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The Trade Remedies Authority of Vietnam (TRAV) under the Ministry of Industry and Trade has reported that it has received information regarding the issuance by the United States Department of Commerce (DOC) of a preliminary determination in the countervailing duty investigation concerning plywood and decorative wood products imported from Vietnam. The key aspects of the case are summarised below.
General information
The petitioner in the case is the U.S. Hardwood Plywood Fair Trade Coalition.
The products under investigation are hardwood plywood and decorative wood products, mainly classified under HS codes 4412 and 9403.
The countries under investigation include China, Indonesia, and Vietnam. All three countries are simultaneously subject to both anti-dumping and countervailing duty investigations.
According to data cited by the petitioner from the U.S. International Trade Commission (ITC), during the period 2022–2024, Vietnam’s exports of the investigated products to the United States amounted to approximately USD 401 million, USD 186 million, and USD 244 million, respectively, ranking second among the three investigated countries, after Indonesia.
The petitioner named nearly 100 Vietnamese companies alleged to have engaged in dumping while also receiving government subsidies.
Key developments in the investigation
On 11 June 2025, the DOC officially initiated the investigation.
Following initiation, the DOC issued Quantity and Value (Q&V) questionnaires to Vietnamese exporters and producers in order to collect information for the selection of mandatory respondents. Based on the information collected, the DOC selected two Vietnamese companies as mandatory respondents. The findings for these mandatory respondents will serve as the basis for determining the countervailing duty rates applicable to the remaining Vietnamese companies.
Within the framework of the investigation, the DOC examined a total of 29 programmes and policies of the Government of Vietnam, including corporate income tax incentives; grant programmes; preferential loan programmes; exemptions, reductions, and refunds of import duties; land-related incentives; and the provision of input materials at prices lower than adequate remuneration.
During the course of the investigation, the DOC issued the initial countervailing duty questionnaires as well as multiple supplemental questionnaires to the Government of Vietnam and the two mandatory respondent companies.
Contents of the preliminary determination
According to the DOC’s preliminary determination, 3 out of the 29 programmes under investigation were found to constitute countervailable subsidies, including preferential loan programmes for exporters from state-owned commercial banks; industrial promotion grant programmes; and the provision of input materials at prices lower than adequate remuneration.
With respect to certain additional allegations, the DOC indicated that it would continue its examination and issue conclusions in subsequent memoranda following the preliminary determination.
Based on the preliminary determination, the countervailing duty rates were determined as follows: the mandatory respondents are subject to rates ranging from 4.37% to 26.75%, while the remaining Vietnamese companies are subject to a rate of 15.56%.
Overall, the preliminary countervailing duty rates applicable to Vietnamese companies are significantly lower than those applied to Chinese companies (81.34%) and fall within the lower range of the rates applied to Indonesian companies (ranging from 2.4% to 128.66%) in the same investigation.
With regard to the allegation of retroactive duties, the DOC reviewed the monthly import data provided by the petitioner and compared the periods before and after the filing of the petition. Based on its calculations, the DOC concluded that there was no massive surge in imports during the comparison period and therefore did not apply retroactive duties to imports from Vietnam.
Next steps and recommendations
In accordance with the investigation procedures, following the issuance of the preliminary determination, the DOC may continue to issue supplemental questionnaires, further investigate allegations of new subsidy programmes, and conduct on-site verifications of the companies concerned as well as the Government of Vietnam to verify the information provided.
The DOC also allows interested parties to submit case briefs and rebuttal briefs. The deadline for filing case briefs is within seven days from the date the DOC issues the final verification report, and rebuttal briefs must be submitted within the following five days. Upon request, the DOC may hold a hearing within 30 days from the publication of the preliminary determination, prior to issuing the final determination.
It is expected that the DOC will issue its final countervailing duty determination in May 2026, subject to extension in accordance with applicable regulations.
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.
ASL Law is a leading full-service and independent Vietnamese law firm made up of experienced and talented lawyers. ASL Law is ranked as the top tier Law Firm in Vietnam by Legal500, Asia Law, WTR, and Asia Business Law Journal. Based in both Hanoi and Ho Chi Minh City in Vietnam, the firm’s main purpose is to provide the most practical, efficient and lawful advice to its domestic and international clients. If we can be of assistance, please email to [email protected].
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