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On March 14, 2024, the Trade Remedies Authority, Ministry of Industry and Trade of Vietnam issued a list of early warnings for Vietnamese products at risk of being investigated for the application of international trade defense measures. The items at risk include:
1. Some wood products exported to the United States
Hardwood plywood
HS codes for reference: 4412.31, 4412.32, 4412.33, 4412.34, 4412.94, 4412.99
The DOC allows eligible Vietnamese exporters to participate in the self-certification mechanism to be excluded from the measures. Therefore, Vietnamese exporters to the US participating in the self-certification mechanism should refrain from using imported veneer from China as material for plywood cores and maintain scientific records and documents to demonstrate the origin of materials to the competent US authorities upon request for verification.
Wooden cabinets and vanities
HS codes for reference: 9403.40, 9403.60, 9403.90
Enterprises manufacturing kitchen cabinets and bathroom vanities should avoid using door components, drawer fronts, and wooden frames as finished products, semi-finished products, or sub-assemblies manufactured in China for processing, assembling products, and exporting to the US as these cases, according to DOC’s preliminary findings, are still subject to duties similar to Chinese products.
Wooden bedroom furniture
HS codes for reference: 9403.50.9041, 9403.50.9042, 9403.50.9045, 9403.50.9080, 9403.90.7005, 9403.90.7080
This product constitutes a significant proportion of total US imports, hence there is a possibility of the US initiating a trade remedy investigation or duty evasion regarding imported bedroom furniture from Vietnam. Vietnamese enterprises should avoid using main components manufactured in China for processing, assembling products, and exporting to the US.
Seats with wooden frames, upholstered
HS code for reference: 9401.61
This product also represents a large proportion of total US imports, thus there is a possibility of the US initiating a trade remedy investigation or duty evasion regarding imported sofa seats from Vietnam. Vietnamese enterprises should avoid using main components manufactured in China for processing, assembling products, and exporting to the US.
Continuous shaped wood mouldings, millwork products
HS codes for reference: 4409.10, 4409.22, 4409.29
Vietnam’s share of total US imports is increasing. Vietnamese exporters to the US should avoid using main materials imported from China to produce these products.
2. Some building materials exported to the United States
Quartz surface products
HS code for reference: 6810.99
The United States requires importers of assembled products using quartz stone surfaces originating from China, India, and Turkey, such as kitchen cabinets, bathroom vanities, etc., to separately declare the value of quartz stone and pay CBPG and CTC taxes based on this value. Therefore, enterprises exporting products using quartz stone surfaces should communicate with import partners to accurately declare imports as required by US customs authorities, avoiding being considered as evading CBPG and CTC measures as per US law.
Ceramic tile
HS codes for reference: 6907.21, 6907.22, 6907.23, 6907.30, 6907.40
Vietnam’s ceramic tile exports to the US market are forecasted to continue rapidly increasing due to a significant decrease in ceramic tile exports from China to the US because of CBPG and CTC tariffs. Vietnamese enterprises exporting to the US should avoid using main materials imported from China for producing these products.
3. Some steel products exported to the United States
Corrosion-resistant carbon steel (CORE)
HS codes for reference: 7210.30, 7210.41, 7210.49, 7210.61, 7210.69, 7210.70, 7210.90, 7212.30, 7212.40, 7212.50, 7212.60
Enterprises exporting to the US should refrain from using CRS and HRS from markets subject to US anti-dumping duties as raw materials for producing CORE steel and maintain scientific records and documents to prove the origin of materials to the competent US authorities upon request for verification.
Pipe and Tube
HS codes for reference: 7306.30, 7306.50, 7306.19, 7306.61
Enterprises exporting to the US should avoid using HRS from markets subject to US anti-dumping duties as raw materials for producing steel pipes and maintain scientific records and documents to prove the origin of materials to the competent US authorities upon request for verification.
Prestressed concrete steel wire strand
HS code for reference: 7312.10
This is a product at risk of US trade defense or anti-circumvention investigations. Enterprises exporting to the US should avoid using main materials imported from China for producing this product.
Stainless steel flanges
HS code for reference: 7307.21
This is a product at risk of US trade defense or anti-circumvention investigations. Enterprises exporting to the US should avoid using main materials imported from China and India for producing this product.
4. Some steel products exported to Mexico
Up to the end of 2023, Mexico has been applying 45 anti-dumping measures against steel products imported from various countries and territories. Prior to 2021, there were no trade defense cases regarding Vietnamese exports to Mexico. However, starting from 2021, Mexico has conducted investigations and applied trade defense measures against Vietnamese steel products, including galvanized steel (2021), cold-rolled steel (2022), and welding wire (2023).
In the near future, some steel products exported to Mexico are at risk of being subject to Mexico’s next trade defense investigation. Specifically:
Hot rolled sheet steel – HS codes for reference: 7208.36, 7208.37, 7208.38, 7208.39
Vietnam accounts for 7.2% of Mexico’s total imports of this product. Vietnam is the fourth-largest supplier to the Mexican market, following the United States, Japan, and South Korea. Mexico has imposed anti-dumping measures on hot rolled sheet steel imported from China, Germany, France, Russia, and Ukraine.
Prestressed products – HS code for reference: 7312.10
Vietnam accounts for 6.8% of Mexico’s total imports of this product. Vietnam is the fifth-largest supplier to the Mexican market, following China, the United States, South Korea, and Indonesia. Mexico has imposed anti-dumping measures on prestressed products imported from China, Spain, and Portugal.
5. Hot rolled structural steel sections exported to Australia
HS codes for reference: 7216.31, 7216.32, 7216.33, 7216.40, 7216.50, 7228.70
Vietnam’s share accounts for 10.5% of Australia’s total imports of similar products. This is a product at risk of being investigated for trade defense by Australia if the export volume to Australia continues to increase at the same rate as in the past.
6. Some aluminum products exported to the United States
Aluminum wire and cable
HS code for reference: 8544.49
In mid-October 2023, the Department of Commerce (DOC) initiated an investigation to consider the scope of products and circumvention of AD and CVD duties on aluminum wire and cable from Vietnam, Cambodia, and South Korea. Enterprises exporting to the United States should avoid using main materials imported from China to produce this product.
Aluminum extrusions
HS codes for reference: 7604.10, 7604.21, 7604.29, 7608.10, 7608.20, 7610.10, 7610.90
Besides continuing to participate in this investigation to protect their legitimate rights and interests, enterprises exporting to the United States should refrain from using main materials imported from the relevant countries to produce this product to avoid being subjected to overlapping anti-circumvention duties.
7. Some other industrial products
Solar panels exported to the United States
HS codes referenced in US tariff: 8501.61.0010, 8507.20.80, 8541.40.6015, 8541.40.6025, and 8501.31.8010
Enterprises exporting to the United States participating in the self-certification mechanism should ensure honest self-certification and maintain scientific records and documents to prove the origin of materials to the competent US authorities upon request for verification.
Electric bicycles exported to the United States and the EU
HS code for reference: 8711.60
In cases where some imported components are used to manufacture electric bicycles for export, Vietnamese enterprises should accurately declare the origin to avoid being viewed as evading taxes. If necessary, enterprises can consult with the customs authority of the importing country on the method of determining the origin to ensure accurate declaration of the product’s origin.
Large residential washers exported to the United States
HS code for reference: 8450.20
After the removal of the US safeguard measure, the export volume of large residential washers from Vietnam to the United States is rapidly increasing. Therefore, enterprises should be aware of the risk of the United States initiating a trade defense investigation against this product.
Truck and bus tires exported to the United States
HS code for reference: 4011.20
In the event that products from Thailand are subjected to US anti-dumping duties, there is a possibility that US importers will switch to other suppliers, including those from Vietnam. Therefore, enterprises exporting truck and bus tires to the United States should take note to prepare and devise appropriate business plans to avoid becoming the subject of the next investigation if exports from Vietnam to the United States increase too rapidly.
(Information from the Vietnam’s Trade Remedy Authority)
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