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On 18 November 2025, the U.S. Department of Commerce (DOC) released the Preliminary Results of the second administrative review of the anti-dumping duties imposed on raw honey imported from Vietnam. The period of review spans from 1 June 2023 to 31 May 2024. The preliminary findings outline several key issues related to dumping margins, applicable duty rates, and the next steps in the review process.
In its preliminary determination, the DOC found the dumping margins for the two mandatory respondents from Vietnam to be 6.72% and 21.55%, respectively. Twelve other companies were deemed eligible for a separate rate and will be subject to a margin of 14.14%, calculated as the simple average of the two mandatory respondents’ margins. This rate is significantly lower than the final rates in the first administrative review, covering the period from 25 August 2021 to 31 May 2023, which ranged from 100.72% to 156.96%.
Other exporters that did not qualify for a separate rate, did not participate in the review, or fall under the “new shipper” category will continue to be subject to the country-wide rate of 60.03%, in accordance with the original anti-dumping duty order. This rate remains applicable to companies that fail to demonstrate independence in their export activities or do not fully participate in the review process.
Regarding the calculation methodology, since Vietnam continues to be treated as a non-market economy (NME) in this proceeding, the DOC applied the surrogate value method to determine the normal value, using data from a third-country market. This approach is authorized under Section 773(c) of the Tariff Act of 1930, which allows the DOC to use price and cost data from an economy deemed more suitable for comparison.
Stakeholders are permitted to submit case briefs within 21 days of the publication of the Preliminary Results. Rebuttal briefs may be submitted within five days thereafter. Parties wishing to request a hearing must submit a written request through the DOC’s ACCESS electronic system by 5:00 p.m. Eastern Time within 30 days of the publication date. Oral statements presented at the hearing must be limited to issues raised in each party’s case brief.
The DOC is expected to issue the Final Results within 120 days from the date of publication of the Preliminary Results. Under Section 751(a)(2)(C) of the Tariff Act of 1930, the Final Results will determine the anti-dumping duties applicable to entries during the period of review and set the future cash deposit rates for incoming shipments. The Preliminary Results notice has been made publicly available by the DOC for stakeholder reference.
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.
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