Six of Seven Citric Acid Reviews Never Moved

Commerce has put a dumping rate on Sucroal S.A. eight times since 2018.

Seven of those are finished proceedings carrying both a preliminary number and a final number, and in six of them the two numbers match to the hundredth of a point.

Identical. 4.59 and 4.59. 2.50 and 2.50. 6.10 and 6.10. 0.00 and 0.00. 4.69 and 4.69.

That is a strange way for a proceeding with case briefs, rebuttal briefs and a statutory comment round to behave.

Yesterday the eighth rate landed. Sucroal's preliminary weighted-average margin for the July 1, 2024 to June 30, 2025 review period is 3.25 percent, and every preliminary and final this order has produced sits in one frame (chart below).

Sucroal is the only Colombian producer with a rate. The order covers Belgium, Colombia and Thailand together, it dates to July 2018, and the investigation rate was 28.48 percent.

That figure never went away. It is still the all-others rate, and Commerce says it intends to liquidate any entry Sucroal did not know was destined for the United States at exactly that number.

The one that moved went up

The 2020-2021 review is the exception on the chart, and the direction matters more than the fact.

Commerce preliminarily put Sucroal at 1.14 percent in July 2022. The final results in November came back at 3.58 percent, which is 2.44 points higher and roughly 3.1x the preliminary.

So the record is six reviews that did not move and one that tripled. No completed review of this order has ever moved down between the preliminary and the final.

Treat 3.25 as a floor on the 2024-2025 entries. The distribution of outcomes around it is one-sided, and eight years of this docket says so.

Nobody had written "adverse" in this docket before

Something is genuinely different about this review, and it is in the methodology paragraph rather than the margin table.

Commerce says it "preliminarily relied on partial adverse facts available under sections 776(a) and (b) of the Act."

Search the six earlier preliminary notices, the six earlier final results and the 2018 order itself and the phrase does not appear once. This is the first adverse inference in the proceeding's history.

It arrives alongside the other first: at the February request of Archer Daniels Midland, Cargill and Primary Products Ingredients Americas, Commerce verified Sucroal's information in July 2026 under section 782(i)(3).

A verified respondent that still draws partial AFA is the fact pattern worth watching here. The six quiet reviews behind it had neither.

What 3.25 actually does to your entries

The number published yesterday changes nothing you pay today. Worth being precise about which clock each piece runs on:

• Your current deposit is 4.69 percent. That rate took effect for entries on or after April 8, 2026, the publication date of the 2023-2024 final results. The deposit moves to whatever this review's final says, effective its own publication date.
• The 2024-2025 entries are already made and are not yet liquidated. CBP assesses them on importer-specific rates: total dumping calculated on each importer's examined sales divided by that importer's total entered value, and a per-unit rate where entered value was not reported.
• Below 0.50 percent the deposit goes to zero. That is the de minimis threshold in 19 CFR 351.106(c)(1), and the 2022-2023 review actually hit it at 0.00.
• Case briefs are due November 9, twenty-one days from publication, with rebuttals five days later. Commerce has modified the usual deadline, so that date is the one in the notice.

One more thing about the clock. This preliminary was due in the ordinary course well before now: Commerce tolled every deadline by 47 days for the November 2025 appropriations lapse, then by 21 more for the ACCESS filing backlog that followed, then took a 120-day statutory extension. The preliminary deadline became October 7, 2026, and the notice published on the 19th. Entries from the summer of 2024 are being priced in the autumn of 2026.

Final Thoughts

Colombia is a small line in the US citric acid book. On 2025 trade data it is $35.9m of a $369.7m import total and 19,074 tonnes of 228,075, call it a tenth by value, against Canada and Thailand at better than four fifths between them.

A tenth of the book is still the part of the book that a lot of buyers use as their price check on the other nine tenths, and Colombian material has been landing at $1.88/kg against a $1.62/kg world average. A rate that swings between zero and six points on an input priced like that is not noise in the quote you get next quarter.

The useful read is the one the chart makes. Six of seven times, the number you see in the preliminary is the number you will be assessed on, so the window to argue about it closes on November 9 rather than next spring.

The seventh time, waiting cost the importer 2.44 points.

Thanks for reading.