AD/CVD on hydraulic cylinders.

Product Scope and Import Activity

The proposed scope is broad and covers both completed linear acting hydraulic cylinders and certain cylinder components. Covered cylinders must have a steel barrel, a bore or inner diameter of at least 25.4 mm (one inch), and a retracted length of at least 101.6 mm (four inches). The scope extends to several configurations, including tie-rod, welded body, telescopic, plunger, rodless, single-acting, double-acting, ram-type, double-rod, spring-return, and other hydraulic cylinder designs.

Components are also subject to investigation. These include covered steel barrels, steel piston rods, and components attached to, assembled with, or shipped with a covered barrel or piston rod. Covered barrels generally include sufficiently processed welded or seamless steel tubes that have been precision machined and processed for predominant use as hydraulic cylinder barrels. Covered piston rods include qualifying solid or hollow steel bars or tubes that have been chrome plated or coated, cut to length, and machined for use as piston rods. Other parts including mounting components, pistons, rings, gaskets, seals, valves, sensors, and hydraulic tubing may be within the scope when imported with or attached to the covered cylinder, barrel, or rod. However, such miscellaneous parts are not covered when imported or invoiced separately from the hydraulic cylinder.

The scope is also significant for manufacturers and importers of larger machinery because qualifying hydraulic cylinders incorporated into equipment classified in Chapter 84 of the Harmonized Tariff System of the United States (HTSUS) remain subject to the investigation. In those circumstances, only the covered cylinder portion of the equipment is subject to the scope. Minor processing or assembly in a third country likewise does not necessarily remove otherwise covered merchandise from the investigations. The merchandise is currently associated with HTSUS subheadings 8412.21.0015, 8412.21.0030, 8412.21.0045, 8412.21.0060, 8412.21.0075, and 8412.90.9005; however, Commerce emphasizes that the written scope description, rather than the tariff classification alone, controls whether a product is covered.

The trade involved is substantial. For 2025, Commerce reported import values of approximately $263.0 million from Canada, $183.6 million from China, $92.6 million from India, $147.7 million from South Korea, and $185.7 million from Mexico. The Petitioners estimated 2025 imports at approximately 68.1 million pounds from Canada, 303.4 million pounds from China, 76.0 million pounds from India, 33.0 million pounds from South Korea, and 45.3 million pounds from Mexico.

Investigation Timeline and Potential Consequences

The U.S. International Trade Commission is conducting parallel injury investigations to determine whether there is a reasonable indication that the subject imports are materially injuring or threatening material injury to a U.S. industry. Commerce initially misstated the statutory timing for the ITC’s preliminary determination and issued a Federal Register correction on September 22. The corrected notice states that the ITC must make its preliminary determination within 25 days after receiving notice from Commerce that the investigations were initiated, rather than within 25 days of the filing of the petitions. A negative ITC determination for a particular country would terminate the investigation for that country.

Affirmative preliminary determinations were announced on September 30, 2026. The USITC determined that there is a reasonable indication that U.S. industry is materially injured by imports of linear hydraulic cylinders from Canada, China, India, Mexico, and South Korea. The imports from all five countries are alleged to be sold in the United States at less than fair value, while imports from China, India, and Mexico are also alleged to benefit from government subsidies. Commerce will move forward with its investigations and is scheduled to announce its preliminary determinations on November 12, 2026, for the CVD investigations, and on January 26, 2027, for the AD investigations, though those dates may be extended under the statute. Affirmative preliminary Commerce determinations could lead to suspension of liquidation and the collection of AD and/or CVD cash deposits on covered imports. Ultimately, permanent AD or CVD orders would require the necessary affirmative determinations from both Commerce and the ITC. Accordingly, importers, manufacturers, and companies incorporating hydraulic cylinders into Chapter 84 machinery should closely evaluate product specifications, origin, component configuration, and entry documentation as the investigations progress.

Need Help Assessing the Impact?

If your company imports hydraulic cylinders or machinery containing hydraulic cylinders from Canada, China, India, South Korea, or Mexico, now is a good time to evaluate whether your products may fall within the scope of these investigations and understand the potential duty implications.

Magnolia Global Trade Solutions can help you review product scope, tariff classification, country of origin, and import activity to assess potential exposure and prepare for the next steps. Contact us if you would like assistance navigating these investigations. www.MagnoliaGlobalTrade.com