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On July 11, 2025 (U.S. time), the U.S. Department of Commerce (DOC) officially announced the initiation of an anti-circumvention investigation concerning the anti-dumping and countervailing duties imposed on disposable aluminum products—such as containers, pans, trays, and lids—imported from Vietnam and Thailand.
According to the petition filed by the American Foil Container Manufacturers Association (AFCMA), the investigation covers products under the following HS codes: 7615.10.7125, 7612.90.1090, 7615.10.3015, 7615.10.3025, 7615.10.7130, 7615.10.7155, 7615.10.7180, 7615.10.9100, and 8309.90.0000.
AFCMA alleges that producers in Vietnam and Thailand imported aluminum foil—the primary input—from China to manufacture disposable aluminum products, which were then completed and exported to the United States in an attempt to evade the anti-dumping and countervailing duties currently imposed on similar Chinese-origin goods.
At this stage, DOC has not announced the list of mandatory respondents in the case, but the selection is expected to be based on import statistics provided by U.S. Customs and Border Protection (CBP).
Under U.S. trade remedy procedures, DOC is expected to issue a preliminary determination within 150 days from the initiation date (anticipated by December 4, 2025), and a final determination within 300 days (anticipated by May 4, 2026). While the investigation timeline may be extended, the total duration generally does not exceed 365 days (i.e., by July 7, 2026).
Given this development, relevant manufacturers and exporters should proactively review their export activities to the U.S. market; thoroughly study U.S. regulations and procedures on anti-circumvention investigations; fully and punctually comply with all requests from the investigating authorities; and closely coordinate with the Trade Remedies Authority of Vietnam throughout the process to safeguard their legitimate interests.
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.
