New AD/CVD Petitions: Chassis From Mexico, Thailand And Vietnam

On February 26, 2025, the US Chassis Manufacturers Coalition ("Petitioner") filed an antidumping duty ("ADD") petition on chassis and a countervailing duty (CVD) petition on imports of certain chassis and subassemblies from Mexico, Thailand, and Vietnam. These investigations aim to address unfair trade practices impacting the U.S. chassis industry.

This case follows the 2021 antidumping and countervailing duty orders imposed on chassis imports from China. However, the U.S. domestic chassis industry saw limited relief, as chassis imports from Mexico, Thailand, and Vietnam quickly replaced Chinese imports.

The Chinese state-owned producer China International Marine Containers (Group) Co., Ltd. ("CIMC") relocated its U.S. dedicated production capacity to a new facility in Thailand. About a billion dollars' worth of chassis and chassis parts were imported from these three countries in 2024.

Two federal agencies will conduct these AD/CVD investigations. The ITC will assess if the imports harmed the domestic industry, while the DOC will examine if they were sold at unfairly low prices ("dumping") or benefited from government subsidies. AD/CVD duties will only be imposed if the ITC finds material injury, or the DOC confirms dumping or subsidies.

Scope

This section outlines the specific products targeted by these investigations. Understanding the scope is crucial, as it determines which imports will be subject to potential duties.

The merchandise covered by these investigations consists of:

• Chassis and subassemblies, whether finished or unfinished
• Assembled or unassembled components, regardless of coating
• Any number of axles, designed for:
  • Carriage of containers
  • Other payloads (including self-supporting payloads)
  • Road, marine roll-on/roll-off (RORO), and/or rail transport

Chassis are typically comprised of the following:

• Rectangular framed trailers
• Suspension and axle systems
• Wheels and tires
• Brakes
• Lighting and electrical systems
• Coupling mechanisms for towing
• Locking systems to secure containers using:
  • Twistlocks
  • Slide pins

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

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 the following: 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.

Scope Exclusions:

• Dry Van Trailers:
  • Wholly enclosed cargo space with fixed sides, nose, floor, and roof
  • Articulated panels (doors) at the rear and occasionally on the sides
  • Permanently incorporated cargo space
• Refrigerated Van Trailers:
  • Wholly enclosed cargo space with fixed sides, nose, floor, and roof
  • Articulated panels (doors) at the rear and occasionally on the sides
  • Insulated cargo space with specific thermal properties for refrigeration
• Flatbed (Platform) Trailers:
  • Load-carrying main frames
  • Solid, flat, or stepped loading deck or floor
  • 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 and8716.90.5060. Imports of finished and unfinished chassis may also enter under HTSUS subheading8716.90.5010. While the HTSUS subheadings are provided for convenience and customs purposes, the written description of the merchandise under investigation is dispositive.

Alleged AD/CVD Margins

Petitioner estimated the following dumping margins:

1. Antidumping duty on chassis from Mexico: 33.37%

2. Antidumping duty on chassis from Thailand: 234.06%

3. Antidumping duty on chassis from Vietnam: 304.68%

Petitioner did not provide any specific subsidy margin calculations.

Named Exporters/ Producers

Petitioner included a list of companies that it believes are producers and exporters of the subject merchandise. See Petitioner's list of Petitioner's List of Chassis Producers and Exporters.

Named U.S. Importers

Petitioner did not include a list of companies that it believes are U.S. importers of the subject merchandise.

Estimated Schedule of Investigations

February 26, 2025 – Petitions filed

March 18, 2025 – DOC initiates investigation

March 19, 2025 – ITC Staff Conference

April 12, 2025 – ITC preliminary determination

July 26, 2025 – DOC CVD preliminary determination (assuming extended deadline) (5/22/25 – unextended)

September 24, 2025 – DOC AD preliminary determination (assuming extended deadline) (8/5/25 – unextended)

February 6, 2026 – DOC AD/CVD final determinations (extended)

March 23, 2026 – ITC final determination (extended)

March 30, 2026 – DOC AD/CVD orders issued (extended)

Conclusion and Implications for Stakeholders

These AD/CVD investigations on chassis imports will determine if antidumping duties or countervailing duties should be imposed on chassis imports from Mexico, Thailand, and Vietnam. The outcome could significantly impact the U.S. chassis industry and related trade regulations.

Potential Implications for Stakeholders:

• U.S. Manufacturers: If duties are imposed, domestic manufacturers could see reduced competition from low-cost imports, potentially increasing demand for U.S.-made chassis. However, supply chain disruptions and cost fluctuations for imported components could also occur.
• Importers and Distributors: Companies relying on chassis imports from Mexico, Thailand, or Vietnam may face higher costs due to AD/CVD duties. This could lead to price adjustments, supply chain restructuring, or shifts to alternative sourcing countries.
• Logistics and Transportation Industry: Increased costs or supply constraints could impact freight rates and container transport logistics, affecting operational efficiency and profitability.
• Policy Makers and Trade Associations: The investigations and potential duties could influence trade relations with Mexico, Thailand, and Vietnam.

Strategic Considerations:

• Stakeholders should monitor these investigations closely and assess potential financial impacts.
• U.S. manufacturers may consider scaling production or diversifying supply chains.
• Importers should evaluate alternative sourcing options or negotiate long-term contracts to mitigate potential cost increases.

These investigations underscore the importance of strategic planning and risk management in the U.S. chassis industry. By staying informed, stakeholders can better navigate their evolving trade landscape.