On April 9, 2025, the Canada Border Services Agency (CBSA) released its Statement of Essential Facts (SEF) in the ongoing anti-circumvention investigation into semi-trailers imported from Vietnam.
According to the SEF, CBSA’s preliminary assessment concludes that semi-trailers from Vietnam are not engaged in circumvention of Canada’s trade defense duties currently applied to similar products from China.
1. Background of the Investigation
Table of Contents
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On January 19, 2022, CBSA issued a final determination confirming that China had engaged in dumping and subsidization of semi-trailer products.
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Subsequently, on February 18, 2022, the Canadian International Trade Tribunal (CITT) determined that such imports from China caused injury to Canada’s domestic industry and decided to impose anti-dumping and countervailing duties on these products.
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On November 25, 2024, based on allegations filed by Max-Atlas International Inc., CBSA initiated an anti-circumvention investigation to verify whether semi-trailers imported from Vietnam were being used to evade existing duties imposed on Chinese products.
The investigated products are primarily classified under HS code 8716.39, but may also fall under 8706.00, 8716.40, 8716.80, and 8716.90.
The current duties on products originating from or imported from China include:
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Anti-dumping duty: 126.4%
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Countervailing duty: 12,370 RMB per unit
2. CBSA’s Preliminary Findings
After conducting its preliminary investigation, CBSA presented several key conclusions:
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Significant Change in Trade Flows:
Between 2021 and September 2024, imports of semi-trailers from China decreased sharply — from 49% of total imports down to 1%. Meanwhile, imports from Vietnam rose dramatically from 0% in 2021–2022 to 34% in 2023. -
Negligible Chinese Component Usage:
The share of Chinese-origin parts and components in Vietnam’s total semi-trailer production cost is insignificant. -
Substantial Domestic Value Addition:
Upon reviewing the cost structure of production in Vietnam — including labor, management, and raw materials— and comparing these to total production costs, CBSA determined that Vietnam’s production activities represent a substantial portion of the total value.CBSA also noted evidence of large-scale investments in infrastructure, machinery, and R&D activities in Vietnam, concluding that the manufacturing process in Vietnam is not a minor or insignificant transformationof Chinese-origin materials.
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Preliminary Assessment:
While there has been a clear shift in trade volumes from China to Vietnam, CBSA does not find sufficient evidence to conclude that such imports from Vietnam constitute circumvention of Canada’s trade defense duties on Chinese semi-trailers.
3. Next Steps
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Comment Submission: Interested parties may submit comments on the SEF by 12:00 p.m. (Eastern Time), April 16, 2025.
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Response Submission: Responses to submitted comments must be filed by 12:00 p.m., April 23, 2025.
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Final Determination: CBSA is expected to issue its final conclusion by May 23, 2025.
The full SEF document can be accessed through the file titled:
📄 20250410_-_Statement_of_Essential_facts_1d05a.pdf
Contact Information
For more details, please contact:
Department of Trade Remedies – Foreign Trade Remedies Division
Ministry of Industry and Trade (MOIT), Vietnam
📍 Address: 23 Ngo Quyen, Hoan Kiem, Hanoi
📧 Emails: kiennh@moit.gov.vn | ngocny@moit.gov.vn
👤 Officer in Charge: Nguyen Hoang Kien
📱 Mobile: +84 94 261 3889