
On March 17, 2025, the U.S. Department of Commerce (DOC) received a petition requesting an anti-dumping (AD) investigation on polypropylene plastic containers imported from Vietnam, and both anti-dumping and countervailing duty (CVD) investigations on the same products from China. Vietnam is only subject to the anti-dumping investigation, not the CVD investigation.
1. Case Overview
Table of Contents
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Product under investigation: Polypropylene plastic containers, classified under HS code 3923.10.9000
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Case number: A-552-850
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Petitioners: CoolSeal USA, Inteplast Group, and SeaCa Plastic Packaging & Technology Container
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Date of filing: March 17, 2025
According to data submitted by the petitioners (based on U.S. Customs statistics), in 2024:
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Vietnam exported over USD 6 million worth of the investigated products to the U.S., accounting for 19.4% of total imports.
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China exported USD 13.4 million, or 43.3% of total imports.
Together, the two countries represented 62.7% of total U.S. imports of the subject merchandise.
The petition names seven Vietnamese exporters accused of dumping. If the investigation is initiated, DOC is expected to issue a Quantity and Value (Q&V) questionnaire (due within 14 days) to collect export data and select mandatory respondents (usually the two largest Vietnamese exporters).
Vietnamese exporters are advised to:
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Register for an IA ACCESS account at https://access.trade.gov/login.aspx to submit documentation and follow updates;
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Respond promptly to DOC questionnaires, including the Q&V form and the Separate Rate Application, proving independence from government control to qualify for individual duty rates (due within 21 days from the initiation notice). Extensions may be requested but must be approved by DOC.
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Alleged dumping margin for Vietnam: 40.85% (significantly lower than China’s alleged margin of 74.63%–83.49%).
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Surrogate country and values: As the U.S. considers Vietnam a non-market economy, DOC will use third-country surrogate values to calculate dumping margins. The petitioners propose Indonesia as the surrogate country, citing its similar level of development and active polypropylene container production. Interested parties have 60 days before the preliminary determination to comment on the surrogate country selection.
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Proposed investigation periods:
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Dumping investigation period: July 1 – December 31, 2024
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Injury investigation period: January 1, 2022 – December 31, 2024
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2. Investigation Procedure
According to U.S. trade remedy regulations, two agencies are involved in an AD investigation:
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DOC investigates dumping and determines the dumping margin.
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U.S. International Trade Commission (ITC) assesses whether the U.S. domestic industry suffers material injury.
An anti-dumping duty will only be imposed if both agencies issue affirmative determinations.
Timeline (estimated):
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March 17, 2025: DOC receives the petition.
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By April 7, 2025: DOC decides whether to initiate the investigation (within 20 days).
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Within 45 days: ITC issues a preliminary injury determination. If negative, the case ends.
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Within 140 days: DOC issues a preliminary dumping determination. In urgent cases, DOC may apply retroactive duties up to 90 days before the preliminary decision.
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Within 75 days: DOC issues its final dumping determination.
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Within 45 days: ITC issues its final injury determination.
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Within 7 days: DOC publishes the final anti-dumping duty order (if both results are affirmative).
(Timelines may be extended depending on case complexity.)
3. Recommendations
For Industry Associations:
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Notify relevant Vietnamese exporters and assist in preparing defense strategies if the DOC initiates the case.
For Exporting Enterprises:
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Closely monitor developments and study U.S. anti-dumping procedures;
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Fully cooperate with DOC — failure to respond adequately may result in adverse facts available (AFA) and the highest dumping duty rates;
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Register on IA ACCESS to track updates and file documents;
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Coordinate with the Trade Remedies Authority of Vietnam (TRAV) for timely support.
Contact Information
Foreign Trade Remedies Division
Trade Remedies Authority of Vietnam (TRAV)
Ministry of Industry and Trade (MOIT)
📍 54 Hai Bà Trưng, Hoàn Kiếm, Hà Nội, Vietnam
📞 Mr. Bùi Anh Dũng – Tel: (024) 7303 7898
📧 Email: dungban@moit.gov.vn | ngocny@moit.gov.vn
🌐 Website: http://trav.gov.vn

