Introduction
Vietnam anti-circumvention investigation on hot-rolled steel could start soon.
On September 18th, 2025, Vietnam’s Trade Remedies Authority confirmed the validity of a petition to examine whether Chinese exporters are circumventing existing anti-dumping duties by shipping hot-rolled steel coils wider than 1,880 mm.
The move signals a tougher stance after the government had already imposed definitive anti-dumping duties and rejected a proposed industry undertaking. This time, the goal is not to prove dumping again but to determine whether traders are dodging duties already in force, and to act swiftly if circumvention is proven.
Petition Acceptance Marks the Starting Point
The Vietnam anti-circumvention investigation on hot-rolled steel is triggered when the Ministry of Industry and Trade (MOIT), through its Trade Remedies Authority (TRAV), accepted a petition filed on September 10th, 2025 by domestic steel producers.
The petition alleges that certain Chinese mills are shifting to coils of width greater than 1,880 mm and less than 2,300 mm to avoid anti-dumping duties that currently apply to narrower coils.
Under law, the authority now has 45 days from September 18th, 2025 to decide whether to initiate a formal anti-circumvention investigation. This assessment phase focuses on evidence of trade-pattern changes, increases in import volumes or values, and the risk that such practices undermine existing duties.
The Legal Foundation: Decision 1959/QĐ-BCT
The Vietnam anti-circumvention investigation on hot-rolled steel is built on the earlier anti-dumping case known as AD20. On July 4th, 2025, the MOIT issued Decision 1959/QĐ-BCT, which imposed definitive anti-dumping duties ranging from 23.10 % to 27.83 % on hot-rolled steel coils of width up to 1,880 mm originating in China. Imports from India were examined but ultimately not subject to duties.
The duty rate of 23.10 %–27.83 % is therefore confirmed and legally effective only for products within the AD20 scope. Should the new anti-circumvention investigation conclude that wider coils are essentially the same product and used to evade duties, the Ministry can extend these existing rates to the wider coils for the remaining five-year duty period.
Rejection of a Price Undertaking: Decision 1958/QĐ-BCT
Just before the Vietnam anti-circumvention investigation on hot-rolled steel petition was filed, Chinese industry tried to avoid full duties. The China Iron & Steel Association (CISA), representing sixteen mills, proposed a price and quantity undertaking to replace the duties. On July 4th, 2025, the MOIT issued Decision 1958/QĐ-BCT, rejecting this proposal.
The Ministry explained that the undertaking lacked adequate cooperation, failed to provide a transparent reference price, did not guarantee quantities or prices sufficient to remedy injury, and offered no reliable enforcement mechanism. This rejection ensured that the full 23.10 %–27.83 % anti-dumping duties remained in force on products within the AD20 scope and underscored Vietnam’s determination to prevent circumvention.
Why Anti-Circumvention Matters
An anti-circumvention investigation is different from an anti-dumping investigation in Vietnam. It does not require calculating a new dumping margin. Instead, it examines whether traders are altering trade patterns, changing product specifications, or routing goods through third countries to defeat an existing duty.
Because it builds on a measure already in place, the process is generally faster, often six to nine months, and can lead to a swift extension of the original duty to cover evasive products or exporters. The Vietnam anti-circumvention investigation on hot-rolled steel therefore carries a more immediate commercial risk for importers and exporters than a standard anti-dumping case.
Potential Business Impact of Vietnam Anti-Circumvention Investigation On Hot-Rolled Steel
If Vietnam initiates a full anti-circumvention investigation and finds circumvention, the 23.10 %–27.83 % duty rates from Decision 1959/QĐ-BCT could be extended to extra-wide coils from China for the remainder of the original five-year period.
Vietnamese importers may face retroactive duty assessments, shipment delays, and cash-flow stress. Chinese exporters could suddenly find their wider coils subject to the same duty rate as their narrower coils. Even third country shippers who simply transship Chinese steel might be affected if their role is deemed a form of circumvention.
Compliance and Risk-Management Steps
Businesses exposed to the Vietnam anti-circumvention investigation on hot-rolled steel should act early. They should audit supply chains to prove substantial transformation outside China where applicable. They must keep detailed origin records, mill certificates, factory invoices, and shipping documents ready for customs verification. Monitoring official updates from Vietnam authorities is essential to meet deadlines and respond to questionnaires. Seeking specialist legal advice can help prepare robust responses or request product exclusions when justified.
The Broader Message
Vietnam anti-circumvention investigation on hot-rolled steel illustrates Vietnam’s increasingly assertive trade-remedy policy. By rejecting the Chinese industry’s proposed undertaking and validating a new anti-circumvention petition, the Ministry of Industry and Trade has made clear that superficial product changes will not escape duties.
If a full investigation is launched and circumvention is confirmed, Vietnam will extend the same 23.10 % to 27.83 % anti-dumping duties imposed under Decision 1959/QĐ-BCT to the targeted extra-wide products for the rest of the original five-year period. The message to global steel traders is unmistakable: altering specifications is no safe harbor.
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Source: https://antlawyers.vn/update/anti-circumvention-investigation-on-hot-rolled-steel-7-facts.html
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