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On June 4, 2025, the U.S. Department of Commerce (DOC) received a petition requesting the initiation of antidumping (AD) and countervailing duty (CVD) investigations on imports of steel concrete reinforcing bars from four countries, including Vietnam, Algeria, Bulgaria, and Egypt.
1. Case Summary
- Case Numbers: A-552-853 (Antidumping) and C-552-854 (Countervailing)
- Petitioner: U.S. Concrete Reinforcing Steel Institute
- Product under investigation: Primarily classified under HS codes 7213.10.0000, 7214.20.0000, and 7228.30.8010, among others as applicable.
- Proposed AD/CVD investigation period: Calendar year 2024
- Injury investigation period: From 2022 to 2024
- Export volume from Vietnam: Approximately 78,663 metric tons (accounting for 8.2% of total U.S. imports from April 2024 to March 2025)
- Number of named Vietnamese exporters/producers: 08
2. Allegations
2.1. Antidumping
Vietnamese exporters are accused of dumping steel concrete reinforcing bars in the U.S. market at a margin as high as 115.44%. Since Vietnam is treated as a non-market economy by the United States, the DOC is expected to use surrogate country data, with the petitioner recommending Egypt as the surrogate.
2.2. Countervailable Subsidies
Although no specific subsidy margin is identified, the petitioner alleges that Vietnamese companies benefit from 39 government subsidy programs, which allegedly cause or threaten material injury to the U.S. domestic industry. These programs are grouped into six categories:
- Preferential lending (9 programs): Including state-owned bank credit, interest rate support, guarantees, and development credit from the Vietnam Development Bank.
- Corporate income tax incentives (11 programs): Related to location-based, old/new project incentives, incentives for foreign investors, accelerated depreciation, etc.
- Import duty exemptions/rebates (7 programs): For raw materials for export production, machinery, components, and industrial zones.
- Land use incentives (5 programs): Land rent exemption/reduction, land use tax incentives in preferential zones.
- Direct grants (3 programs): Including investment and export promotion support, and state financial support under Decree 118/2015.
- Preferential utility pricing (4 programs): Provision of electricity, water, etc., in industrial parks at below-market rates.
3. Investigation Procedures
Under U.S. law, the DOC is responsible for investigating the alleged dumping and subsidization, while the U.S. International Trade Commission (ITC) evaluates whether the domestic industry has suffered material injury. Duties will only be imposed if both agencies reach affirmative determinations.
Key procedural milestones (subject to extension):
- CVD consultations: The Vietnamese government is expected to consult with the DOC shortly after receiving notice.
- DOC review of the petition: Within 20 days; initiation decision expected by June 24, 2025.
- ITC preliminary injury determination: Within 45 days. If no injury is found, the case is terminated.
- DOC preliminary determinations:
- CVD: Within 65 days of initiation
- AD: Within 140 days of initiation
- DOC final determinations: Within 75 days after the preliminary determinations.
- ITC final injury determination: Within 45 days of DOC’s final determinations.
- Issuance of duty orders by DOC: Within 7 days following affirmative final determinations by both DOC and ITC.
To protect their legitimate interests, manufacturers and exporters should familiarize themselves with the procedure and actively contact Vietnamese law firms 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.
