The chassis orders show how antidumping law prices the same product three different ways

The highest cash deposit in the new chassis orders is 186.84 percent, and it falls on Vietnam, which supplied the smallest share of the trade. The country that supplied nearly all of it, Mexico, faces a countervailing duty rate of 76.91 percent and an antidumping cash deposit of zero^1,2,4. On June 18, 2026 the Department of Commerce issued antidumping orders on chassis and subassemblies from Mexico, Thailand and Vietnam, and countervailing duty orders on those from Mexico and Thailand^1,2. The orders are small in dollar terms but instructive as policy, because they show how the same finding of injury is turned into three quite different price penalties.

The instrument

Antidumping and countervailing duties are not tariffs in the sense of the Section 232 or Section 301 actions that dominate the news. They are remedies that a domestic industry must request, and they depend on two findings by two agencies. Commerce determines that imports are sold below normal value, or that a foreign government subsidized them. The U.S. International Trade Commission then determines whether a domestic industry is materially injured by reason of those imports. Only if both answers are yes does Commerce issue an order, under section 736 of the Tariff Act of 1930 for antidumping duties and section 706 for countervailing duties^2,7.

The chassis case followed that sequence over sixteen months. The U.S. Chassis Manufacturers Coalition, whose members are Cheetah Chassis Corporation of Berwick, Pennsylvania and Stoughton Trailers of Stoughton, Wisconsin, filed the petitions, and the Commission instituted the investigations on February 26, 2025³. Commerce published preliminary subsidy findings for Mexico and Thailand on August 1, 2025 and preliminary dumping findings for all three countries on September 29, 2025^1,2. Transport Topics reported that the government shutdown that began in November 2025 delayed the case by 47 days, with a further 21 days lost to a filing backlog⁴. The Commission scheduled its final phase on December 15, 2025 and held its hearing on April 21, 2026³. Commerce’s final determinations appeared on April 24^1,2. The Commission, with Commissioner David S. Johanson dissenting, found material injury in investigations 701-TA-755-756 and 731-TA-1734-1736, filed its determinations on June 8 and published them June 11³.

The mechanism: what the chassis orders cover and what they charge

The scope covers chassis and subassemblies, finished or unfinished, assembled or not, for carrying containers or other payloads by road, marine roll-on/roll-off or rail. It includes frames, running gear and axle assemblies, and pintle hooks and B-trains. Individual components entered by themselves are outside the scope, but components entered with a chassis are in it. Trimming, painting, assembly or other processing, whether in the country of manufacture or in a third country, does not take a chassis out of the orders. Dry van, refrigerated van and flatbed trailers are excluded, as are small light-duty trailers and light axle assemblies. Commerce lists HTSUS 8716.39.0090 and 8716.90.5060 as the usual classifications, notes that entries may also come in under 8716.90.5010, and says the written scope, not the tariff heading, is dispositive¹.

The rates are as follows^1,2:

• Mexico: a countervailing rate of 76.91 percent for ten named producers and all others. The antidumping margin of 32.37 percent is based on adverse facts available, and the cash deposit after subsidy offsets is 0.00 percent.
• Thailand: antidumping margins of 72.85 percent for Dee Siam Manufacturing and all others and 129.63 percent for Panus Assembly, plus countervailing rates of 10.72 percent for Dee Siam, 9.65 percent for Panus and 10.50 percent for all others.
• Vietnam: a single antidumping rate of 186.84 percent for the Thaco entities and the Vietnam-wide entity. No countervailing duty case was brought.

The Mexican zero is an arithmetical result, not a finding that Mexican producers sold at fair value. Commerce reduces an antidumping deposit by the export subsidies it finds in the companion countervailing case. For Thailand it found no export subsidies for Dee Siam, and it set Panus’s offset at zero as a further adverse inference, so the Thai deposits carry no reduction¹. Every Mexican rate, in both columns, rests on adverse facts available, and the same rates apply to all ten named producers and to all others^1,2.

Which chassis entries owe duties, and from when?

The timing is awkward for importers. Commerce says the duties reach entries made on or after September 29, 2025 for antidumping and August 1, 2025 for countervailing purposes, the dates of the preliminary determinations. They exclude a gap. Provisional antidumping measures may last four months, or six at the request of exporters, and Commerce granted six; they ended on March 27, 2026. Provisional countervailing measures last four months and ended before November 29, 2025. Entries made from those dates until the Commission’s notice appeared are liquidated without regard to the duties^1,2. Cash deposits resumed on June 11, the day that notice was published, and are now owed at entry alongside ordinary duties^1,2,3.

For an importer of record the practical consequences are three. Entries inside the provisional windows stay unliquidated until Commerce sends assessment instructions to U.S. Customs and Border Protection. Entries inside the gap are to be liquidated free of these duties. And any party that wants notice of later scope or circumvention requests has 30 days from June 18 to enter an appearance on the annual inquiry service list in Commerce’s ACCESS system¹.

The effect

Transport Topics, citing the petitioners, put 2024 imports from the three countries at nearly $1 billion, of which more than $950 million came from Mexico, more than $26.85 million from Thailand and more than $18.57 million from Vietnam⁴. The sole mandatory respondent in the Mexican case was Hyundai de Mexico, an affiliate of Hyundai Translead^2,4. The same report says the new duties are in addition to Section 232 steel derivative duties on the full value of imported chassis⁴.

So the weight of the remedy falls on a trade in which one origin dominates. A Mexican producer cannot obtain an antidumping benefit from its subsidy rate, and an importer of Mexican chassis pays a countervailing deposit in the high seventies. Thai producers pay a combined deposit of roughly 83 to 139 percent, adding the antidumping and countervailing columns. Vietnamese exporters face a rate that Commerce set for a single producer group and the country-wide entity^1,2. Stoughton’s chief executive, Bob Wahlin, said the ruling “sends a clear message that the U.S. government will not allow unfair trade practices”⁴. The sources used here contain no comment from the carriers, leasing companies or ports that buy chassis. Transport Topics reported that Hyundai Translead plans two facilities in Will County, Illinois while keeping its Rosarito, Mexico plant⁴.

The longer view

This is the second round of chassis remedies, and the first set the pattern. Commerce issued a countervailing duty order on Chinese chassis on May 10, 2021, at 44.32 percent for the CIMC companies and all others⁹. It followed with an antidumping order on July 8, 2021, which assigned the China-wide entity a margin of 188.05 percent and a deposit of 177.05 percent after the export-subsidy adjustment⁸. The Vietnamese rate now sits within two points of that Chinese margin^1,8.

The Chinese orders are themselves under review. The Commission instituted five-year reviews on April 1, 2026, with responses due May 1 and comments on their adequacy due June 9; the question is whether revocation would lead to continued or recurring injury⁵.

Another case is already moving, with an overlapping cast. On November 20, 2025 the American Trailer Manufacturers Coalition, whose members are Great Dane, Stoughton Trailers and Wabash National, petitioned against van-type trailers and subassemblies from Canada, China and Mexico, classified under the same two HTSUS subheadings, 8716.39.00 and 8716.90.50⁶. Commerce has preliminarily found subsidies for China and Mexico, has terminated the countervailing case against Canada, and has not yet issued its preliminary dumping findings. The Commission will place its prehearing staff report on the record on August 7 and hold its hearing on August 20, 2026⁶. The chassis orders last until a five-year review, subject to annual administrative reviews in which the deposit rates can be reset⁴. Whether the unusually wide spread between Mexican and Vietnamese rates narrows in those reviews is not something the record can yet answer.