Tiếng Việt
中文 (中国)
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The U.S. Department of Commerce (DOC) has recently announced the initiation of anti-circumvention investigations concerning antidumping and countervailing duties on 22.5–24.5 inch steel wheels imported from Vietnam that use hot-rolled steel (HRS) originating from China.
The investigations were initiated based on petitions filed by Accuride Corporation and Maxion Wheels USA LLC. According to the petitioners, companies in Vietnam allegedly used Chinese-origin hot-rolled steel — considered the primary input material for steel wheel production — to complete manufacturing processes in Vietnam before exporting the finished products to the United States in order to circumvent the antidumping and countervailing duty measures currently imposed on similar products from China.
The products subject to investigation include 22.5–24.5 inch steel wheels classified under various U.S. HS codes, including 8708.70.4530, 8708.70.4560, 8708.70.6030, 8708.70.6060, and 8716.90.5059. Additional HS codes that may also be involved include 4011.20.1015, 4011.20.5020, and 8708.99.4850.
As of now, the DOC has not announced the list of mandatory respondents in the investigations. However, the U.S. investigating authority is expected to select companies for examination based on import data provided by U.S. Customs and Border Protection (CBP).
Under U.S. anti-circumvention investigation procedures, the DOC is expected to issue its preliminary determination on August 13, 2026, and the final determination on January 11, 2027. Although these deadlines may be extended, the total investigation period generally does not exceed 365 days from the initiation date.
Amid increasing scrutiny by the United States over transshipment and processing activities involving materials sourced from countries subject to trade remedy measures, this case reflects a growing trend toward stricter examination of upstream supply chains, particularly in the industrial manufacturing and mechanical engineering sectors.
To safeguard the legitimate rights and interests of Vietnamese enterprises, the Trade Remedies Authority of Vietnam has recommended that manufacturers and exporters of related products proactively review their exports to the United States, especially the use of Chinese-origin input materials in their production processes.
In addition, enterprises are advised to thoroughly study U.S. anti-circumvention regulations and investigation procedures, while fully cooperating with the investigating authority in order to have the opportunity to participate in self-certification mechanisms and thereby avoid the risk of future anti-circumvention duty measures.
Relevant companies are also encouraged to coordinate closely with legal counsel, importers, and government authorities throughout the investigation process to ensure the complete, accurate, and timely submission of information to the DOC.
According to information from the authorities, enterprises may contact the Foreign Trade Remedies Investigation Division under the Trade Remedies Authority of Vietnam for guidance and support during their participation in this investigation.
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].
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.
