In late September, U.S. steel producers AK Steel Corporation, ArcelorMittal USA, California Steel Industries, Nucor Corporation, Steel Dynamics, and United States Steel Corporation filed petitions requesting the U.S. Department of Commerce (DOC) initiate investigations on whether imports of cold-rolled and corrosion-resistant steel from Vietnam are circumventing the antidumping and countervailing duty (AD/CVD) orders on imports of both types of steel from China to avoid the corresponding AD/CVD duties ranging from 238 to 456 percent of the value of the imports.

The U.S. steel producers have alleged that China Minmetals Corporation, a large state-owned Chinese metal trading firm, is arranging for Chinese hot-rolled steel to be cold-rolled, and in some cases galvanized, in Vietnam before exporting the steel to the U.S. They note that Vietnam has no installed capacity to produce hot-rolled steel and that imports from Vietnam surged into the U.S. market from zero before the AD/CVD petitions on China were filed to over 300,000 tons in the first half of 2016, more than replacing the pre-petition Chinese volumes. They argue the cold-rolling and galvanizing of the Chinese hot-rolled steel in Vietnam are “minor or insignificant” processing such that DOC should find that these Vietnamese exports to the U.S. circumvent the AD/CVD orders on Chinese steel and, thus, DOC should treat the steel imports from Vietnam as covered by the AD/CVD orders on Chinese steel.

DOC has until the week of November 7-11 to either issue a ruling based on the circumvention petitions or initiate a formal circumvention investigation, in which case DOC will request comments and factual information from interested parties and issue a final determination by early September 2017.