitioners Also Advocate Multi-Country Duty Treatment

The September 4 filing goes further where a covered component from one subject country is incorporated into a hydraulic cylinder produced in another subject country.

The petitioners use the example of a Chinese barrel incorporated into a hydraulic cylinder in Mexico. Under their proposed approach, the Chinese barrel would be subject to China AD/CVD duties, while the remaining value of the hydraulic cylinder produced in Mexico would be subject to any applicable Mexico AD/CVD duties.  The petitioners explain that this treatment is intended to prevent foreign companies from engaging in what they call “duty shopping” or “duty washing” by incorporating covered components from a country with higher dumping margins or subsidy rates into a cylinder produced in another subject country with lower rates.

Commerce’s initiated scope likewise retains broad third-country language. It provides that subject merchandise includes covered hydraulic cylinders, barrels, and rods that undergo “assembly or minor processing in a third country” in a manner that would not otherwise remove the merchandise from scope if performed in the country of manufacture.

This approach would create unusually complex duty calculations and origin-tracing requirements for hydraulic cylinders and components moving through multi-country supply chains.

Petitioners Refuse to Narrow the Chapter 84 Provision

The petitioners also rejected Commerce’s request to narrow the proposed downstream-product language.

Commerce specifically asked the petitioners to replace the broad reference to any equipment or parts of equipment classified in Chapter 84 with specified four- or six-digit HTSUS provisions covering equipment relevant to hydraulic cylinders. The petitioners declined. They argued that the machinery applications using hydraulic cylinders are too varied to identify on an HTS-specific basis and that Chapter 84 is “reasonably inclusive” of equipment and machinery likely to incorporate hydraulic cylinders. The resulting proposed scope continues to cover hydraulic cylinders and parts meeting the physical description when they are “attached to or imported with any equipment or parts of equipment classified in Chapter 84”, while specifying that only the hydraulic cylinder is covered by the scope.

Commerce retained that broad language in the initiated scope. The scope includes hydraulic cylinders and parts meeting the physical description when they are “attached to or imported with any equipment or parts of equipment classified in Chapter 84” of the HTSUS. Where a covered hydraulic cylinder is attached to or imported with Chapter 84 equipment, the scope specifies that only the hydraulic cylinder is covered.

The compliance implications are substantial. An importer entering finished Chapter 84 equipment, such as a forklift or excavator, will need to determine whether the equipment contains a covered hydraulic cylinder, the origin and producer of that cylinder or its covered components, the value attributable to the subject merchandise, and the applicable AD/CVD duty.

Broad Component Coverage Also Remains

The revised proposed scope continues to cover certain steel barrels and steel piston rods, as well as any part or component of a hydraulic cylinder attached to, assembled with, or shipped with a covered steel barrel or piston rod. It also includes attachments, parts, or components imported with, attached to, or invoiced with a hydraulic cylinder or covered barrel or rod, including mounting parts, connectors, pistons, rings, gaskets, seals, valves, sensors, hydraulic tubing, and hydraulic lines. Those ancillary items are excluded when imported or invoiced separately from a hydraulic cylinder. Commerce also asked the petitioners to consider adding diameter dimensions to distinguish covered piston rods from piston rods used in other applications. The petitioners declined, explaining that piston-rod diameter may vary significantly relative to cylinder bore size depending on the particular cylinder design.

Importantly, Commerce itself has now expressed “concerns related to the administrability of certain provisions in the proposed scope.” Commerce specifically identified the definition of covered steel barrels, including language concerning when a barrel has been processed to the point that its sole or predominant use is as a barrel for an in-scope hydraulic cylinder, as an outstanding issue. Commerce adopted that language for purposes of initiation but stated that it will continue evaluating the scope and may make additional modifications to clarify what products are covered or excluded.

How This Scope May Affect Your Company

Commerce has opened the formal scope-comment process. Initial scope comments are due by 5:00 p.m. ET on September 28, 2026, and rebuttal comments are due by 5:00 p.m. ET on October 8, 2026. Commerce specifically invited parties to address its administrability concerns and requested that factual information relevant to scope be submitted during this period. Scope comments must be filed simultaneously on the records of the concurrent AD and CVD investigations. The same September 28 and October 8 deadlines apply to comments and rebuttal comments concerning the physical product characteristics Commerce will use in its AD questionnaires for cost reporting and product comparisons.

Commerce has also begun respondent selection. For Canada, India, South Korea, and Mexico, Commerce released CBP import data under administrative protective order on September 8 and indicated that comments on the CBP data and respondent selection are due within three business days after publication of the initiation notice, with no rebuttal comments permitted. For China, Commerce will use quantity-and-value questionnaires for respondent selection, with responses due by 5:00 p.m. ET on September 22, 2026.

Companies whose merchandise or supply chains are implicated should review the initiated scope carefully and consider participating early. The scope-comment process is particularly important for companies that import or export downstream machinery or rely on multi-country supply chains and may not otherwise view themselves as participants in a hydraulic-cylinder investigation.