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With Vietnam positioned as the third-largest trading surplus partner with the United States, Vietnamese exports are increasingly becoming the focus of anti-dumping and countervailing duty investigations. U.S. probes are no longer confined to traditional agricultural and seafood products such as shrimp, pangasius, and honey, but have expanded into higher value-added processing and manufacturing areas including steel, wood, and renewable energy.
The report notes that the United States is the world’s largest importer. Competition from imported goods exerts pressure on U.S. domestic manufacturing, prompting U.S. authorities to seek solutions to limit imports through a range of trade defense tools. These include anti-dumping and countervailing measures, anti-evasion measures, safeguards, and provisions under Section 301 and Section 232 of the Trade Act, the Forced Labor Act, and most recently counter-tariffs.
According to WTO statistics cited in the report, the United States currently leads the world in both the number of investigations and the application of trade defense measures aimed at protecting domestic manufacturing.
In 2024, despite ranking third in trade surplus with the United States (after China and Mexico), Vietnamese goods were the target of the most investigations and trade defense measures in that market. To date, the United States has initiated 77 investigations out of 297 foreign investigations against Vietnam, representing almost 26%. These include 35 anti-dumping cases, 16 countervailing duty cases, 23 cases involving evasion of anti-dumping duties, and 3 safeguard cases.
The report says the range of investigated products is becoming more diverse, spanning both high-value and mid- to low-value items. Examples of high-value export products under investigation include wood, solar panels, steel, aluminum, and seafood such as shrimp and pangasius, as well as tires. Mid- and small-value products mentioned include paper bags, honey, and paper plates.
The number of anti-avoidance investigations has increased rapidly. Before the September 2021 amendments to anti-avoidance investigations, the number of such investigations initiated by the U.S. against Vietnam was 9. From September 2021 to date, the United States has initiated 14 out of 40 anti-avoidance cases against Vietnam, accounting for 35% of total anti-avoidance investigations against Vietnam to date. The report states these cases mainly focus on export products using inputs of Chinese origin.
Vietnamese products are also frequently subject to “cluster” investigations, where multiple measures are applied to the same product. The report cites examples including tires, solar panels, aluminum, and frozen warm-water shrimp.
In addition, the report describes “chum” investigations. It notes that Vietnam’s production structure is similar to China’s, and that China ranked fourth in direct investment into Vietnam in 2023, suggesting spillover effects. Because Vietnam participates in regional supply chains through multiple free trade agreements (FTAs), it is often investigated together with China and India.
The report highlights that the scope of investigations is expanding and the trend is tightening, with longer investigation times, particularly for anti-avoidance investigations. It also notes that because the United States has not recognized Vietnam as a market economy, it uses the costs of a third country (replacement) to calculate normal value in relevant cases, making outcomes less predictable.
Further, the report says the United States uses substitute-country thresholds when calculating subsidy margins, which can raise margins. It also notes that these thresholds can increase the likelihood that a firm is deemed to evade anti-dumping or countervailing measures.
In response to the tightening trend of U.S. anti-dumping and countervailing investigations, Vietnam has developed a legal framework under the Foreign Trade Management Law and related circulars to guide responses to trade remedy cases. The Ministry of Industry and Trade has also established an early warning system to help businesses identify litigation risks based on fluctuations in export indicators.
The report states that enterprise response capabilities have improved. It notes that major sectors such as shrimp and pangasius are familiar with U.S. reviews and have achieved 0% tariffs through transparent accounting systems.
Despite these improvements, the report identifies difficulties in responding to U.S. cases. Not being recognized as a market economy places Vietnamese firms at a disadvantage when calculating taxes using replacement-country values. The report also says that pursuing U.S. cases is extremely costly, creating a heavy burden for small and medium-sized enterprises. Vietnam still lacks a team of lawyers and experts who can litigate directly in English and deeply understand the DOC’s complex calculation methods.
To improve effectiveness in responding to U.S. trade remedies, the report recommends:
Drawing on international experience from China and India, the report concludes that response efforts are no longer the responsibility of any single enterprise. It describes the work as a legal battle requiring an “organic linkage” among three players: the State, which creates legal and diplomatic frameworks; associations, which connect and guide; and enterprises, which implement directly while ensuring governance transparency.
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