ASL LAW's legal analysis of the EAEU tire anti-dumping investigation

EAEU Initiates Anti-Dumping Investigation on Tires Originating from or Imported from Thailand and Vietnam

On November 7, 2025, the Domestic Market Protection Department of the Eurasian Economic Commission (the EAEU trade remedy investigating authority) initiated an anti-dumping investigation on tires imported from Thailand and Vietnam into the EAEU market.

The products under investigation are truck tires used for various vehicles operating on multiple axles, including freight cars, buses, electric vehicles, dump trucks, trailers, and semi-trailers. These tires and inner tubes are made of rubber with rim diameters ranging from 17.5 to 24.5 inches and are classified under HS codes 4011.20.100.0 and 4011.20.900.0.

The complainants in this case include Belshina Union of Companies, Omskshina, Cordiant, and Nizhnekamsk. According to the initiation notice, during 2022–2024, import volumes from Thailand and Vietnam into the EAEU increased 2.6 times, consumption shares rose 2.4 times, and the import-to-domestic production ratio increased 2.8 times.

The EAEU’s damage allegation asserts that imports from Thailand and Vietnam were priced lower on average than domestically produced tires (except in 2023), resulting in declines in production, economic, and financial indicators of the domestic industry during 2022–2024 and April 2024–March 2025.

Specifically, production volume decreased by 6% and 14%, capacity utilization fell by 5% and 6%, year-end inventory levels increased by 15% and 19%, sales profits within the Union declined by 59% and 78%, production profit margins decreased by 68% and 80%, and sales profit margins fell by 62% and 76%. The investigating authority also noted that truck tires in Thailand and Vietnam are mainly export-oriented, with total production capacities exceeding EAEU market demand. Vietnam, in particular, is reported to be expanding its capacity by up to 1.4 million units, increasing export potential.

In addition, recent trade remedy measures by the United States, Brazil, South Africa, and Egypt, as well as the U.S. Section 232 tire investigation, may redirect exports toward the EAEU market. The alleged dumping margins in this case are 24.17% for Thailand and 19.59% for Vietnam.

The investigation process is conducted pursuant to Article 49 of the EAEU Treaty and Appendix No. 8 of the Protocol on the Application of Safeguard, Anti-Dumping, and Countervailing Measures. Within 25 days of initiation, enterprises may register as interested parties; upon recognition, they gain access to non-confidential documents and can participate in public hearings or consultations. The investigating authority provides an “Electronic Library of Documents for Investigation Participants,” allowing access to non-confidential documents after completing registration procedures.

The deadline to request a public hearing is 45 days from initiation, while the deadline to submit comments on the case is 60 days. All documents submitted to the investigating authority must be prepared in Russian, with both confidential and non-confidential versions; guidance for preparing the non-confidential version is published on the EAEU website.

During the investigation, under Point 239 of the Protocol, the authority will send questionnaires to foreign producers, exporters, and domestic producers. The questionnaires may request information on EAEU import supplies and the status of the domestic production industry. Additional information may be requested under Point 211; confidentiality of sensitive data is ensured in accordance with the 2012 EAEU Commission Regulations. On-site verifications may be conducted if necessary to verify the accuracy of the submitted information.

Failure to cooperate carries serious consequences. If an interested party does not provide information, submits it late, or provides inaccurate data significantly impeding the investigation, the authority will issue conclusions based on adverse facts available (AFA), usually leading to the application of high anti-dumping duties.

Regarding recommendations, industry associations should promptly inform relevant manufacturing and exporting enterprises to respond timely and avoid being considered uncooperative. Associations should also identify enterprises with the highest export volumes from July 1, 2024, to June 30, 2025, to anticipate which companies may be selected as mandatory respondents.

For enterprises, key steps include registering as interested parties within the prescribed timeframe; providing information for sample selection within 25 days; preparing to respond fully to questionnaires if selected as mandatory respondents; submitting hearing requests within 45 days; and providing comments within 60 days. Enterprises should actively monitor the entire investigation process and thoroughly study related regulations to protect their rights in the case.

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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