Tiếng Việt
中文 (中国)
日本語
The Trade Remedies Authority of Vietnam (TRAV) has announced that the U.S. domestic industry has officially filed a petition requesting the U.S. Department of Commerce (DOC) to initiate an anti-dumping investigation on imports of PTMEG (polytetramethylene ether glycol) from China, South Korea, Taiwan (China), and Vietnam.
The product subject to the proposed investigation is PTMEG, currently classified under HS code 3907.20.00 and later adjusted to subheading 3907.29.00 under the Harmonized Tariff Schedule of the United States (HTSUS). The case is identified as A-552-855, filed by BASF Corporation. The DOC officially received the petition on April 7, 2026.
According to the petition, the complainant alleges that at least one Vietnamese exporter has shipped PTMEG to the United States in significant volumes and engaged in dumping practices. The proposed period of investigation for dumping is from October 1, 2025, to March 31, 2026, while the injury review period is from January 1, 2023, to March 31, 2026.
Notably, the alleged dumping margins for Vietnamese products are exceptionally high, ranging from 78.72% to 295.36%, the highest among the investigated countries and territories. As the United States continues to treat Vietnam as a non-market economy, the petitioner proposes that the DOC use surrogate data from countries with comparable levels of development to calculate dumping margins, including Indonesia, El Salvador, and Jordan.
Currently, the DOC is conducting a technical review of the petition before deciding whether to initiate the investigation, and has requested the petitioner to provide additional details on data and calculation methodologies by April 20, 2026. Failure to comply with these requirements may result in rejection of the petition.
Under U.S. law, an anti-dumping investigation involves two authorities: the DOC determines the existence of dumping, while the U.S. International Trade Commission (ITC) assesses injury to the domestic industry. Anti-dumping duties are imposed only if both agencies reach affirmative determinations.
The investigation process is expected to involve multiple stages with strict timelines: the DOC reviews the petition within 20 days to decide on initiation; the ITC issues a preliminary injury determination within 45 days; the DOC makes a preliminary dumping determination within 140 days from initiation; followed by final determinations by both the DOC and ITC before the DOC issues an anti-dumping duty order if sufficient grounds exist. These timelines may be extended depending on actual circumstances.
If the investigation is initiated, the DOC may issue Quantity and Value questionnaires to select mandatory respondents. Relevant companies should pay close attention to registering accounts on the IA ACCESS system of the DOC to monitor case developments and submit filings on time. At the same time, companies must prepare complete data and submit applications for separate rate status within the prescribed deadlines to avoid being subject to a high country-wide duty rate.
To proactively respond, TRAV recommends that relevant manufacturing and exporting enterprises closely monitor developments, thoroughly study U.S. regulations and investigation procedures, and develop appropriate response strategies. Full and timely cooperation with the investigating authorities is critical, as any lack of cooperation may result in the application of adverse facts available and the highest alleged duty rates.
In addition, enterprises should proactively register for and use the IA ACCESS system to stay updated and submit documents, while maintaining regular contact with TRAV for support throughout the case handling process.
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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