Volume I, No. XXVI
Canadian softwood lumber duties fall by a third in the 2024 review, while the Section 232 tariff stays on top
Final results published October 19 cut the combined antidumping and countervailing duty deposit for most Canadian lumber exporters from 35.16 to 24.75 percent. The annual review leaves the 2018 orders in place, and the 10 percent national security tariff of October 2025 still applies on top.
For most Canadian sawmills shipping to the United States, the cash deposit on softwood lumber fell on October 19 from 35.16 percent of entered value to 24.75 percent. That is the sum of two rates the Commerce Department set in the final results of its 2024 administrative reviews: 10.64 percent in antidumping duties and 14.11 percent in countervailing duties for the companies it did not examine individually1,2. A year earlier the same two figures stood at 20.53 and 14.63 percent6,7. The decline is real money for importers. It is also a reminder that the lumber orders, now in their ninth year, are not a fixed tariff but a rate recomputed each year from the prior year’s sales and subsidies, and that since October 2025 they have run alongside a second instrument, the 10 percent Section 232 duty, that is not recomputed at all8.
The instrument: an annual review that rewrites the rate
The orders date from January 3, 2018, when Commerce published the antidumping and countervailing duty orders on certain softwood lumber products from Canada1,2. In December 2023 the International Trade Commission determined in its first five-year review that revoking them would be likely to lead to continuation or recurrence of material injury to the U.S. industry within a reasonably foreseeable time, which kept both in force10.
Between sunset reviews, the working instrument is section 751(a) of the Tariff Act of 19301,2. U.S. duty collection on trade remedy orders is retrospective. An importer posts a cash deposit at entry; a year or more later Commerce reviews the period, calculates what was actually owed, and instructs U.S. Customs and Border Protection to liquidate the entries at that assessment rate1. The same results then reset the deposit rate for future shipments1,2. Each annual review therefore does two jobs at once: it settles the past and prices the next year.
The review is also selective. Commerce examines a few large exporters and gives everyone else a rate built from theirs. For the antidumping review, the regulation at 19 CFR 351.109(g) directs Commerce to follow the method for an all-others rate in an investigation, a weighted average of the examined companies’ margins excluding zero, de minimis and facts-available rates1. The countervailing duty review uses the parallel subsidy rule in section 705(c)(5)(A)2. A company that is never reviewed keeps the rate from the original investigation, 6.04 percent for dumping and 14.19 percent for subsidies1,2.
The mechanism: three mills, two cases and a period of review
The period of review is calendar 2024 in both cases1,2. In the antidumping review Commerce examined three companies, Canfor, Resolute and West Fraser, and assigned the average to 220 others; it rescinded the review for 105 companies, 93 because review requests were withdrawn and 12 because they had no suspended entries to liquidate1. The subsidy review looked at only two respondents, Resolute and West Fraser, and set a rate weighted from theirs for 215 other companies2.
What are the final 2024 rates for Canfor, West Fraser and Resolute?
| Company | Antidumping (%) | Countervailing (%) | Combined (%) |
|---|---|---|---|
| Canfor | 17.00 [1] | 14.11, non-selected [2] | 31.11 |
| Resolute | 13.13 [1] | 12.42 [2] | 25.55 |
| West Fraser | 4.71 [1] | 15.31 [2] | 20.02 |
| Non-selected companies | 10.64 [1] | 14.11 [2] | 24.75 |
The final numbers moved little from April’s preliminary results, when the non-examined antidumping rate was 10.66 percent and the subsidy rate 14.17 percent3,4. The large movement is against the 2023 review. Canfor’s dumping margin there was 35.53 percent as first published and 35.47 percent after a correction for ministerial errors, and West Fraser’s was 9.65 percent5,6. Canfor was a subsidy respondent in 2023 at 12.12 percent; in the 2024 review it falls into the non-selected group2,7.
The new deposit rates apply to lumber entered for consumption, or withdrawn from warehouse, on or after October 19, 20261,2. Commerce said it would send assessment instructions to CBP for 2024 entries no earlier than 41 days after publication1,2. For companies whose review was rescinded, 2024 entries will be assessed at the deposit rate in force when they entered1. Importers also receive the standard warning: a reimbursement certificate must be on file before liquidation, or Commerce may presume reimbursement and double the antidumping duty1.
What did the parties argue about?
The subsidy case turns on stumpage, the fee provincial governments charge to harvest Crown timber. The list of issues Commerce resolved runs to dozens of comments, many of them about whether private standing timber prices in Nova Scotia are a fair benchmark for Crown timber in Alberta, Ontario and Québec, given differences in forest, species and tree diameter2. Other comments address British Columbia’s log export restraint, electricity purchase agreements and provincial grant programs2. The dumping case is narrower and more technical, centered on cost adjustments, permanent closure costs and affiliated electricity and log purchases1.
The effect: who pays, and the duty that does not move
The deposits are paid by U.S. importers of record, and for 2024 entries the review is a settlement: whatever was deposited at entry, the duty finally owed is the 2024 assessment rate1,2. On the other side stands the petitioner, the Committee Overseeing Action for Lumber International Trade Investigations or Negotiations, which has also carried the litigation over earlier segments6,12.
The Section 232 duty changes the arithmetic. Proclamation 10976, signed on September 29, 2025, imposed a 10 percent ad valorem duty on softwood timber and lumber listed in its Annex I from October 14, 2025, and stated that the tariffs are “in addition to any other duties, taxes, fees, exactions, and charges” except as the proclamation provides8. Its country caps cover the United Kingdom, the European Union and Japan, not Canada8. A non-selected Canadian mill’s lumber thus bears 24.75 percent in trade-remedy deposits plus the 10 percent national security duty. The Section 232 rate is set by proclamation, not by review, and the President’s December 31, 2025 amendment left the lumber rate at 10 percent while delaying higher rates on upholstered furniture, kitchen cabinets and vanities to January 1, 20279.
The two instruments rest on different findings. The orders answer dumping and subsidies found company by company1,2. Proclamation 10976 rests on the Commerce Secretary’s finding that wood product imports “threaten to impair the national security,” and its stated aim is domestic capacity8. Canadian exporters also face the separate section 338 duties this journal examined in earlier coverage. The October 19 results leave the Section 232 layer untouched1,2,8.
The longer view: a dispute litigated in two forums at once
Each annual result in this case is also a lawsuit in waiting, and the older ones are still being decided. On October 8 a USMCA binational panel under Article 10.12, which on request provides binding review of a trade remedy determination, affirmed in part and remanded in part Commerce’s countervailing duty review covering 2017 and 201811. In August Commerce brought D&G/Portbec back under the subsidy order at 1.05 percent after a case that began with a 2019 expedited review, passed through a Court of International Trade ruling vacating the expedited review rule, a 2023 Federal Circuit reversal and four remand redeterminations, and ended in a trade court judgment on July 21, 202612.
The same proclamation that put the 10 percent rate on lumber gave the Secretary until October 1, 2026 to report on hardwood timber and lumber imports so the President could decide whether to add a duty there8. It also told the Trade Representative to pursue agreements on wood products, with tariff adjustments tied to their outcome8.
The calendar for the 2024 review is short. Commerce intends to disclose its subsidy calculations within five days of publication2, ministerial error allegations follow, and after the 2023 review that process lowered Canfor’s margin by 0.06 points and the non-selected rate by 0.03 points6. Separately, the October 8 panel decision sends parts of the 2017-2018 subsidy review back to Commerce, so a rate set eight years ago is still open while the 2024 rate takes effect11.