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Petition Summary: Certain Chassis and Subassemblies Thereof from Mexico, Thailand, and the Socialist Republic of Vietnam | Husch Blackwell LLP
On February 26, 2025, the U.S. Chassis Manufactures Coalition (“Coalition” or “Petitioner”), filed a petition for the imposition of antidumping and countervailing duties on U.S. imports of certain chassis and subassemblies thereof from Mexico, Thailand, and the Socialist Republic of Vietnam.
SCOPE OF THE INVESTIGATION
The merchandise covered by these investigations consists of 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 these investigations. Subject merchandise also includes chassis, whether finished or unfinished, entered with or for further assembly with components such as, but not limited to: hub and drum assemblies, brake assemblies (either drum or disc), dressed 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 investigations, but components entered with or for further assembly 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 finished and unfinished chassis subject to these investigations 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.
PETITIONERS
U.S. Chassis Manufacturers Coalition
Cheetah Chassis Corporation
3rd & Oak Streets
P.O. Box 388
Berwick, PA 18603
Stoughton Trailers LLC
416 S. Academy Street
Stoughton, WI 53589
COUNSEL FOR PETITIONER
Wiley Rein, LLP
2050 M. Street, NW
Washington, DC 20036
NAMED PRODUCERS/EXPORTERS
For a list of foreign producers/exporters alleged by Petitioner, please see Attachment I.
NAMED IMPORTERS
The petition refers to the list of foreign producers and exporters of subject merchandise in identifying the list of known exporters. The petition also indicates that there may be additional importers that are not known to petitioner and requests that U.S. Department of Commerce (“Commerce”) and the U.S. International Trade Commission (“ITC”) obtain this information from U.S. Customs and Border Protection.
ESTIMATED SCHEDULE
Below is an estimated schedule. Please note that Commerce deadlines are likely to be extended for the AD investigation as authorized by statute.
| Event | Earliest Date | Extended Date |
| Petition Filed | February 26, 2025 | |
| DOC Initiation | March 18, 2025 | |
| ITC Preliminary Investigation: | ||
| Questionnaires Due | March 12, 2025 | |
| Request to appear at hearing | March 17, 2025 | |
| Hearing | March 19, 2025 | |
| Briefs | March 24, 2025 | |
| ITC Vote | April 12, 2025 | |
| DOC Investigation Schedule: | ||
| DOC Preliminary Antidumping Determination | August 5, 2025 | September 24, 2025 |
| DOC Final Antidumping Determination | October 19, 2025 | February 6, 2026 |
| ITC Final Investigation: | ||
| ITC Final AD Determination | December 3, 2025 | March 23, 2026 |
ALLEGED DUMPING MARGINS
Mexico: 32.37%
Thailand: 234.06%
Vietnam: 304.68%
ALLEGED COUNTERVAILING DUTY MARGINS
Above de minimis.
IMPORTS OF SUBJECT MERCHANDISE
| 2022 | 2023 | 2024 | |
| U.S. Imports from: | Quantity in Units | ||
| Mexico | 30,560 | 41,481 | 40,550 |
| Thailand | 1.325 | 1,038 | 596 |
| Vietnam | 714 | 983 | 824 |
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