The plywood determinations are the third attempt to fence one product, and each fence follows the trade

On July 16 the Department of Commerce announced final affirmative determinations that hardwood and decorative plywood from China, Indonesia and Vietnam is sold in the United States at less than fair value and subsidized by all three governments⁷. The notices appeared in the Federal Register on July 21^1,5. As news, it is the expected end of a case the Coalition for Fair Trade in Hardwood Plywood filed on May 22, 2025⁹. As policy, it is something more particular. This is the third time the Commission and Commerce have examined plywood from China, and the second time the trade remedy has had to chase the product into another country^10,12. The new scope is drawn around what the 2018 China orders left out, and it reaches Vietnam and Indonesia directly rather than through circumvention findings^6,10.

The instrument: Title VII and the two-agency test

Antidumping and countervailing duties come from Title VII of the Tariff Act of 1930. They are not presidential tools. Commerce decides whether goods are sold below fair value or benefit from countervailable subsidies, and the U.S. International Trade Commission decides separately whether those imports materially injure, or threaten to injure, a domestic industry^1,11. Only if both answers are yes does Commerce issue an order, and the duty applies only to the merchandise in the written scope¹.

That last point is why the scope matters so much here. Commerce’s China dumping notice says that if the Commission finds no injury, “this proceeding will be terminated, all cash deposits will be refunded or canceled, and suspension of liquidation will be lifted”¹. If it finds injury, the duty reaches back to the first entries suspended in the case¹. The Commission’s notices list 35 HTS subheadings, all in heading 4412¹¹, but the scope language governs and carves out several product groups, among them plywood already covered by the January 2018 China orders and multilayered wood flooring under the 2011 flooring orders⁶.

The petitioner is a coalition of five producers: Columbia Forest Products of Greensboro, North Carolina; Commonwealth Plywood of Whitehall, New York; Manthei Wood Products of Petoskey, Michigan; States Industries of Eugene, Oregon; and Timber Products Company of Springfield, Oregon⁷. Its counsel, Timothy C. Brightbill of Wiley Rein, said at the preliminary stage that the domestic industry “has been harmed for decades by dumped and subsidized hardwood and decorative plywood”¹⁴.

The mechanism: three countries, three kinds of rate

The rates diverge because the cooperation did.

China. The two Chinese companies selected for examination, Linyi Evergreen Wood and Xuzhou Shelter Import and Export, did not answer Commerce’s antidumping questionnaire, and nine other producers ignored its quantity-and-value questionnaire¹. Commerce treated them as part of an uncooperative China-wide entity and applied adverse facts available¹. No party commented on the preliminary dumping finding, so the final rate is unchanged: a 187.27 percent margin and a 185.96 percent cash deposit rate after a subsidy offset, for every exporter, including the four that earned separate-rate status¹. The subsidy rate, also built on adverse inferences, is 88.96 percent for all producers², up from a preliminary 81.34 percent, according to Lesprom¹³. Combined, Chinese panels in scope face cash deposits of 274.92 percent¹³. Commerce also found critical circumstances, so suspension of liquidation reaches back to December 2, 2025, 90 days before the preliminary dumping notice¹.

Indonesia. Here the respondents participated, and the rates are calculated. PT Wijaya Cahaya Timber’s dumping deposit is 15.39 percent and PT Sengon Indah Mas’s is 23.78 percent; the all-others rate is 18.06 percent; and PT Mustika Buana Sejahtera, treated under adverse inferences, is at 84.94 percent³. Subsidy rates run from 4.22 percent for Sengon Indah Mas to 58.39 percent for Wijaya Cahaya Timber, with 40.87 percent for all others and 128.66 percent for Mustika Buana Sejahtera⁴. Summed, the deposits run from about 28 percent for Sengon Indah Mas to about 214 percent for Mustika Buana Sejahtera^3,4.

Vietnam. The largest change came here. At the preliminary stage in March, Commerce set a 196.14 percent dumping margin for the separate-rate companies⁸. The final margin is 90.12 percent, with an 84.95 percent cash deposit rate, applied to 52 companies with separate rates and to the Vietnam-wide entity, because Trieu Thai’s rate was the only calculated one that was not zero, de minimis or based on facts available⁵. Commerce made “certain changes” after verification and comments, set out in a decision memorandum⁵. Subsidy rates are 47.68 percent for Trieu Thai and all others, and 165.39 percent for Junma Phu Tho, which also drew a critical-circumstances finding the others avoided⁶.

Timing matters for importers. Antidumping suspension continues for entries from March 2, 2026^1,3. Countervailing provisional measures, by statute limited to four months, ended for entries on or after May 22, 2026, so subsidy deposits are not now collected and will resume only if orders issue^2,4,6. Commerce is also holding back the subsidy-offset adjustment to the China dumping deposit until the Commission rules¹.

The effect: who pays, and what the Commission is weighing

The Commission’s preliminary report gives the volume picture. Cumulated subject imports fell from 2.1 billion square feet in 2022 to 928.7 million in 2023, then rose to 1.3 billion square feet in 2024, still 38.4 percent below 2022¹⁰. Interim 2025 imports, at 372.9 million square feet, were 18.2 percent above the year-earlier period¹⁰. Market shares were withheld as business proprietary¹⁰.

The case is not evenly documented. Indonesian producers that answered the Commission’s questionnaires accounted for 95.3 percent of subject imports from Indonesia in 2024, while responding Chinese producers covered 3.7 percent of Chinese production and Vietnamese producers 16.3 percent of Vietnam’s subject imports¹⁰. That pattern mirrors Commerce’s: China’s rates rest on adverse facts, Indonesia’s on calculations^1,3.

The sharpest dispute concerns Indonesia. Respondents argued that Indonesian imports “overwhelmingly consist of tropical thin plywood that is exclusively used in the RV industry,” and the RV Industry Association filed a written statement¹⁰. The Commission was unpersuaded at the preliminary stage, finding the largest channel for Indonesian plywood was sales to distributors, the domestic industry’s own largest channel¹⁰. Recreational-vehicle builders, cabinet makers and distributors are the buyers who would bear any order. Chinese panels already carried a 25 percent Section 301 duty, the Commission noted in 2025¹⁰.

The longer view: Plywood I, Plywood II and the Vietnam workaround

The first attempt failed. In 2013 the Commission reached a negative determination on hardwood plywood from China, in what its later report calls Plywood I¹⁰. A second petition succeeded in 2017, and Commerce issued antidumping and countervailing duty orders on January 4, 2018^10,12. Those orders set a China-wide dumping rate of 183.36 percent and an all-others subsidy rate of 22.98 percent¹².

The trade moved. In July 2023 Commerce found that hardwood plywood completed in Vietnam from Chinese veneers and core platforms was circumventing the China orders, and set up a certification regime: Vietnamese exporters who could not certify non-Chinese inputs paid the China rates¹². Circumvention findings extend an existing order; they do not create a case against a new country’s own production. This petition does. It also reaches products the 2018 orders missed: panels with a softwood face or back, panels without a core, and decorative two-ply panels¹⁰. The Commission treats imports already under the old orders, including the Vietnamese circumvention panels, as nonsubject¹⁰. Similar country-by-country layering appears in the chassis orders, where a 2021 China order was followed by cases on Mexico, Thailand and Vietnam.

What remains is the Commission’s vote. Its hearing was scheduled for July 16, posthearing briefs and nonparty statements were due July 23, the record closes August 12 and final comments are due August 14¹¹. Commerce’s notices say the vote must come no later than 45 days after the final determinations¹. An affirmative finding would put new orders on top of the 2018 ones. A negative one for any country would end that country’s case and refund its deposits^1,4.