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On September 25, 2024, the United States initiated anti-dumping and countervailing duty investigations on corrosion-resistant steel (CORE steel) imported from Vietnam (Case Numbers: A-552-843 and C-552-844).
The investigated product is CORE steel under HS codes 7210.30, 7210.41, 7210.49, 7210.61, 7210.69, 7210.70, 7210.90, 7212.20, 7212.30, 7212.40, 7212.50, 7212.60, and 7226.99.
Countries under investigation include Canada, Mexico, Brazil, the Netherlands, Taiwan, Turkey, the United Arab Emirates, Vietnam, Australia, and South Africa. These nations are among the top 10 exporters of the investigated product to the United States, accounting for 75% of total U.S. imports in 2023.
From 2021 to 2023, Vietnam exported $626 million, $751 million, and $242 million worth of the investigated product to the United States, ranking third among the 10 countries under investigation, following Canada and Mexico. Accordingly, the anti-dumping investigation period is the first six months of 2024, while the countervailing duty investigation covers 2023. The injury investigation period is three years (2021-2023).
The alleged dumping margin for Vietnam is 195.23%, the highest among the 10 countries under investigation and higher than the margin proposed by the petitioner.
As the U.S. considers Vietnam a non-market economy, the Department of Commerce (DOC) plans to use surrogate values from the United States and Morocco, which were recently updated in the DOC’s latest list of surrogate countries for Vietnam. (Typically, in trade remedy investigations, Indonesia has been a common surrogate country used by the U.S. for Vietnam.)
Parties have 30 days to submit comments on the surrogate country and surrogate values before the DOC issues its preliminary determination.
Regarding the countervailing duty investigation, the DOC has not yet announced any alleged subsidy margins for Vietnam. However, the DOC has initiated investigations into 26 subsidy programs from the Vietnamese government, classified into five different groups, as detailed in the DOC’s announcement.
In the coming period, parties involved in the dual investigations will need to respond to the DOC’s questionnaire. The deadline for submitting responses is October 9, 2024, with the possibility of an extension. Companies that did not receive the Quantity and Value (Q&V) questionnaire but exported the investigated product to the U.S. during the investigation period should proactively contact the DOC to register as an interested party and respond to the questionnaire to receive separate duty rates, avoiding unfavorable nationwide rates.
Notably, in the countervailing duty investigation on CORE steel, the DOC will also issue a separate questionnaire for the Vietnamese government. The typical response period is 30 days from the date of the initial questionnaire issuance, though extensions may be requested. The DOC may issue supplemental questionnaires with shorter response deadlines.
The DOC is expected to issue its preliminary determination for the anti-dumping investigation on February 12, 2025, and for the countervailing duty investigation on November 29, 2024.
To safeguard their legitimate interests, related manufacturers and exporters should familiarize themselves with U.S. regulations and review procedures and proactively contact experienced Vietnamese law firms specializing in anti-dumping and trade remedy matters for timely support.
The announcement and the Quantity and Value Questionnaire can be viewed here.
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ASL LAW is the top-tier Vietnam law firm for Anti-dumping & countervailing. If you need any advice, please contact us for further information or collaboration.
