Vietnam’s Case AD25 Anti-Dumping Investigation: Survival & Procurement Guide for Vietnamese Stainless Steel Importers

HO CHI MINH CITY / HANOI, VIETNAM — On November 6, 2026, Vietnam’s Ministry of Industry and Trade (MOIT) issued Decision No. 2948/QD-BCT (Case No. AD25), launching an anti-dumping (AD) investigation into cold-rolled stainless steel flat products imported from China, Indonesia, and Taiwan.

Initiated following a petition from domestic producers Posco VST Co., Ltd. and Tan Viet Metal Science and Technology Co., Ltd., this investigation directly impacts Vietnam’s downstream fabricators, service centers, pipe/tube manufacturers, and trading companies. While no tariffs are currently collected at the border, petitioners have alleged aggressive preliminary dumping margins—up to 76.6% for China, 75.5% for Indonesia, and 51.0% for Taiwan. For Vietnamese importers, proactive compliance and supply chain planning over the next 60 days are critical to protecting profit margins and avoiding sudden provisional duty shocks in 2027.

1. Product Audit: Are Your Imported Coils, Sheets, or Strips Covered?

Before changing purchase orders, Vietnamese procurement teams must confirm whether their exact inventory falls within MOIT’s technical product scope.

Covered Products (Subject to Investigation)

• Product Forms: Cold-rolled stainless steel in coils, sheets, and strips.

• Gauge Thickness: 3.5 mm or thinner (annealed or unannealed; regardless of heat treatment, pickling, or descaling).

• Chemical Composition: Carbon content 1.2% or less by weight and chromium content 10.5% or higher by weight.

• Surface Finishes & Coatings: Standard finishes including No. 2D, No. 2B, No. 3, No. 4, HL, BA, and DULL, as well as steel with thin non-metallic functional layers (anti-fingerprint coatings, passivation layers, and temporary protective films such as PVC/PE laser films).

• Covered HS Codes: 7219.32.00, 7219.33.00, 7219.34.00, 7219.35.00, 7219.90.00, 7220.20.10, 7220.20.90, 7220.90.10, and 7220.90.90.

Explicit Exemptions (Safe from Case AD25)

1. Cold-rolled stainless steel flat products exceeding 3.5 mm in thickness.

2. Clad or laminated multi-layer products combining stainless steel with other materials.

3. Products coated, plated, or covered with other metals (such as zinc, tin, aluminum, chromium, copper, nickel, or their alloys).

2. Critical Timeline & What Vietnamese Importers Must Do Now

Under procedures managed by the Trade Remedies Authority of Vietnam (TRAV), Case AD25 follows a strict regulatory schedule. Missing early participation windows can leave your business exposed to punitive country-wide duty rates.

[Nov 6, 2026]   ──> Decision No. 2948/QD-BCT Takes Effect (No Immediate Duty Collected)
       │
[Jan 5, 2027]   ──> Mandatory Deadline to Register as an Interested Party (60 Working Days)
       │
[Q1–Q2 2027]    ──> Importer/Exporter Questionnaires, Verifications & Provisional Duty Ruling

4 Action Steps for Vietnamese Buyers & Distributors

1. Register as an Interested Party Before January 5, 2027: Vietnamese importers, traders, and end-user factories should register directly via TRAV’s online portal (online.trav.gov.vn) within 60 working days of initiation. Registering gives your company legal standing to submit comments, access non-confidential case files, and advocate against prohibitive duty rates on specialized grades not produced locally in Vietnam.

2. Audit Your Overseas Suppliers’ Participation: In anti-dumping cases, mills that cooperate with TRAV questionnaires receive individualized, lower duty rates, while non-cooperating suppliers get hit with the highest “all-others” rate. Confirm immediately whether your suppliers in China, Indonesia, or Taiwan intend to participate in Case AD25.

3. Review Q1/Q2 2027 Sales Contracts & Incoterms: If provisional anti-dumping duties are imposed in Q1 or Q2 2027, they apply upon customs clearance. Avoid locking into fixed-price long-term supply agreements with domestic Vietnamese customers under DDP/delivered terms without inserting a tariff/force majeure price-adjustment clause.

4. Lock In Strict Origin & Mill Test Certificate (MTC) Traceability: Vietnamese customs authorities will heighten origin inspections to prevent transshipment or certificate of origin (C/O) circumvention. Ensure every incoming shipment includes complete EN 10204 3.1 Mill Test Certificates (MTCs) detailing exact furnace Heat Numbers, melt origin, and valid Form E / Form AI / C/O documentation.

Importer Compliance & Risk Matrix

Frequently Asked Questions (FAQ) for Vietnamese Importers

• Are anti-dumping duties being charged on shipments arriving in Vietnam right now?

  No. Decision No. 2948/QD-BCT only initiates the investigation. Shipments clearing Vietnamese customs currently pay standard MFN or FTA import duties until TRAV issues a preliminary determination (typically 4 to 6 months after initiation).

• What if the specific stainless steel grade or finish I import is not manufactured in Vietnam?

  Vietnamese importers and downstream manufacturers can formally request product exclusions during the investigation by registering as an interested party before January 5, 2027, and submitting technical evidence proving domestic mills cannot supply the required specification.

• Can I switch sourcing to other origins to avoid Case AD25?

  Yes, sourcing cold-rolled flat products from non-subject origins (such as South Korea, Japan, India, or Europe) is outside Case AD25, provided the goods meet genuine substantial transformation rules and carry verified melt-and-pour MTC documentation.