Vietnam’s AD22 Anti-Dumping Case
On 18 July 2025, Vietnam’s Ministry of Industry and Trade (MoIT) initiated an anti-dumping investigation into colorless float glass from Indonesia and Malaysia (case AD22). The investigated goods are classified under HS 7005.29.20 / 7005.29.90. The case was opened upon a petition from domestic producers alleging dumped imports and material injury.
Foreign producers and exporters have been issued an official questionnaire and must submit responses by the end of 8 September 2025 (Hanoi time). Submissions must be made through TRAV ONLINE, and the filing is only considered timely after all documents are uploaded. Then, send a signed hard copy (confirmation page) and a USB containing the full submission to the authority’s Hanoi address.
MoIT’s public notice confirms the deadline and references Notice No. 109/TB-PVTM (1 Aug 2025). The authority emphasizes confidentiality protection under the Law on Foreign Trade Management and warns that non-cooperation or late/incomplete responses may trigger “facts available” treatment.
Definition: The product is colorless float glass produced by horizontal drawing/float process, without mesh core and without absorbent/reflective/non-reflective coatings; not unprocessed optical glass.
POI & injury period: Dumping POI (Jul 2024 – Jun 2025); injury period (Jul 2021 – Jun 2025).
Alleged margins (from petition/decision summary): Indonesia ~60.68%; Malaysia ~23.02% (indicative at this stage; actual rates depend on the investigation).
1. Register and download the pack. Use questionnaire from the authority’s sites/TRAV ONLINE.
2. Prepare two versions: Confidential and Limited circulation (non-confidential) electronic sets, with proper bracketed redactions and meaningful summaries.
3. Submit via TRAV ONLINE first; then signed hard copy (confirmation page) plus USB to Trade Remedies Authority of Vietnam.
4. Audit your sales & cost trails. Align invoice, payment, shipment, and accounting records to the POI; reconcile to financials. (If selected for on-site verification, this is where most submissions crack.) The authority has explicitly reserved the right to verify on site.
5. Coordinate with importers & end-users in Vietnam. Their questionnaire data (prices/volumes/uses) often corroborate your narrative and gaps can invite adverse inferences.
6. Register as an interested/related party within the designated window to receive disclosures and participate fully.
7. If timing is tight, request an extension early. Vietnam practice allows extensions on reasoned requests.
Failing to respond on time or supplying incomplete/incorrect information can lead the authority to apply “facts available,” which typically results in much higher provisional/final margins than cooperative respondents. The notice is explicit on this point.
Master product mapping: thickness, sizes, processing, and how your models fit the scope definition.
Sales databases: POI exports to Vietnam; home-market/third-country sales as required; transaction-by-transaction with price terms and adjustments.
Cost of production (COP): Bills of materials, utilities, labor, depreciation, yield/loss, overhead allocation keys.
Affiliations & ownership: Any links with Vietnam importers or other entities in the chain.
Policy & process memos: Discounts/rebates, freight policies, warranty, and accounting practices (to show consistency).
Verification kit: Index of source records (trial balance, ledgers, invoices, GRNs, payment proofs) and ready for on-site review.
Given parallel float glass trade actions in other jurisdictions, multijurisdictional alignment of your data story matters. While each system differs, consistency across filings protects credibility and reduces the risk of adverse inferences.
We help clients overcome cultural barriers and achieve their strategic and financial outcomes, while ensuring the best interest protection, risk mitigation and regulatory compliance. ANT Lawyers has lawyers in Ho Chi Minh city, Hanoi, and Danang, and will help customers in doing business in Vietnam.
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