The Department of Commerce has self-initiated a new inquiry to determine whether imports of stainless steel flat-rolled products from China that are completed in Vietnam and then exported to the U.S. are circumventing the antidumping and countervailing duty orders on stainless steel sheet and strip from China. The DOC is also self-initiating a concurrent scope inquiry to determine if stainless steel sheet and strip from Vietnam is within the scope of the AD/CV duty orders on such goods from China, as the scope language of those orders states that they include stainless steel sheet and strip that has undergone certain types of minor processing in third countries.

If the DOC preliminarily determines that circumvention is occurring, it will instruct U.S. Customs and Border Protection to begin collecting AD/CV cash deposits on imports of stainless steel sheet and strip completed in Vietnam using Chinese-origin stainless steel flat-rolled inputs and/or Chinese-origin stainless sheet and strip further processed in Vietnam. For products found to be circumventing the AD/CV duty orders, or subject to their scope, duties will be imposed on future imports and on any unliquidated entries from the date of initiation of the anti-circumvention inquiry.

The DOC will next solicit information from producers and exporters of the goods under investigation. There will be strict deadlines associated with these proceedings, so companies that wish to protect their interests should contact Sandler, Travis & Rosenberg as soon as possible.

For more information please contact Kristen Smith at (202) 730-4965.

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