Cambodia steel wire garment hangers: preliminary circumvention of China and Vietnam orders
Country-wide prelim circumvention for Cambodia-completed hangers using Chinese or Vietnamese inputs. Third-country case numbers, dual certification, and post-summary corrections.
Commerce preliminarily determines that steel wire garment hangers completed in Cambodia using Chinese- or Vietnamese-origin steel wire (or steel wire and paper accessories) are circumventing the China AD order and the Vietnam AD/CVD orders on steel wire garment hangers. Applicable September 22, 2026 (91 FR 60086; FR Doc. 2026-19376). Underlying cases A-570-918, A-552-812, and C-552-813.
Cambodia hangers with China/Vietnam steel wire (or wire plus paper accessories): prelim country-wide circumvention. Suspend from Aug 12, 2025 Initiation. Default deposits at Vietnam-wide AD 220.68% and all-others CVD 31.58% (A-555-812 / C-555-813), unless dual certification shows Chinese inputs (A-555-918).
Inquiry merchandise
These circumvention inquiries cover hangers completed in Cambodia using either (1) steel wire or (2) steel wire and paper accessories produced in China or Vietnam, where the hangers are subsequently exported from Cambodia to the United States. Commerce initiated country-wide inquiries on August 12, 2025, and identified Alpha Hanger (Cambodia) Co., Ltd as the sole mandatory respondent.
Suspension and cash deposits
Suspend unliquidated inquiry merchandise on/after Aug 12, 2025 (Initiation Notice)
Default third-country case nos.: A-555-812 (Vietnam AD) · C-555-813 (Vietnam CVD)
Default deposits: Vietnam-wide AD 220.68% · all-others CVD 31.58%
China-input certified entries: third-country case A-555-918 (China AD rate)
Under 19 CFR 351.226(l)(2), Commerce will direct CBP to suspend liquidation and require cash deposits on unliquidated entries of inquiry merchandise entered, or withdrawn from warehouse for consumption, on or after August 12, 2025. Where China and Vietnam orders both potentially apply, Commerce intends to instruct CBP to collect deposits at the Vietnam Orders rates under third-country case numbers A-555-812 and C-555-813. For entries where both the exporter and importer certify Chinese-origin steel wire or steel wire and paper accessories under Commerce's dual circumvention certification program, deposits use the China AD rate under third-country case number A-555-918.
Post-summary corrections (type 01 to type 03, third-country case numbers, cash deposits) apply to unliquidated entries (and entries for which liquidation has not become final) entered on or after August 12, 2025 and before publication of this preliminary determination. Separately, the FR certification grace covers hangers entered from August 12, 2025 through 45 days after publication where the entry has not been liquidated (and entries for which liquidation has not become final): complete and upload certifications to ACE DIS as soon as practicable, but not later than 45 days after publication. After that grace window, importer certifications are due by entry summary and producer certifications by time of shipment. Alpha Hanger, Everbrit, and Kaining are preliminarily ineligible to certify Chinese-origin inputs (AFA).
Certification program (ops)
Commerce is not preliminarily allowing parties to certify that hanger inputs are from a third country other than China or Vietnam. The dual certification program lets eligible parties certify Chinese (rather than Vietnamese) steel wire or steel wire and paper accessories, with supporting documentation to CBP at entry summary via ACE DIS (after the 45-day grace window described above), and with AD/CVD Certification Designation type code 6 on the importer's additional declaration (record 54). Case briefs are due no later than seven days after publication; rebuttals five days after case briefs.
AD/CVD cash deposits and assessed duties remain generally outside drawback (AD/CVD drawback exclusion).
- Prelim country-wide circumvention: Cambodia-completed steel wire garment hangers using Chinese or Vietnamese steel wire (or wire plus paper accessories) under China AD Order A-570-918 and Vietnam Orders A-552-812 / C-552-813 (91 FR 60086; FR Doc. 2026-19376; applicable Sept 22, 2026).
- Suspend and collect deposits on unliquidated inquiry merchandise entered on or after August 12, 2025 (Initiation).
- Default deposits: Vietnam-wide AD 220.68% and all-others CVD 31.58% under A-555-812 / C-555-813; Chinese-input certified entries use A-555-918 at the China AD rate.
- Post-summary corrections: pre-publication unliquidated entries (Aug 12, 2025 to publication), including where liquidation has not become final. Certification grace: unliquidated (or not-finally-liquidated) entries Aug 12, 2025 through 45 days after publication, due within 45 days of publication; thereafter certify by entry summary / shipment.
- Alpha Hanger, Everbrit, and Kaining ineligible to certify Chinese inputs. Case briefs within 7 days of publication. AD/CVD generally outside drawback.
- Steel Wire Garment Hangers From the People's Republic of China and the Socialist Republic of Vietnam: Preliminary Affirmative Determination of Circumvention of the Antidumping Duty Order on Steel Wire Garment Hangers From the People's Republic of China and the Antidumping and Countervailing Duty Orders on Steel Wire Garment Hangers From the Socialist Republic of Vietnam (91 FR 60086; FR Doc. 2026-19376) · International Trade Administration, Department of Commerce
This article is for general information and is not legal or tax advice. Drawback eligibility depends on your specific facts, and final refunds are determined by CBP at liquidation. Consult a licensed customs broker or attorney for your situation.