ASL LAW trade remedy attorneys reviewing exemption application documents for Vietnam’s anti-circumvention case AC03.AD20 at Hanoi office

Vietnam Receives Applications for Exemption from Temporary Anti-Circumvention Trade Remedy Measures on Certain Hot-Rolled Steel Products Originating from China (Case No. AC03.AD20)

On April 2, 2026, the Ministry of Industry and Trade issued Decision No. 612/QD-BCT on the application of temporary anti-circumvention trade remedy measures on certain hot-rolled steel products originating from China.

The products subject to the temporary anti-circumvention trade remedy measures are hot-rolled steel products imported from China, identified based on their basic characteristics and HS codes as follows.

Basic characteristics of the products

The goods are flat-rolled products of alloy or non-alloy iron or steel, hot-rolled, with a thickness ranging from 1.2 mm to 25.4 mm and a width greater than 1,880 mm and less than or equal to 2,300 mm. The products have not undergone processing beyond the hot-rolling stage, may be pickled or non-pickled, are not clad, plated, coated, or otherwise surface-treated, may be oiled or non-oiled, and contain carbon content not exceeding 0.30% by weight.

HS codes subject to the measures

The above-mentioned hot-rolled steel products are classified under the following HS codes: 7208.25.00, 7208.26.00, 7208.27.19, 7208.27.99, 7208.36.00, 7208.37.00, 7208.38.00, 7208.39.20, 7208.39.40, 7208.39.90, 7208.52.00, 7208.53.00, 7208.54.90, 7208.90.90, 7211.14.15, 7211.14.16, 7211.14.19, 7211.19.13, 7211.19.19, 7211.90.12, 7211.90.19, 7225.30.90, 7225.40.90, 7225.99.90, 7226.91.10, and 7226.91.90.

According to Clause 2, Article 12 of Circular No. 26/2025/TT-BCT dated May 15, 2025 of the Ministry of Industry and Trade, imported goods subject to trade remedy measures may be considered for exemption if they fall into one of the following cases.

First, the goods are included in the list eligible for exemption under the decision imposing trade remedy measures or subsequent review decisions.

Second, the goods cannot be produced by the domestic industry.

Third, the goods have distinct characteristics that domestic products cannot substitute.

Fourth, the goods are specialized products of similar or directly competitive goods produced domestically.

Fifth, similar or directly competitive domestic goods are not sold under normal conditions or there is a supply shortage due to force majeure factors.

Sixth, the imported goods are used for research and development or other non-commercial purposes and fall within the total exemption quota requested.

Pursuant to Clause 1, Article 17 of Circular No. 26/2025/TT-BCT, the authority hereby notifies enterprises with demand to submit applications for exemption from the temporary anti-circumvention trade remedy measures in case AC03.AD20. Exemption application dossiers must be prepared in accordance with Article 16 and Appendix II of Circular No. 26/2025/TT-BCT.

According to Clause 3, Article 17 and Article 18 of Circular No. 26/2025/TT-BCT, enterprises are required to submit exemption application dossiers through the Ministry of Industry and Trade’s online public service portal at https://dichvucong.moit.gov.vn.

Decision No. 612/QD-BCT dated April 2, 2026 has been officially published for relevant enterprises to proactively monitor, study, and prepare exemption application dossiers in accordance with applicable regulations.

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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