New Antidumping and Countervailing Duty Petitions on Certain Chassis and Subassemblies Thereof from Mexico, Thailand and Vietnam

Introduction

On February 26, 2025, domestic producers filed petitions with the U.S. Department of Commerce (DOC) and the U.S. International Trade Commission (ITC), seeking antidumping (AD) duties on imports of certain chassis and subassemblies thereof from Mexico, Thailand and Vietnam, and countervailing duties (CVD) on such imports from Mexico and Thailand.

Petitioners include the U.S. Chassis Manufacturers Coalition (Coalition) and two members of the Coalition, Cheetah Chassis Corporation and Stoughton Trailers, LLC.

According to Petitioners, imports of the covered merchandise into the United States from the identified countries significantly increased in 2022, with total import values of approximately $996 million in calendar year 2024. Petitioners also allege that the increase in imports from the identified countries came shortly after the chassis industry successfully obtained relief from unfair imports of similar merchandise through the imposition of AD and CVD orders on certain chassis and subassemblies thereof from the People’s Republic of China in 2021 (China Orders).

Under U.S. law, a domestic industry can petition the government to initiate an AD investigation into the pricing of an imported product to determine whether it is sold in the United States at less than fair value (i.e., “dumped”). A domestic industry can also petition the government to initiate a CVD investigation regarding the alleged unfair subsidization of foreign producers by a foreign government. Additional duties can be imposed if DOC determines that imported goods are “dumped” and/or unfairly subsidized, and if the ITC makes an affirmative determination with respect to injury by reason of imports.

If the ITC and DOC make preliminary affirmative determinations, U.S. importers will be required to post cash deposits in the amount of the AD and/or CVD for all entries on or after the date DOC’s preliminary determinations are published in the Federal Register. The preliminary AD/CVD rates can change in the final DOC determinations, especially if foreign producers and their governments participate fully in the investigations.

Scope

The physical characteristics of the covered products, which define the scope, are as follows:

• 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.
• 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.

The scope excludes dry van trailers, refrigerated van trailers and flatbed trailers, and includes a detailed description of such trailers.

As observed in the scope proposed by Petitioners, 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.

A full description of the proposed scope is provided in Attachment 1.

The proposed scope for the new AD and CVD petitions on chassis and subassemblies closely mirrors the scope of the existing China Orders, differing in only two aspects. First, unlike the China Orders, the proposed scope for the new petitions does not explicitly include “landing gear” in the list of subassemblies subject to the scope. The absence of landing gear from the list does not necessarily imply that such merchandise is excluded from the proposed scope, as the list is not exhaustive. Second, the proposed scope for the new petitions refers to axle components as “dressed axles,” whereas the scope of the China Orders simply refers to such components as “axles.”

Foreign Producers and Exporters of Subject Merchandise

A list of foreign producers and exporters of certain chassis and subassemblies thereof, as identified in the petitions, is provided in Attachment 2.

US Importers of Subject Merchandise

A list of the U.S. importers of certain chassis and subassemblies thereof, as identified in the petitions, is also provided in Attachment 3.

Alleged Margins of Dumping/Subsidization

Petitioners allege the following dumping margins:

• Mexico: 32.37%
• Thailand: 234.06%
• Vietnam: 304.68%

DOC generally assigns duties at these alleged dumping rates to exporters that fail to cooperate during the investigation.

The petitions include no specific subsidy rates.

Potential Trade Impact

According to official U.S. import statistics, total imports of chassis and subassemblies nearly reached $1 billion in value in 2024. Of this amount, the vast majority—$950,244,022—was imported from Mexico, while a total of $26,850,082 was imported from Thailand and a total of $18,573,022 was imported from Vietnam.

Estimated Schedule of Investigations

02/26/2025     Petitions filed.

04/14/2025     ITC preliminary injury determination.

05/22/2025     DOC preliminary CVD determinations, if not postponed.

07/26/2025     DOC preliminary CVD determinations, if fully postponed.

08/05/2025     DOC preliminary AD determinations, if not postponed.

09/24/2025     DOC preliminary AD determinations, if fully postponed.

02/13/2026     DOC final AD and CVD determinations, if both preliminary and final determinations are fully postponed.

04/06/2026     ITC final injury determination, if DOC’s determinations are fully postponed.

04/13/2026     AD/CVD orders published.