U.S. Finalizes Review on Anti-Circumvention of Trade Remedy Measures
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The U.S. Department of Commerce (DOC) has announced the final results of the administrative review of anti-circumvention concerning anti-dumping (AD) and countervailing (CVD) duties imposed on Light-Walled Rectangular Pipe and Tube (LWR Pipe) originating from China (Case Nos. A-570-914 and C-570-915).
This review was initiated on October 18, 2023, at the request of a Vietnamese respondent company, covering the period of review (POR) from 2022 to 2023.
Key Findings of the DOC’s Final Determination
On September 13, 2024, the DOC issued its preliminary determination, finding that the sole Vietnamese respondentin the case used only hot-rolled steel (HRS) sourced from Vietnam to produce its rectangular steel pipe exports to the United States during the review period.
The DOC verified that:
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The company maintained invoices and purchase records for its hot-rolled steel inputs;
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It demonstrated full traceability of the material’s origin; and
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It qualified for the certification mechanism confirming non-use of Chinese-origin HRS.
As a result, the DOC’s final determination remains unchanged from the preliminary results, confirming that the Vietnamese company is eligible for exemption from the application of AD/CVD measures related to Chinese steel.
A Positive Outcome for Vietnam’s Steel Exporters
This represents a favorable outcome for Vietnamese exporters, especially given the DOC’s previous 2023 final determination in the original anti-circumvention investigation, where the same company was denied certification due to insufficient cooperation.
The latest conclusion demonstrates that Vietnamese enterprises can maintain access to the U.S. market by:
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Strictly complying with DOC requirements;
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Fully cooperating in verification and documentation; and
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Proving transparent sourcing of raw materials during subsequent administrative reviews.
Background of the Anti-Circumvention Investigation
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On August 4, 2022, the DOC initiated an anti-circumvention investigation into imports of Light-Walled Rectangular Pipe and Tube (LWR Pipe) from Vietnam.
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The investigation alleged that Vietnam was importing hot-rolled steel (HRS) — the primary raw material for pipe production — from China and Taiwan, performing minor processing, and exporting the finished pipes to the U.S. to circumvent existing AD and CVD orders on Chinese and Taiwanese products.
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These measures were originally imposed to offset unfair trade practices and subsidies identified in earlier cases against Chinese and Taiwanese steel exporters.
Significance and Compliance Outlook
The case underscores the importance of transparency and traceability in Vietnam’s steel supply chain.
By maintaining clear documentation and proving local or third-party sourcing independent from restricted countries, Vietnamese exporters can avoid punitive duties and continue participating in key markets such as the United States.
The final ruling also signals that the U.S. DOC remains open to recognizing legitimate Vietnamese manufacturing operations that meet compliance and certification standards.
Contact Information
Foreign Trade Remedies Division – Trade Remedies Authority of Vietnam
Ministry of Industry and Trade
Address: 54 Hai Ba Trung, Hoan Kiem District, Hanoi, Vietnam
Email: thona@moit.gov.vn, nganha@moit.gov.vn