CBSA Launches Dumping and Subsidy Investigations on Chinese Non-Structural Plywood (DONP2 2026)

The Initiation

CBSA opened dumping and subsidizing investigations under the Special Import Measures Act on April 10, 2026, covering decorative and other non-structural plywood originating in or exported from China. If you import this product description or file CADs on it, the clock is now running on a 105-day provisional period and a parallel injury inquiry at the Canadian International Trade Tribunal.

This is the second plywood SIMA case in recent years, hence the “DONP2” case shorthand. The first covered structural grades; this one targets decorative veneers, cabinet-grade panels, and other finished or semi-finished sheet goods that don’t meet CSA O151 structural certification. The scope language is still being refined, but if your supplier ships hardwood-faced plywood, melamine panels, or UV-cured decorative sheets from China, assume you’re in until CBSA publishes the final product definition in the Statement of Reasons.

What Happens Next

SIMA investigations follow a fixed calendar. CBSA has 105 days from initiation to decide whether to impose provisional duties. That puts the preliminary determination around late July 2026. If CBSA finds dumping or subsidizing, provisional duties apply immediately to all subject goods released after the decision date, not retroactively to April 10.

The Tribunal runs a separate injury inquiry in parallel. They have 120 days from initiation to issue a preliminary injury finding, then another window to make a final determination. If both CBSA and the Tribunal find dumping/subsidizing and material injury, the duties become final and stay in place for five years, subject to review.

Between now and late July, CBSA will issue requests for information to Chinese exporters, Canadian importers of record, and domestic producers. If you’ve imported the subject goods in the past two years, expect an RFI. The response deadline is tight, usually 37 days, and the penalty for non-response is that CBSA assigns you the highest calculated margin in the case. We’ve seen that margin hit 200% in past Chinese furniture and steel cases. Don’t ignore the RFI.

Provisional Duty Math and Your RPP Bond

Provisional duties are collected as cash security on every CAD filed after the preliminary determination. They do not appear on your K84 monthly statement as a payable; CBSA holds the cash in escrow until the final determination. If the case closes without final duties, you get a refund. If final duties are lower than provisional, you get the difference back. If final duties are higher, you owe the gap within 90 days of the final decision.

The problem for importers is cash flow. If CBSA sets provisional duties at 75% of the normal value and your landed cost per container is $35,000, you’re posting an extra $26,250 per box on top of your regular GST and tariff. That’s not a duty you can defer under Release Prior to Payment. Provisional SIMA security is due at the time of release, either as cash deposit or, if CBSA approves it, via a separate SIMA bond. Most importers don’t have a SIMA bond in place before the case opens, so the first few shipments are cash-on-release.

Your existing RPP bond does not cover provisional duties. If you want to keep importing without cash hits, you need to apply for a SIMA security account and post a bond sized to your expected import volume over the next 12 months. CBSA will calculate the bond requirement as a multiple of your trailing monthly imports times the provisional duty rate. For high-volume importers, that bond can run into seven figures. We help size and arrange those bonds, but the approval cycle is 4-6 weeks, so file early.

HS Classification and Scope Questions

The product scope will be defined in CBSA’s final Statement of Reasons, but the preliminary description covers plywood that is decorative or non-structural. Typical HS codes in scope include 4412.33, 4412.34, 4412.39, and 4412.94, though CBSA often writes the scope description independently of HS classification to prevent minor tariff shifts from evading the duty.

If your goods sit on the margin (for example, plywood that could be used structurally but is sold and imported as decorative), you need a scope ruling before the provisional determination. CBSA’s SIMA Measures unit will issue advance scope opinions during the investigation period, but only if you submit a detailed product specification, end-use declaration, and lab certification. If you wait until after provisional duties are imposed, you’re filing a request for exclusion retroactively, and CBSA’s backlog on those requests is long. We routinely see six-month turnarounds.

If you import plywood from other origins (Vietnam, Malaysia, Indonesia), watch for circumvention risk. CBSA has authority under section 9.2 of SIMA to extend duties to third countries if it finds that Chinese-origin panels are being transshipped or lightly processed to evade the measure. That usually takes 12-18 months after the original case, but if your Vietnamese supplier started operations in 2024 and ships the same panel thickness and finish as your old Chinese supplier, expect scrutiny.

Importer of Record Responsibilities

If you’re the IOR on a CAD covering subject goods, you have three obligations during the investigation:

1. Respond to any RFI CBSA sends. The questionnaire will ask for transaction-by-transaction import data, supplier names, landed costs, and resale prices. If you’re an NRI, make sure your Canadian agent or broker has access to your accounting records, because CBSA will not extend deadlines for cross-border coordination issues.

2. File accurate normal values if you’re claiming a specific exporter rate. If your Chinese supplier cooperates with the investigation and receives an individual margin, you can claim that rate on your CADs instead of the country-wide residual rate. But you must file the exporter’s CBSA-assigned normal value code and maintain proof that the goods actually came from that mill. If your supplier subcontracts production or sources veneer from a second mill, the individual rate may not apply.

3. Track your provisional duty payments and reconcile them when the final determination is published. CBSA does not automatically credit your account. You file a request for refund or pay the balance owing within 90 days. Miss that window and you forfeit the adjustment.

Warehouse and Release Timing

If you operate on a PARS or RMD release model and your plywood arrives after provisional duties are imposed, your broker cannot file the CAD for release until you’ve either posted cash security or confirmed that your SIMA bond is active and sufficient. That means longer dwell time at the port or in a sufferance warehouse while you arrange payment. If your inbound flow runs through Montreal, our FENGYE warehouse in Lachine handles sufferance storage under CBSA license, but even there, the goods sit until the security clears.

If you’re bringing in consolidations where only some SKUs are subject goods, make sure your commercial invoice and packing list break out the line items clearly. CBSA will apportion duties by line, and if the documentation is ambiguous, they’ll apply the highest rate to the entire shipment and leave you to file a re-determination later.

What to Do Right Now

If you import decorative or non-structural plywood from China, pull your import history for the past 24 months and confirm which HS codes and suppliers are in play. Cross-check the preliminary product description in CBSA’s Statement of Reasons when it’s published, usually within two weeks of initiation. If you think you’re in scope, talk to your broker about an advance scope ruling and start the SIMA bond application process before the preliminary determination lands in July.

If you’re not sure whether your goods are structural or decorative, get lab certification now. A CSA O151 structural cert will keep you out of scope; a generic mill cert will not.

We file CADs on plywood every week and we’ve been through three prior SIMA cases on Chinese wood products. If you want to walk through your specific supplier and cost structure before provisional duties hit, get in touch.

Source: CSCB