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On May 14, 2026, the U.S. Department of Commerce (DOC) officially published a correction notice regarding the initiation of antidumping investigations into imports of PTMEG (polytetramethylene ether glycol) from Vietnam, China, South Korea, and Taiwan, China. The original notice of initiation had previously been issued by the DOC on May 5, 2026.
The investigations were initiated following a petition filed by BASF Corporation, a chemical producer in the United States. According to the petitioner, PTMEG imported from the investigated countries is being sold in the U.S. market at prices below normal value, thereby causing material injury to the domestic industry.
The product under investigation is PTMEG, also known by other names such as PTMG, PTHF, or polybutylene glycol. The merchandise is currently classified primarily under U.S. HS code 3907.29.0000, and may also be imported under HS codes 2932.11.0000 and 3404.90.5150. The DOC has determined that the period of investigation for the antidumping proceeding extends from October 1, 2025 to March 31, 2026.
With respect to Vietnam, the DOC noted that there was one exporter of PTMEG to the United States during the investigation period. In the petition, the petitioner alleged extremely high dumping margins for Vietnamese exports, ranging from 100.61% to more than 212%, depending on the surrogate country used to calculate normal value.
As the United States continues to treat Vietnam as a non-market economy (NME), the DOC will not directly use the Vietnamese company’s domestic cost data to calculate dumping margins. Instead, the investigating authority will rely on data from a third-country market economy to determine surrogate values for the factors of production. At the initiation stage, the countries being considered as surrogate countries include Jordan, El Salvador, and Indonesia.
The scope of investigation is drafted broadly, covering nearly all forms of PTMEG regardless of purity level, physical characteristics, molecular weight, additives, or packaging specifications. In addition, blended, mixed, or further-processed products manufactured in third countries may still fall within the scope of investigation if they satisfy the DOC’s product description.
During antidumping investigations in the United States, both the DOC and the United States International Trade Commission (ITC) play critical roles. The DOC is responsible for determining the existence of dumping, while the ITC evaluates whether the U.S. domestic industry has suffered material injury. An antidumping duty order will only be issued if both agencies reach affirmative determinations.
Under the investigation procedures, following initiation, the DOC will issue Quantity and Value (Q&V) Questionnaires for purposes of selecting mandatory respondents. For companies located in non-market economy countries such as Vietnam, enterprises are also required to submit Separate Rate Applications in order to be considered for individual duty rates rather than being subject to the nationwide rate.
After selecting mandatory respondents, the DOC will continue issuing detailed questionnaires concerning factors of production, costs, sales activities, and export data. During the proceeding, the DOC may also conduct on-site verification of the information submitted by enterprises, while allowing interested parties to submit legal comments, rebuttal arguments, or participate in public hearings.
The ITC is expected to issue its preliminary injury determination within 45 days from the date the petition was filed. If the ITC issues a negative determination with respect to Vietnam, the investigation concerning Vietnamese products will be terminated. Conversely, if both the preliminary and final determinations are affirmative, the DOC may issue an antidumping duty order on PTMEG imports from Vietnam.
In addition, if the DOC determines that there has been a surge of imports following the initiation of the investigation, the authority may impose provisional retroactive duties on imports entered up to 90 days prior to the issuance of the preliminary determination.
In light of the ongoing proceeding, the Trade Remedies Authority of Vietnam has recommended that Vietnamese PTMEG producers and exporters closely monitor the progress of the investigation, proactively register ACCESS accounts with the DOC to access case documents, and complete all necessary procedural requirements.
Relevant enterprises are also advised to timely and fully submit responses to the Q&V Questionnaires, Separate Rate Applications, and subsequent DOC questionnaires. Failure to cooperate, or incomplete cooperation, may result in the DOC’s application of adverse facts available (AFA), which could lead to the imposition of extremely high antidumping duty rates.
In addition, companies should proactively review export data, revenues, production costs, and factors of production during the investigation period to ensure the accuracy and consistency of the information submitted to the U.S. investigating authority. Close coordination with legal counsel, importers, and government authorities will play an important role in protecting the legitimate rights and interests of Vietnamese enterprises throughout the course of this trade remedy proceeding.
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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