Two distinct trade remedy developments affect different segments of U.S. import supply chains: an ITC injury determination on polypropylene corrugated boxes from Vietnam, and Commerce Department initiation of administrative reviews covering large diameter welded pipe from Türkiye.

The U.S. International Trade Commission (ITC) issued an affirmative material injury determination in the antidumping duty investigation of polypropylene corrugated boxes from Vietnam. The ITC found that the U.S. polypropylene corrugated box industry is materially injured by reason of imports from Vietnam sold at less than fair value (LTFV).

An affirmative ITC injury determination is the final step required before Commerce can issue an antidumping duty order. With the ITC’s determination in place, Commerce will issue an antidumping duty order imposing duties on covered imports.

Practical Implications for Importers

• Cash deposit requirements: Importers of covered merchandise from Vietnam will be required to post cash deposits at the applicable antidumping duty rate at entry
• HTSUS classification: Importers should verify correct classification under applicable HTSUS subheadings
• Liquidation risk: Entries made during the investigation period remain unliquidated pending the final order
• Supplier contracts: Review contracts for antidumping duty indemnification provisions, price adjustment mechanisms, and termination rights
• Sourcing alternatives: Evaluate alternative sourcing including domestic production and imports from non-subject countries

The Commerce Department initiated administrative reviews of existing antidumping and countervailing duty orders, including reviews covering large diameter welded pipe (LDWP) from Türkiye. Administrative reviews are annual proceedings in which Commerce recalculates dumping margins or subsidy rates for specific exporters/producers based on their actual sales and costs during the review period.

Large diameter welded pipe is used in oil and gas pipelines, water transmission, structural applications, and infrastructure construction.

Practical Implications

• Cash deposit rate changes: The review outcome changes the cash deposit rate applicable to future entries from reviewed exporters/producers
• Assessment of past entries: Reviews result in assessment of final duties on entries made during the review period — replacing cash deposits posted at entry
• No-shipment certifications: Exporters/producers that made no shipments during the review period may request a no-shipment certification
• Review participation: Parties that want to influence the review outcome must participate by submitting questionnaire responses; failure to participate can result in adverse facts available (AFA) rates

Both developments illustrate the ongoing complexity of U.S. trade remedy law. Importers should also be aware of:

• Classification disputes: Scope ruling requests to Commerce can resolve ambiguity about whether a specific product variant falls within an order
• Circumvention: Commerce actively investigates attempts to avoid duties by routing products through third countries or making minor alterations to covered products

Importers, exporters, customs brokers, and supply chain participants in the affected product categories should review their HTSUS classification, cash-deposit exposure, supplier contracts, and administrative-review participation rights promptly.