ASL LAW's analysis of Vietnam's anti-circumvention measures review process for imported sugar products.

Vietnam Ministry of Industry and Trade announces the results of the review on anti-circumvention measures applied to imported sugar products

On October 13, 2025, the Ministry of Industry and Trade issued Decision No. 2868/QĐ-BCT announcing the results of the review on the application of anti-circumvention measures related to trade remedy actions against certain imported sugar products (Case Code: AR02.AC02-AD13.AS01).

This Decision was made based on a comprehensive assessment of the review findings, documents submitted by enterprises, and independent evaluations by competent authorities to ensure that the application of trade remedy measures remains transparent, lawful, and consistent with international practices.

Previously, on August 1, 2022, the Ministry of Industry and Trade had issued Decision No. 1514/QĐ-BCT to impose anti-circumvention measures on certain sugar products originating from Cambodia, Indonesia, Laos, Malaysia, and Myanmar.

The measure was adopted after the investigating authority found indications that sugar from these countries might have been used as a transit channel to evade the existing anti-dumping and countervailing duties applied to sugar originating from Thailand, thereby adversely affecting Vietnam’s domestic sugar industry.

On December 24, 2024, based on a request from Wilmar Sugar (Myanmar) Limited, the Ministry of Industry and Trade issued Decision No. 3485/QĐ-BCT to initiate a review of the application of anti-circumvention measures on this enterprise. The review process was conducted in accordance with the Law on Foreign Trade Management and the Government’s implementing decrees on trade remedy measures.

During the review, the Ministry coordinated with relevant agencies, organizations, and enterprises to collect data, assess information related to raw material sources, production processes, and supply chains to ensure that the conclusions were objective, comprehensive, and supported by verified evidence.

The review results showed that Wilmar Sugar (Myanmar) Limited did not meet the conditions for exclusion from the scope of anti-circumvention measures. Accordingly, the Ministry of Industry and Trade decided to maintain the application of the anti-circumvention measures as stipulated in Decision No. 1514/QĐ-BCT.

The continued enforcement of these anti-circumvention measures is considered necessary to maintain fair competition, prevent trade fraud, and safeguard the legitimate interests of Vietnam’s domestic sugar industry.

It also reaffirms Vietnam’s commitment to the strict and consistent implementation of World Trade Organization (WTO) regulations on trade remedies, thereby demonstrating the country’s dedication to building a fair, transparent, and sustainable trade environment.

To protect their legitimate interests, manufacturers and exporters should familiarize themselves with the procedure and actively contact Vietnam Antidumping Law Firm specializing in anti-dumping and trade remedy for timely assistance.

Enterprises, industry associations, and relevant organizations may access the full text of Decision No. 2868/QĐ-BCT and its accompanying documents for detailed guidance and implementation instructions here.

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