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On 27 July 2026, U.S. time, the U.S. Department of Commerce (“DOC”) issued its final determinations in the antidumping and countervailing duty investigations concerning imports of steel concrete reinforcing bar from Vietnam.
Compared with its preliminary determinations, the DOC increased the antidumping and countervailing duty rates applicable to Vietnamese enterprises. Given the relatively high final duty rates, Vietnam’s exports of steel concrete reinforcing bar to the United States are expected to face significant difficulties in the coming period.
Steel Concrete Reinforcing Bar Subject to the Investigations
The product under investigation is steel concrete reinforcing bar, classified under the following U.S. Harmonized Tariff Schedule (“HTSUS”) subheadings:
7213.10.0000, 7214.20.0000, 7228.30.8010, 7221.00.0017, 7221.00.0018, 7221.00.0030, 7221.00.0045, 7222.11.0001, 7222.11.0057, 7222.11.0059, 7222.30.0001, 7227.20.0080, 7227.90.6030, 7227.90.6035, 7227.90.6040, 7228.20.1000, and 7228.60.6000.
During the investigations, the DOC selected one Vietnamese enterprise as the mandatory respondent. A total of 10 affiliated companies were identified as being related to this enterprise.
Whether an enterprise is subject to the duties must be determined based on the product description, technical specifications, HS code, manufacturer, exporter, and affiliation among the relevant parties.
Final Antidumping and Countervailing Duty Rates
According to the DOC’s final determinations, the duty rates applicable to the mandatory respondent, its affiliated companies, and all other companies are as follows:
| Type of duty | Mandatory respondent and affiliated companies | All other companies |
| Preliminary antidumping duty rate, adjusted for export subsidies | 121.97% | 130.77% |
| Preliminary countervailing duty rate | 1.08% | 1.08% |
| Final antidumping duty rate, adjusted for export subsidies | 123.49% | 131.53% |
| Final countervailing duty rate | 6.8% | 6.8% |
Compared with the preliminary determination, the final antidumping duty rate applicable to the mandatory respondent and its affiliated companies increased from 121.97% to 123.49%. For all other companies, the rate increased from 130.77% to 131.53%.
The countervailing duty rate increased significantly, from 1.08% to 6.8%. This increase was primarily attributable to the DOC’s revised determinations regarding certain subsidy programs under investigation, particularly programs involving preferential loans.
Reasons for the Increase in the Countervailing Duty Rate
In determining the benefits conferred under preferential lending programs, the DOC used benchmark interest rates from outside Vietnam to calculate the amount of the subsidy. This methodology increased the subsidy margins associated with the loans, causing the final countervailing duty rate to exceed 5%.
The investigation involved nearly 50 alleged subsidy programs, many of which had never previously been investigated by the United States in relation to Vietnam. This made the process of providing, reconciling, and verifying information more complex for the enterprise and the relevant authorities.
Although Vietnam’s final countervailing duty rate increased to 6.8%, it remains significantly lower than the 23.27% rate determined for Egypt, which was also subject to the investigation.
Next Steps in the Proceedings
Following the DOC’s final determinations on dumping and subsidization, the U.S. International Trade Commission (“ITC”) will issue its final injury determination within 45 days.
If the ITC determines that the U.S. steel concrete reinforcing bar industry is materially injured or threatened with material injury by imports subject to the investigations, the DOC will issue formal antidumping and countervailing duty orders within seven days thereafter. U.S. Customs and Border Protection will adjust the cash deposit rates in accordance with the DOC’s final determinations.
If the ITC determines that there is no injury, the investigations will be terminated, and the cash deposits collected will be refunded in accordance with applicable regulations. The ITC’s forthcoming determination will therefore decide whether the antidumping and countervailing duty orders formally take effect.
Recommendations for Vietnamese Enterprises
Vietnamese manufacturers and exporters of steel concrete reinforcing bar should continue to closely monitor the ITC’s final determination and any duty orders subsequently issued by the DOC. Enterprises should also proactively coordinate with the Trade Remedies Authority of Vietnam to receive updates and promptly address any requirements that may arise.
In addition, enterprises should:
- Review existing export contracts and comprehensively assess the impact of the duties on sale prices, costs, cash deposit obligations, and the feasibility of continuing exports to the United States;
- Diversify export markets, enhance competitiveness, and ensure compliance with the regulations of importing markets;
- Maintain complete accounting books, supporting documents, and data concerning manufacturing and export activities, affiliated companies, and government support programs;
- Prepare for potential participation in annual administrative reviews after the formal duty orders are issued; and
- Consider requesting a new shipper review if the relevant conditions are satisfied or using other appropriate legal mechanisms under U.S. law to seek reconsideration of the duty rates in the future.
With antidumping duty rates reaching 131.53% and a countervailing duty rate of 6.8%, enterprises should carefully evaluate the feasibility of maintaining exports to the United States and develop long-term legal and business strategies to mitigate the effects of these trade remedy measures.
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.
