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On 28 July 2026, the Ministry of Industry and Trade issued Decision No. 1917/QĐ-BCT on the imposition of definitive anti-circumvention measures against the circumvention of trade remedy measures applicable to certain hot-rolled steel products originating from China. The case is designated as AC03.AD20.
Following the imposition of the definitive measures, the Trade Remedies Authority of Vietnam announced that it would accept exemption applications from enterprises importing products falling within the scope of the measures, provided that the conditions prescribed by trade remedy laws are satisfied.
Scope of Products Subject to the Anti-Circumvention Measures
The products subject to the measures are certain hot-rolled steel products with a width exceeding 1,880 mm but not exceeding 2,300 mm, originating from China.
These products are classified under the following HS codes:
7208.25.00, 7208.26.00, 7208.27.19, 7208.27.99, 7208.36.00, 7208.37.00, 7208.38.00, 7208.39.20, 7208.39.40, 7208.39.90, 7208.52.00, 7208.53.00, 7208.54.90, 7208.90.90, 7211.14.15, 7211.14.16, 7211.14.19, 7211.19.13, 7211.19.19, 7211.90.12, 7211.90.19, 7225.30.90, 7225.40.90, 7225.99.90, 7226.91.10, and 7226.91.90.
Whether a product falls within the scope of the measures must be determined by concurrently considering the product description, technical specifications, origin, and relevant HS code.
Circumstances Eligible for Exemption Consideration
Pursuant to Clause 2, Article 12 of Circular No. 26/2025/TT-BCT dated 15 May 2025 of the Minister of Industry and Trade, imported goods subject to trade remedy measures may be considered for exemption if they fall within any of the following circumstances:
- The goods are included in the list eligible for exemption consideration under the decision imposing the trade remedy measure or the decision on the results of a review of the case;
- The goods cannot be manufactured by the relevant domestic industry;
- The goods have distinctive characteristics and cannot be substituted by domestically manufactured goods;
- The goods constitute special products within the category of like goods or directly competitive goods manufactured domestically;
- Like goods or directly competitive goods manufactured domestically are not sold in the domestic market under normal commercial conditions, or a force majeure event has caused a shortage of domestic supply; or
- The imported goods fall within the total volume for which exemption is requested under the circumstances mentioned above and are used for research and development activities or other non-commercial purposes.
Enterprises applying for an exemption must demonstrate that the imported goods fully satisfy the relevant conditions, particularly those concerning product characteristics, the domestic industry’s manufacturing and supply capabilities, actual demand, and the purpose of importation.
Required Documents for an Exemption Application
Pursuant to Clause 1, Article 17 of Circular No. 26/2025/TT-BCT, the Trade Remedies Authority of Vietnam has requested enterprises seeking an exemption from the definitive anti-circumvention measures in Case AC03.AD20 to review the requirements, prepare the necessary documents, and submit their exemption applications.
The application dossier must comply with Article 16 and Appendix II issued together with Circular No. 26/2025/TT-BCT. Enterprises must ensure that all declared information is complete, accurate, consistent, and supported by appropriate evidence.
When preparing their applications, enterprises should carefully review information concerning the products, HS codes, technical specifications, import volumes, intended uses, and the possibility of substitution by domestically manufactured products. These matters are important to the assessment of exemption applications.
Methods of Submission
Pursuant to Article 18 and Clause 3, Article 17 of Circular No. 26/2025/TT-BCT, enterprises may submit exemption applications through the Ministry of Industry and Trade’s Online Public Service Portal at https://dichvucong.moit.gov.vn or directly to the Trade Remedies Authority of Vietnam.
Enterprises importing hot-rolled steel products falling within the scope of Case AC03.AD20 should promptly assess their eligibility for an exemption, prepare supporting documents, and monitor guidance from the investigating authority to ensure that their applications are submitted in compliance with the 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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