Potential AD/CVD for Mexican, Vietnamese, & Thai Chassis

Apr. 24, 2026
By: Chaney A. Finn

The U.S. Department of Commerce finalized its findings that could result in steep (in some cases reaching triple-digit rates) antidumping and countervailing duties imposed on chassis imports from Mexico, Vietnam, and Thailand. Investigations concluded that exporters in these countries sold chassis and subassemblies at unfairly low prices, triggering proposed duties outlined below:

• Vietnam (potentially) faces the harshest antidumping measure, with a potential 186.84% rate applied nationwide. Vietnam does not face additional countervailing duties.

• Mexico’s exports could see orders for both AD/CVD at rates of 32.37% antidumping duty and a 76.91% countervailing duty. Commerce indicated specific rates to several firms, including a subsidiary of Hyundai that manufactures transportation trailers.

• Thailand’s chassis imports could incur a 72.85% antidumping duty overall. Commerce specified that one firm, Panus Assembly Co. Ltd., obstructed the investigation, consequently risking a much higher 129.63% rate. Countervailing duties for Thailand remain lower, averaging 10.5%, with slight company-specific adjustments.

For purposes of the investigations the scope is

chassis and subassemblies thereof whether finished or unfinished, whether assembled or unassembled, whether coated or uncoated, regardless of the number of axles, for carriage of containers, or other payloads (including self-supporting payloads) for road, marine roll-on/roll-off (RORO) and/or rail transport. Chassis are typically, but are not limited to, rectangular framed trailers with a suspension and axle system, wheels and tires, brakes, a lighting and electrical system, a coupling for towing behind a truck tractor, and a locking system or systems to secure the shipping container or containers to the chassis using twistlocks, slide pins or similar attachment devices to engage the corner fittings on the container or other payload.

Subject merchandise includes, but is not limited to, the following subassemblies:

• Chassis frames, or sections of chassis frames, including kingpin assemblies, bolsters consisting of transverse beams with locking or support mechanisms, goosenecks, drop assemblies, extension mechanisms and/or rear impact guards;

• Running gear assemblies or axle assemblies for connection to the chassis frame, whether fixed in nature or capable of sliding fore and aft or lifting up and lowering down, which may or may not include suspension(s) (mechanical or pneumatic), wheel end components, slack adjusters, dressed axles, brake chambers, locking pins, and tires and wheels; and

• Assemblies that connect to the chassis frame or a section of the chassis frame, such as but not limited to, pintle hooks or B-trains (which include a fifth wheel), which are capable of connecting a chassis to a converter dolly or another chassis.

Importation of any of these subassemblies, whether assembled or unassembled, constitutes an unfinished chassis for purposes of this investigation.

Subject merchandise also includes chassis, whether finished or unfinished, entered with components such as, but not limited to: hub and drum assemblies, brake assemblies (either drum or disc), bare axles, brake chambers, suspensions and suspension components, wheel end components, landing gear legs, spoke or disc wheels, tires, brake control systems, electrical harnesses and lighting systems.

Processing of finished and unfinished chassis and components such as trimming, cutting, grinding, notching, punching, drilling, painting, coating, staining, finishing, assembly, or any other processing either in the country of manufacture of the in-scope product or in a third country does not remove the product from the scope. Inclusion of other components not identified as comprising the finished or unfinished chassis does not remove the product from the scope.

Individual components entered and sold by themselves are not subject to the investigation, but components entered with a finished or unfinished chassis are subject merchandise. A finished chassis is ultimately comprised of several different types of subassemblies. Within each subassembly there are numerous components that comprise a given subassembly.

This scope excludes dry van trailers, refrigerated van trailers and flatbed trailers. Dry van trailers are trailers with a wholly enclosed cargo space comprised of fixed sides, nose, floor and roof, with articulated panels (doors) across the rear and occasionally at selected places on the sides, with the cargo space being permanently incorporated in the trailer itself. Refrigerated van trailers are trailers with a wholly enclosed cargo space comprised of fixed sides, nose, floor and roof, with articulated panels (doors) across the rear and occasionally at selected places on the sides, with the cargo space being permanently incorporated in the trailer and being insulated, possessing specific thermal properties intended for use with self-contained refrigeration systems. Flatbed (or platform) trailers consist of load carrying main frames and a solid, flat or stepped loading deck or floor permanently incorporated with and supported by frame rails and cross members.

The scope also excludes fully and permanently assembled trailers that have permanently incorporated floors welded to the frame without a locking mechanism, a gross axle weight ratings of 8,000 lbs or less, and that connect to Federal Highway Administration Class 3 or Class 5 vehicles with a coupler rated for SAE J684 Standard Class 4, whether entered with or without neck, ramp, dove tail, or dump/safety arm components. The scope also excludes fully dressed axle subassemblies with a gross axle weight rating of 8,000 lbs or less, an outer diameter of the axle beam of three inches or less, and eight or fewer lug nuts.

The finished and unfinished chassis subject to this investigation are typically classified in the Harmonized Tariff Schedule of the United States (HTSUS) at subheadings: 8716.39.0090 and 8716.90.5060. Imports of finished and unfinished chassis may also enter under HTSUS subheading 8716.90.5010. While the HTSUS subheadings are provided for convenience and customs purposes, the written description of the merchandise under investigation is dispositive.

These measures are not yet in force. The U.S. International Trade Commission must still determine whether the imports harm or threaten domestic industry. That decision, expected within 45 days, will decide whether the duties take effect.

Should you have any questions about AD/CVD, or any other trade-related questions, do not hesitate to contact any attorney at Barnes Richardson and Colburn, LLP.