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October 2025, question 80
Valuation, Appraisement and Duty Assessment · Antidumping and countervailing duties
Bebe Mattresses (Bebe), an Italian importer and manufacturer in Italy of toddler bed and baby crib cotton mattresses (mattresses), imported 140 toddler bed mattresses from WeSew, a manufacturer, in China with a value of $2,000.00 US. Bebe repackaged the toddler bed mattresses into individual plastic bags imprinted with Bebe’s logo. Bebe shipped the 140 toddler bed mattresses and 80 baby crib mattresses manufactured by Bebe in Italy to Upscale Baby Furniture, a buyer in the United States. Bebe invoiced Upscale $4,200.00 for the 140 toddler bed mattresses and $1,700.00 for the 80 baby crib mattresses. Which of the formulas below yields the estimated anti-dumping / countervailing duty (AD/CVD) deposit due for the following merchandise? The “all other companies” AD/CVD rates apply. The rate is ad valorem. The possible cases, countries, and rates are: • A-475-845-000; Italy; 257.06% • A-570-092-000; China; 1731.75% • C-570-128-000; China; 97.78% In the formulas below, the “x” stands for “multiplied by.”
- ($1,700.00 x 2.5706) + ($4,200.00 x 2.5706)
- ($1,700.00 x 257.06) + ($2,000.00 x 1731.75) + ($2,000.00 x 97.78)
- ($1,700.00 x 2.5706) + ($4,200.00 x 17.3175) + ($4,200.00 x .9778)
- ($1,700.00 x 257.06) + ($4,200.00 x 1731.75) + ($4,200.00 x 97.78)
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CBP's answer: C. C: ($1,700.00 x 2.5706) + ($4,200.00 x 17.3175) + ($4,200.00 x .9778)
Antidumping and countervailing duties are assessed under Part 351 (159.41 and 159.47). The Italian-made crib mattresses ($1,700) are covered by the Italy case at 257.06 percent, written as 2.5706. The toddler mattresses were made in China, and Bebe only repackaged them, which is not a substantial transformation (134.1(b)), so they stay Chinese and are subject to both China cases, 1731.75 percent (17.3175) and 97.78 percent (.9778), on their $4,200 value to the buyer rather than the $2,000 purchase price. That is the formula in C; the other choices use whole-number percentages or the wrong values.
Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” 19 CFR 134.1(b)
Antidumping duties will be assessed in accordance with part 351, chapter III of this title. 19 CFR 159.41
Search for: Further work or material added to an article in another country must effect a substantial transformation
CBP's key cites: 19 CFR 159.41; 19 CFR 159.47
Question and key from CBP's October 2025 exam and answer key. The walk-through is ours; quotes are from the pinned editions in the reference viewer (HTSUS 2026 Basic, 19 CFR 2025 edition).