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On March 17, 2025, the USA Department of Commerce (DOC) received a petition requesting an anti-dumping investigation on imported polypropylene plastic containers from Vietnam, while simultaneously initiating both anti-dumping and countervailing duty investigations on similar products from China. Vietnam is only subject to an anti-dumping investigation and is not included in the countervailing duty investigation.
According to the petition filed by CoolSeal USA, Inteplast Group, and SeaCa Plastic Packaging & Technology Container, the investigated product falls under HS code 3923.10.9000. In 2024, Vietnam exported over $6 million worth of polypropylene plastic containers to the USA, accounting for approximately 19.4% of total USA imports of this product, whereas China exported nearly $13.4 million, equivalent to 43.3%. The combined import volume from Vietnam and China constitutes 62.7% of total USA imports.
The petitioners accuse seven Vietnamese exporters of dumping, with an alleged dumping margin of 40.85%, significantly lower than the 74.63%–83.49% margin alleged for China. If the investigation proceeds, the DOC will send Quantity and Value (Q&V) questionnaires to the relevant businesses, requiring responses within 14 days to select mandatory respondents. Typically, the DOC selects the two largest exporters based on USA Customs data and company responses.
Since the USA considers Vietnam a non-market economy, the DOC will use data from a third country to calculate the dumping margin. In this case, the petitioners propose Indonesia as the surrogate country due to its comparable economic development and presence of multiple polypropylene plastic container manufacturers. Interested parties have 60 days to provide comments on the surrogate country before the DOC issues its preliminary determination.
Under USA investigation procedures, the DOC has 20 days to review the petition and is expected to announce its initiation decision on April 7, 2025. If the USA International Trade Commission (ITC) determines within 45 days of receiving the petition that there is no injury to the domestic industry, the case will be dismissed; however, this outcome is unlikely.
If the DOC finds an urgent situation due to a surge in imports following the initiation of the investigation, it may impose provisional retroactive duties on imports within 90 days before the preliminary determination. The DOC then has 140 days to issue a preliminary anti-dumping determination and an additional 75 days for the final determination. The ITC will have another 45 days to issue its final injury determination. If both the DOC and ITC confirm dumping and injury, the DOC will issue an anti-dumping duty order within 7 days.
Given this situation, Vietnamese exporters should closely monitor the case, thoroughly understand USA investigation regulations and procedures, and fully cooperate with the DOC to avoid the risk of being subjected to the highest anti-dumping duties.
Additionally, businesses should prepare separate rate applications to prove independence from the government and qualify for lower duty rates. The deadline for submission is 21 days from the initiation of the investigation, with possible extensions upon the DOC’s approval.
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.
View the official document here.
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