How India's Electrodes Beat the Ninety-Day Clock

In December, India shipped the United States 34 tonnes of furnace electrodes. In June it shipped 3,639.

A hundredfold swing in six months is not a demand story.

What moved was a petition. Resonac Graphite America and Tokai Carbon GE filed it on February 24, into a line that had already gone quiet, and the tonnes came back hard on the far side of the filing (chart below).

Commerce noticed. On Wednesday it published preliminary affirmative determinations of critical circumstances in both large diameter graphite electrode cases, India and China, which is the finding that makes a remedy retroactive.

"If the surge is what proves the case, where exactly does the clock start?"

The Volume Test, Run on Public Data

Critical circumstances is a volume test before it is anything else. 19 CFR 351.206(h)(2) says imports are not massive unless they rose by at least 15 percent over an immediately preceding period of comparable duration, and paragraph (i) fixes that period as the one "beginning on the date the proceeding begins and ending at least three months later."

The proceeding began on the petition, February 24. So the windows are December through February against March through May.

India sent 385,348 kg in the first window and 5,526,685 kg in the second.

That is 14.3 times, or +1,334 percent, against a threshold of fifteen. China on the same windows ran +138 percent.

Neither finding is a close call, and both are visible in data anyone can pull.

One honest caveat before the numbers get used in anger: HS 8545.11 is the public six-digit line, and the cases reach only the 8545.11.00.20 split, electrodes exceeding 425 mm in diameter. The six-digit line carries the small-diameter split too, so it is a proxy that runs wide.

Ninety Days From What?

Section 733(e)(2) does not reach back to the surge. It reaches back to the later of two dates: ninety days before suspension of liquidation was first ordered, or the day the initiation notice published.

The initiation published March 20. Ninety days before Wednesday's preliminary determination is July 2.

The statute takes the later date, so July 2 is where cash deposit liability begins.

India moved 8,657,878 kg across April, May and June. That is 31.9 percent of everything it shipped on this line in all of 2025.

All of it cleared customs before the window opened.

The Bill Is on the Smaller Column

July is the most recent month published, and it comes with customs value but no weight. On value it reads like this:

Mexico $8.14m, 40.1 percent of the month, subject to neither case.
India $4.59m, 22.6 percent, now carrying 9.88 percent if it came from Graphite India, 1.15 percent from HEG, 3.53 percent from anyone else.
China $1.10m, 5.4 percent, carrying 95.61 percent, a China-wide rate built on adverse facts available because no respondent earned a separate rate.

Run the rates across July and the Chinese column costs roughly $1.06m against India's $162,000. A quarter the value, six and a half times the bill.

If you are reconciling entries back to July 2, that is the ratio to budget against. The Indian exposure is a rounding error on a drum of working capital; the Chinese exposure is most of the invoice.

Final Thoughts

The substitution has already happened, and it went somewhere awkward. Mexico was 12.1 percent of the half-year book by weight in 2025 and 32.2 percent in 2026, and 40.1 percent of July's customs value.

The one origin on this line that carries no deposit is the one taking the volume.

GrafTech's board approved the permanent closure of its Monterrey graphite electrode and pin plant on August 6, told the workforce on August 31, and expects production to conclude early in the second quarter of 2027. That plant sits on the other end of the Mexican column.

So the lane around the two dutiable origins has about two quarters left in it, and Commerce has until mid-February to make the Indian rates final.

Thanks for reading.