- Case Details
September 18, 2025
Vietnam’s Trade Remedies Authority issued an announcement stating that, on September 10, 2025, a Vietnamese producer filed an application for an anti-circumvention investigation into HRC (Vietnamese: phẩm thép cán nóng) originating in China with a width greater than 1,880 mm and less than 2,300 mm.
October 27, 2025
Vietnam’s Ministry of Industry and Trade issued Announcement No. 3176/QD-BCT, stating that, upon application by a Vietnamese producer, it had initiated an anti-circumvention investigation in the anti-dumping case concerning HRC (Vietnamese: phẩm thép cán nóng) originating in China, to examine whether the products under investigation had been slightly modified into HRC with a width exceeding 1,880 mm and less than or equal to 2,300 mm for export to Vietnam in order to evade anti-dumping duties. The announcement took effect on the date of issuance.
April 2, 2026
Vietnam’s Ministry of Industry and Trade temporarily applied anti-circumvention trade remedy measures to certain hot-rolled steel plate products originating in the People’s Republic of China. The Vietnamese tariff codes of the products under investigation are 7208.25.00, 7208.26.00, 7208.27.19, 7208.27.99, 7208.36.00, 7208.37.00, 7208.38.00, 7208.39.20, 7208.39.40, 7208.39.90, 7208.52.00, 7208.53.00, 7208.54.90, 7208.90.90, 7211.14.15, 7211.14.16, 7211.14.19, 7211.19.13, 7211.19.19, 7211.90.12, 7211.90.19, 7225.30.90, 7225.40.90, 7225.99.90, 7226.91.10, and 7226.91.90. All producers and export enterprises of the People’s Republic of China are subject to an anti-dumping duty rate of 27.83
Products not subject to the temporary anti-circumvention trade remedy measures include: hot-rolled steel plate products with carbon content (by weight) > 0.30%; hot-rolled steel plate products in coil form with thickness ≥10 mm; hot-rolled steel plate products formally excluded from the scope of anti-dumping duties pursuant to Decision No. 1959/QĐ-BCT dated July 4, 2025; and steel plate products of grades BW450, BS700MCK2, AG700, and LG700T. This decision will take effect 15 days after the date of issuance.
- From Anti-Dumping to Anti-Circumvention: What Changed in the Export Data?
Previously, Vietnam’s anti-dumping duties on China’s hot-rolled coil products applied only to products with a width not exceeding 1,880 mm, leading many Chinese exporters to evade tariffs by “slightly adjusting” product specifications into the wider 1,880-2,300 mm range. This anti-circumvention investigation and the subsequent duty decision were intended to completely close this loophole. Under the new rules, hot-rolled steel coils with widths between 1,880 mm and 2,300 mm will also be included in the taxable scope and be subject to the same anti-dumping duty rate of 27.83 as the original products.
Figure 1 Relationship Between Total HRC Exports to Vietnam and Exports of Products Involved in the Anti-Circumvention Case
It can be seen that before the anti-dumping case was filed, China’s HRC exports to Vietnam mainly consisted of conventional-width coils below 1,880-2,300 mm. This was mainly because producing wide hot-rolled products above 2 meters requires special production lines, and the China steel mills capable of exporting such products were highly concentrated, mainly large steel enterprises such as Baowu, Angang, Bensteel Group, and WISCO, making them non-mainstream export products. After the preliminary anti-dumping ruling, the proportion of wide coils gradually increased.
Another set of data shows the following. First, if the preliminary anti-dumping ruling is taken as the time period, China’s HRC exports to Vietnam from January to June of that year had already plunged 46 YoY to 2.3165 million mt, while exports of wide coils surged 815 YoY to 1.2964 million mt. This was also the main support for why the decline in the average exports of China’s HRC to Vietnam was not obvious during the period from the preliminary anti-dumping ruling to the filing of the anti-circumvention case.
Second, if the filing of the anti-circumvention case is taken as the time period, as of December 2025, China’s total HRC exports to Vietnam were 1.0797 million mt, with a monthly average of 529,900 mt; exports of products involved in the anti-circumvention case totaled 627,000 mt, accounting for 58.08. In other words, in an extreme scenario, the establishment of anti-circumvention measures would reduce the monthly average of China’s HRC exports to Vietnam to 226,300 mt. Furthermore, if 2026 is taken as the time period, because the market had previously expected anti-circumvention measures to be implemented in December, some export traders still conducted transactions before then, so the data for November-December 2025 cannot fully reflect the actual reduction in export volumes caused by concerns over the confirmation of anti-circumvention measures. Since the beginning of 2026, China’s total HRC exports to Vietnam were 229,700 mt, with a monthly average of 114,800 mt; exports of products involved in the anti-circumvention case totaled 131,300 mt, accounting for 57.17. In other words, in an extreme scenario, the establishment of anti-circumvention measures would reduce the monthly average of China’s HRC exports to Vietnam to 49,200 mt, representing a decline of 3,789 YoY compared with the 2025 monthly average export volume.
- Impact of Anti-Circumvention Measures
It is thus evident that the further implementation of anti-circumvention measures will further narrow the channel for China’s hot-rolled products to be exported to Vietnam. Last year, Vietnam was still the largest market for China’s hot-rolled exports, but the export landscape may change significantly in the future as a result of this incident. For China’s export enterprises, they should seize the remaining 15-day “breathing space” and accelerate shipments of orders on hand. In the long run, they need to proactively adjust their product mix and pay more attention to export opportunities for high-end products.
