How a sunset review works
Every US antidumping (AD) and countervailing duty (CVD) order expires after five years unless it is reviewed and continued. That review is the "five-year" or "sunset" review. This page walks the clock with the words of the regulation, so each deadline below can be checked against 19 CFR 351.218 — and against the live cases on the home page.
Who decides what
Two agencies run each review. Commerce (the International Trade Administration) asks whether revoking the order would be likely to lead to continuation or recurrence of dumping or subsidies. The US International Trade Commission (USITC) asks the injury question — whether revocation would be likely to lead to continuation or recurrence of material injury to a US industry. The USITC's own explainer puts it this way:
…requiring the Department of Commerce and the USITC to conduct reviews no later than five years after an antidumping or countervailing duty order is issued to determine whether revoking the order would be likely to lead to continuation or recurrence of dumping or subsidies (Commerce) and of material injury (USITC).
Source: USITC, Understanding Five-Year (Sunset) Reviews (archived 2026-10-22).
The clock
- T−30 days · initiation
Commerce must publish a notice of initiation no later than 30 days before the order's fifth anniversary date. For orders continued after an earlier review, the clock anchors to the fifth anniversary of the Commission's last continuation determination.
No later than 30 days before the fifth anniversary date of an order or suspension of an investigation (see section 751(c)(1) of the Act), the Secretary will publish a notice of initiation of a sunset review
19 CFR 351.218(c)(1). Initiations are grouped monthly — that is the monthly "Initiation of Five-Year (Sunset) Reviews" notice, and the reason a register like this one can be built.
- T+15 days · notice of intent to participate
A US domestic interested party that wants the order kept must say so quickly:
…not later than 15 days after the date of publication in the Federal Register of the notice of initiation, file a notice of intent to participate in a sunset review with the Secretary.
19 CFR 351.218(d)(1)(i). This short window is why missing a month's notice matters.
- T+30 days · substantive response
A complete substantive response to a notice of initiation, filed under this section, must be submitted to the Department not later than 30 days after the date of publication in the Federal Register of the notice of initiation.
19 CFR 351.218(d)(3)(i).
- Adequacy decision
Commerce then decides whether the domestic response is adequate enough to keep the review alive:
…the Secretary normally will conclude that domestic interested parties have provided adequate response to a notice of initiation where it receives a complete substantive response under paragraph (d)(3) of this section from at least one domestic interested party.
19 CFR 351.218(e)(1)(i)(A).
- No domestic response → revocation within 90 days
If no domestic interested party files a notice of intent to participate, the order dies on a statutory timetable — Commerce notifies the ITC in writing (normally within 20 days of initiation publication) and must issue a final determination revoking the order no later than 90 days after the initiation notice. This is the "expedited" path that produces most of the revocations you can follow on the Results page.
19 CFR 351.218(e)(1)(i)(C); the revocation notices themselves cite this paragraph, e.g. the 2026 revocation of the CVD order on carbazole violet pigment 23 from India (91 FR 51149).
- Adequate response → full review and the ITC injury question
When the domestic response is adequate, Commerce reviews whether dumping or subsidies would be likely to continue or recur, and the USITC conducts its injury review under the Commission's own statutory timetable. A full review ends with Commerce's determination — "revocation … would be likely to lead to continuation or recurrence" — and the order continues. In 2026 so far, 130 of the 135 result notices did exactly that.
What it means for importers
If you import subject merchandise, a review that ends in continuation keeps the cash-deposit and liquidation regime in place; a revocation ends it from the notice's effective date. The revocation notices state the boundary explicitly — entries before the effective date of revocation remain subject to suspension of liquidation and duty deposit requirements, and Commerce may still conduct administrative reviews on those entries.
This site describes what the regulation and the notices provide; it is not legal advice. For positions to take in a specific proceeding, the proceeding's Federal Register notices and counsel are the places to go.
What it means for exporters
If your product is subject to an AD/CVD order, the sunset calendar is a chance to watch: when a review starts and no US domestic party shows interest, the order is revoked on the 90-day clock — the order simply ends. When domestic parties do participate, the order is normally continued. Exporters and foreign governments can participate as respondents; the substantive response deadline is the same 30-day clock as above.
Where to watch
Commerce's machinery publishes on a monthly rhythm: an advance notification lists the reviews scheduled for initiation next month, and the initiation notice opens them. The home page carries both, plus the year's results so far — every line linked to the underlying Federal Register document.