7 Issues in Vietnam’s AD25 Anti-Dumping Investigation on Cold-Rolled Stainless Steel

On November 6, 2026, Vietnam’s Ministry of Industry and Trade opened an anti-dumping investigation into certain cold-rolled stainless steel originating in China, Indonesia and Taiwan (China). Decision 2948/QD-BCT took effect that day and opened case AD25 without imposing an anti-dumping duty.

Companies seeking to participate in AD25 can register as interested parties through the online system of the Trade Remedies Authority of Vietnam (TRAV). Foreign producers and exporters that receive a sampling questionnaire must also submit their answers to TRAV within the time allowed for that questionnaire.

Why Vietnam Opened the AD25 Anti-dumping Investigation

The Ministry opened the investigation after domestic steel producers filed a petition alleging that certain cold-rolled stainless steel imports were sold in Vietnam below their normal value and that those sales caused material injury to the domestic industry.

TRAV will examine export prices and the financial performance of domestic producers to determine whether dumping occurred and, if so, whether it caused the reported injury. Exporters, importers and industrial users may submit records and explanations relevant to those findings.

Quick Reference

TRAV’s public notice identifies January 5, 2027 as the deadline for interested-party registration. However, the date and the period stated in the signed annex are inconsistent. Businesses should aim to register before the published date and seek clarification from TRAV if the discrepancy could affect their filing.

Foreign producers and exporters generally have 10 days to respond to the sampling questionnaire, with receipt deemed to occur seven days after TRAV dispatches it. The period for examining export sales and dumping runs from October 1, 2025 to September 30, 2026.

7 Issues in Vietnam’s AD25 Anti-Dumping Investigation on Cold-Rolled Stainless Steel

Steel Products Covered by AD25

The investigation concerns cold-rolled stainless steel supplied as coils, sheets or strips with a thickness of up to and including 3.5 mm. The annex defines the relevant stainless steel as containing at least 10.5% chromium and no more than 1.2% carbon by weight. Products may have undergone annealing, heat treatment, pickling or descaling, while subsequent slitting, edge trimming, cutting to length or polishing does not necessarily remove them from the product description.

The notice excludes products thicker than 3.5 mm, multilayer or clad products combining stainless steel with another metal or material, and steel coated or plated with another metal or alloy. These exclusions depend on the product’s composition and construction, rather than simply its commercial name or appearance. For example, a polished finish is not the same as nickel plating. Where a supplier describes a product as “coated,” the importer should confirm the coating material and manufacturing process with the mill.

The notice lists the following Harmonized System (HS) codes for reference. Compare your customs classification and origin records with the mill certificate and technical specification for each item.

Heading 7219 – 7219.32.00, 7219.33.00, 7219.34.00, 7219.35.00, 7219.90.00.

Heading 7220 – 7220.20.10, 7220.20.90, 7220.90.10, 7220.90.90.

Countries of Origin Covered by the Investigation

AD25 covers products originating in China, Indonesia and Taiwan (China). Because a trader may invoice products from several mills or arrange shipment through a third-country port, companies should establish which mill produced each coil and retain the supporting origin documents. The seller’s invoice address or port of loading is not, on its own, sufficient to determine whether the goods fall within the investigation.

Vietnam’s previous measure on cold-rolled stainless steel, AD01, also covered Malaysia and ended in 2024. Because AD25 is a new investigation with its own product and origin requirements, the former duty rates provide no basis for calculating duties on current orders.

Dumping Margins Proposed by Local Producers

The domestic petitioners estimated dumping margins of 76.6% for China, 75.5% for Indonesia and 51.0% for Taiwan (China). A dumping margin is generally calculated by comparing the export price with normal value, rather than simply comparing the price of an imported coil with that of a Vietnamese product.

The Ministry will determine whether dumping occurred and whether a duty is warranted. Until then, buyers can use the proposed margins to estimate how a duty might affect the cost of a fixed-price order. The figures in the petition do not establish an amount payable at customs.

Registration for Interested Parties

TRAV encourages exporters, importers, distributors, traders and industrial users of the products to register as interested parties. A manufacturer purchasing steel through a Vietnamese distributor may have its own relevant evidence, including customer specifications, the availability of particular grades and the ability of domestic suppliers to meet demand. It may explain its interest in the case even if it was not the importer of record.

The official AD25 notice gives January 5, 2027 as the last day to register. The attached signed notice prints January 5, 2026, a date before initiation. Both texts also refer to 60 working days, which does not match the January 2027 date. Submit before the published January 5, 2027 date and seek written clarification from TRAV if timing affects the filing.

Companies seeking interested-party status should submit the application attached to the notice through TRAV online. The application must identify case AD25. The notice also permits an additional copy by post or email. Applicants should retain the submission receipt and check for TRAV’s confirmation of their status.

Sampling Questionnaires for Foreign Producers and Exporters

Under Decree 86/2025/ND-CP, TRAV must send sampling questionnaires within seven days of initiation to known foreign producers and exporters and to representatives of the exporting origins in Vietnam. Responses are due within 10 days of deemed receipt, which occurs seven days after dispatch. The dispatch date may be established by the postmark or TRAV’s public posting.

Exporters should check TRAV’s published notices as well as correspondence addressed to them. A producer or exporter supplying the goods to Vietnam should contact TRAV for the questionnaire if it was omitted from the petition. TRAV treats a foreign producer or exporter that misses the sampling deadline as non-cooperating and may rely on other available information when assessing its sales.

Where an origin has numerous suppliers or the investigation involves many product types, TRAV may select a sample of producers or exporters. A separate, full investigation questionnaire will then follow its own timetable, with responses generally due within 30 days of deemed receipt. A company requiring an extension should provide its reasons in writing and obtain confirmation from TRAV.

Sales and Purchase Records for the Investigation

TRAV will examine alleged dumping during October 1, 2025 – September 30, 2026 and injury to the domestic industry during October 1, 2022 – September 30, 2026. An overseas producer can begin by gathering its domestic and Vietnam sales records for the shorter period. Where a trading affiliate issues export invoices, the producer may need to coordinate with that affiliate while providing its own cost records and technical specifications.

Businesses should reconcile any differences among invoice quantities, customs declarations and sales ledgers before responding. Vietnamese importers should be able to link each imported shipment to the producer, the goods and the relevant entry date. TRAV may verify information on site, including at overseas premises, and companies submitting sensitive pricing or cost data should follow the requirements for confidential and non-confidential versions.

A Vietnamese manufacturer’s purchase records can help TRAV assess whether imported and domestic steel competed for the same orders. Dated quotations and delivery records can show whether suppliers offered the same grade, at what price and in what quantity.

Possible Duties on Orders Already Placed

The Minister may impose a provisional anti-dumping duty following a preliminary finding, but under Decree 86 it cannot take effect earlier than 60 days after the initiation decision. Businesses should therefore monitor subsequent decisions and confirm their effective dates and product coverage before calculating duties on particular shipments.

In limited circumstances, a later decision may apply to goods imported during the 90 days preceding the effective date of a provisional duty. This requires a final finding of material injury or threat of material injury, together with the prescribed findings concerning dumped imports and a sudden increase in import volume or quantity after initiation that caused injury difficult to remedy.

For existing orders, the buyer and seller should review the expected import date alongside the contract terms on import duties and price adjustments, including any clause covering changes in law. If either party proposes an earlier shipment or a larger quantity, they should first establish who would bear any additional duty and record the assumptions used to price the order.

Before issuing its final findings, TRAV will hold a public consultation at which parties to trade remedy proceedings in Vietnam can comment on the evidence. A buyer disputing a price comparison, for example, can submit specifications showing that the two offers concerned different grades of steel.

Frequently Asked Questions About Vietnam’s AD25 Anti-Dumping Investigation on Cold-Rolled Stainless Steel

Q1: Does a 3.5 mm sheet fall within the thickness limit?

Yes. The limit includes sheets measuring exactly 3.5 mm. Coverage also depends on origin, construction and surface treatment. For example, a sheet of that thickness may still qualify for the exclusion for multilayer products.

Q2: What if our supplier has received no questionnaire?

A supplier that has received no questionnaire should check TRAV’s AD25 postings, since public posting can establish the dispatch date. The case announcement identifies the officers responsible for questions about dumping and injury.

Q3: Can we still apply after the published registration date?

TRAV may accept a late registration at its discretion. An applicant should explain the reason for the delay when contacting TRAV. Acceptance of a late registration does not extend the time allowed to answer a questionnaire.

Q4: Is Taiwan’s investigation into Vietnamese steel part of AD25?

No. AD25 concerns certain steel imports into Vietnam, whereas Taiwan’s investigation into cold-rolled stainless steel from Vietnam concerns products entering Taiwan. Businesses trading in both directions should maintain separate records, correspondence and filing calendars for the two proceedings.