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On March 18, 2025, the USA Department of Commerce (DOC) officially initiated an antidumping (AD) investigation on semitrailers and related assemblies imported from Vietnam.
Scope of Investigation
The investigation covers certain types of semitrailers and related assemblies, primarily under HS codes 8716.39.0090, 8716.90.5060, and potentially 8716.90.5010. The case number assigned by DOC is A-552-849. The petition was filed by the USA Trailer Manufacturers Coalition.
According to the USA International Trade Commission (ITC), the export value of semitrailers and related assemblies from Vietnam to the USA reached nearly $19 million in 2024, compared to over $950 million from Mexico and nearly $27 million from Thailand. The petition names four Vietnamese companies accused of dumping.
DOC’s Q&V Questionnaire and Deadlines
DOC has issued the Quantity & Value (Q&V) questionnaire to gather data for selecting mandatory respondents—typically the two largest Vietnamese exporters based on USA Customs and Border Protection (CBP) and other trade data.
- Deadline to submit Q&V responses: 5:00 PM (Eastern Time), April 1, 2025.
- All exporters of the investigated products, whether named in the petition or not, should actively respond to the Q&V questionnaire and submit a Separate Rate Application (SRA) to qualify for an individual dumping margin.
Separate Rate Application (SRA)
To qualify for a separate rate, companies must demonstrate that they operate independently of government control, both legally and practically.
- Deadline to submit SRA: 21 days from the Federal Register notice of initiation.
- Extensions: Companies may request an extension in writing, but it is subject to DOC approval.
Investigation Period and Alleged Dumping Margins
- AD Investigation Period (POI): July 1, 2024 – December 31, 2024.
- Injury Investigation Period: January 1, 2022 – December 31, 2024.
- Alleged Dumping Margin for Vietnam: Up to 302.52%, the highest among the three investigated countries.
Use of Surrogate Country in Dumping Calculation
As the USA classifies Vietnam as a non-market economy (NME), DOC will use a surrogate country’s prices to determine normal value. In this case, Indonesia has been selected as the surrogate country based on the petitioners’ recommendation.
USA AD Investigation Process
The investigation involves two agencies:
- DOC – Investigates dumping practices and determines dumping margins.
- ITC – Evaluates whether the USA industry has suffered material injury due to dumping.
- If both DOC and ITC confirm dumping and injury, AD duties will be imposed on Vietnamese semitrailer imports.
- If ITC finds no injury, the case will be terminated, but such outcomes are rare.
Key Recommendations for Vietnamese Exporters
- Respond to the Q&V questionnaire before the deadline to avoid being assigned an adverse duty rate.
- Submit the Separate Rate Application (SRA) if seeking an individual rate.
- Monitor DOC and ITC updates, including any hearings or deadlines.
- Register an IA ACCESS account and comply with USA procedural requirements.
- Seek legal and trade remedy assistance for proper documentation and representation.
To protect their legitimate interests, manufacturers and exporters should familiarize themselves with the procedure and actively contact Vietnamese law firms specializing in anti-dumping and trade remedy for timely assistance.
View the official document here.
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