New Antidumping Duty and Countervailing Duty Petitions on Certain Linear Hydraulic Cylinders and Parts Thereof from Canada, China, India, Mexico, and South Korea

At a Glance

• A group of US producers filed antidumping and/or countervailing duty petitions on certain linear hydraulic cylinders and parts thereof from Canada, China, India, Mexico, and South Korea.
• Investigations related to these petitions could result in increased prices and/or decreased supply of linear hydraulic cylinders and parts thereof.
• The US Department of Commerce is expected to begin investigations on August 18, 2026.

On July 15, 2026, antidumping (AD) and/or countervailing duty (CVD) petitions were filed on certain linear hydraulic cylinders and parts thereof from Canada (AD only), China (AD & CVD), India (AD & CVD), Mexico (AD & CVD), and South Korea (AD only). The petitions were filed by Aggressive Hydraulics Inc., Hol-Mac Corporation, Ligon Hydraulics, Prince Manufacturing Corporation, PTC Alliance LLC, Rosenboom Machine and Tool Inc., Scot Industries Inc., Stillwell Inc., and Texas Hydraulics Inc. (collectively "Petitioners").

The US AD law imposes special tariffs to counteract imports that are sold in the United States at less than "normal value." The US CVD law imposes special tariffs to counteract imports that are sold in the United States with the benefit of foreign government subsidies. For AD/CVD duties to be imposed, the US government must determine not only that dumping and/or subsidization is occurring, but also that there is "material injury" (or threat thereof) by reason of the dumped and/or subsidized imports. Importers are liable for any potential AD/CVD duties imposed. In addition, these investigations could impact purchasers by increasing prices and/or decreasing supply of welded stainless line and pressure pipe.

Scope Impact on Downstream Merchandise Containing Hydraulic Cylinders

For a detailed description of the product scope proposed by the Petitioners, please see the proposed product scope language at the end of this client alert.

However, we note that the proposed scope includes coverage of hydraulic cylinders even when incorporated into downstream merchandise. The scope language specifically calls out machinery classified in Chapter 84 of the Harmonized Tariff Schedule, but we note that any downstream merchandise that includes a hydraulic cylinder otherwise meeting the description below would likely be covered. The petition states that welded body hydraulic cylinders dominate the mobile hydraulic equipment market, such as construction equipment (e.g., excavators, bulldozers, and road graders), and material handling equipment (e.g., forklift trucks, telehandlers, and lift gates).

Linear hydraulic cylinders have many applications and can be used in any machine where significant forces are required to move a part. Common industrial applications for hydraulic cylinders are in: (1) elevators, lifts, and jacks; (2) manufacturing machinery that requires pushing, pulling, shearing, compacting, or bending of materials; (3) mobile equipment such as dump trucks, garbage trucks, lift trailers, construction equipment, earth-moving equipment (e.g., backhoes, bulldozers, road graters), and agricultural equipment; and (4) material handling equipment (e.g., forklift trucks, telehandlers, and lift gates), among many other uses.

While the scope provides that only the hydraulic cylinder component in the downstream merchandise is covered, there are significant administrative and compliance hurdles that can arise with respect to requiring importers to report a single component value in a downstream good. Parties have the opportunity to raise scope concerns before the US Department of Commerce (DOC).

Estimated Dumping Margins

The Petitioners allege the following dumping margins:

• Canada: 248.33% to 744.85%
• China: 125.77% to 511.41%
• India: 102.59% to 461.46%
• Mexico: 60.16% to 163.42%
• South Korea: 78.70% to 149.33%

The Petitioners also allege subsidies with respect to subject imports from China, India, and Mexico, although the CVD petitions do not quantify the alleged net subsidy margins.

Estimated Schedule of Investigations

The following is an estimated schedule of investigations by the DOC and the US International Trade Commission (ITC):

Product Scope Proposed in Petition

Please note that this section was not written by our authors but is taken verbatim from the petition.

The scope of these investigations covers certain linear acting hydraulic cylinders (also known as hydraulic power engines) and certain barrel and piston rod components and assemblies of linear acting hydraulic cylinders. Covered linear acting hydraulic cylinders have barrels made of steel, a bore size (inner diameter) of 25.4 mm (one inch) or more, and a return (retracted) length of 102.1 mm (four inches) or more. For purposes of this scope, the return (retracted) length is the overall end-to-end measurement of the hydraulic cylinder unit when in the retracted position. The scope covers all such linear acting hydraulic cylinders meeting the physical description above, including but not limited to the following linear hydraulic cylinder designs: tie-rod, welded body, telescopic, plunger, rodless, differential, position sensing, single acting, double acting, displacement, ram type, piggy-back, double rod, rod-fed, and spring return linear acting hydraulic cylinders. All covered cylinders are hydraulically activated. The incorporation of a spring into the design of a hydraulic cylinder otherwise meeting the description above does not exclude a product from the scope.

The scope also covers (1) steel barrel components, (2) steel piston rod components, and (3) any component of a linear hydraulic cylinder that is attached to, assembled with or shipped with a covered steel barrel or a covered piston rod.

Covered barrel components include processed welded or seamless steel tubes four inches or more in length with an inner diameter of one inch (25.4 mm) or more, that have had their inner diameter precision machined (such as through honing or skiving and burnishing), and have otherwise been processed to the point of having as their sole or predominant use a barrel for an in-scope hydraulic cylinder. Such processing may include but is not limited to cutting-to-length, end-finishing (e.g., machine-threading, chamfering, etc.), port drilling, and the addition of weldments, or any combination thereof.

Covered piston rods are solid or hollow bars or tubes that have been hard chrome plated or chrome coated, cut to length, and machined to be a piston rod.

Included in the scope are any attachments, parts, or components that are imported with, attached to, or invoiced with a linear hydraulic cylinder or covered component, including but not limited to cylinder mounting parts (e.g., flanges, trunnions, devises, lugs, etc.), connectors attached to pistons or piston rods, pistons, or hydraulic tubing or hydraulic lines (regardless of material) such as for connections to a hydraulic pump.

Also included in the scope are any hydraulic cylinders meeting the physical description above attached to or imported with any equipment or parts of equipment classified in Chapter 84 of the Harmonized Tariff Schedule of the United States. When a hydraulic cylinder is attached to or imported with any equipment or parts of equipment classified in Chapter 84 of the Harmonized Tariff Schedule of the United States, only the hydraulic cylinder is covered by the scope.

Subject merchandise also includes hydraulic cylinders, components, and subcomponents that undergo assembly or further working in a third country in any manner that would not otherwise remove the merchandise from the scope of the investigations if performed in the country of manufacture of the in-scope hydraulic cylinder. Subject merchandise also includes hydraulic cylinders, components, and subassemblies that are attached to any equipment or parts of equipment classified in Chapter 84, as discussed in the immediately preceding paragraph, if such attachment occurs in a third country.

Excluded from the scope are pneumatic power engines and motors.

Also excluded from the scope are hydraulic cylinders and parts that are covered by preexisting antidumping ("AD") and countervailing duty ("CVD") orders. However, to the extent such AD or CVD orders are revoked, the hydraulic cylinders would be subject merchandise.

All products that meet the written physical description are within the scope of the investigations unless specifically excluded or covered by the scope of an existing order.

The products subject to these investigations are currently classified in the Harmonized Tariff Schedule of the United States (HTSUS) under statistic reporting numbers 8412.21.0015, 8412.21.0030, 8412.21.0045, 8412.21.0060, 8412.21.0075, and 8412.90.9005. The HTSUS subheadings above are provided for convenience and Customs purposes only. The written description of the scope of these investigations is dispositive.