A circumvention inquiry filed June 4 could result in the imposition of antidumping duties on imports of tissue paper products from Vietnam that are produced using jumbo roll inputs from China.
Scope
The products covered by the AD order on tissue paper products from China are cut-to-length sheets of tissue paper with a basis weight not exceeding 29 grams per square meter. Subject merchandise may be bleached, dye-colored, surface-colored, glazed, surface-decorated or printed, sequined, crinkled, embossed, and/or die cut.
Covered tissue paper is in the form of cut-to-length sheets with a width equal to or greater than one-half inch. It may be flat or folded and may be packaged in a variety of ways, including banding, paper or film wrapping, plastic or film bags, and/or boxes for distribution to the ultimate consumer. Packages may contain tissue paper of a single color or style or multiple colors and/or styles.
Tissue paper products are typically classified under HTSUS headings 4802, 4804, 4805, 4806, 4808, 4820, 4823, and 9505.
Retroactive Application of Suspension and Duty Rates
The circumvention inquiry alleges that tissue paper products completed or assembled in Vietnam using jumbo roll inputs from China are circumventing the AD order on tissue paper products from China. The petitioner has requested that the inquiry be conducted on a country-wide basis.
The petitioner has also asked that the Department of Commerce instruct U.S. Customs and Border Protection to suspend liquidation and require cash deposits for imports of subject tissue paper products from Vietnam retroactively to a date prior to the publication of the initiation notice.
Next Steps
The DOC will evaluate the request and will likely initiate an inquiry to determine whether Vietnamese producers are circumventing the order. If the DOC Commerce issues an affirmative preliminary determination, U.S. importers will be required to post AD cash deposits on entries of subject merchandise dating back to a DOC-determined date prior to initiation of the inquiry.
Key issues, such as retroactive application, are often argued early in circumvention proceedings. Companies that engage strategically at these initial stages are best positioned to protect their interests and mitigate potential duty exposure. For more information, please contact Sandler, Travis & Rosenberg.
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