CBSA Preliminary Determinations: Truck Bodies from China

Concerning the preliminary determinations with respect to the dumping and subsidizing of truck bodies originating in or exported from China.

Decision

Ottawa,

March 20, 2026

Pursuant to subsection 38(1) of the Special Import Measures Act, the Canada Border Services Agency made preliminary determinations on March 6, 2026, respecting the dumping and subsidizing of truck bodies originating in or exported from the People’s Republic of China.

Statement of reasons—Preliminary determinations: Truck Bodies (TB 2025 IN)

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Summary

[1] As a result of a written complaint from Morgan Canada Corporation and Morgan Transit Corporation (collectively, “the complainants”), on October 24, 2025, pursuant to subsection 31(1) of the Special Import Measures Act (SIMA), the CBSA initiated investigations respecting the dumping and subsidizing of truck bodies originating in or exported from the People’s Republic of China (China).

[2] Upon receiving notice of the initiation of the investigations, the Canadian International Trade Tribunal (CITT) commenced a preliminary injury inquiry, pursuant to subsection 34(2) of SIMA, into whether the evidence discloses a reasonable indication that the dumping and subsidizing of the above-mentioned goods have caused injury or are threatening to cause injury to the Canadian industry producing the like goods.

[3] On December 23, 2025, pursuant to subsection 37.1(1) of SIMA, the CITT made a preliminary determination that there is evidence that discloses a reasonable indication that the dumping and subsidizing of truck bodies from China have caused or are threatening to cause injury to the domestic industry.

[4] On March 6, 2026, as a result of the CBSA’s preliminary investigations and pursuant to subsection 38(1) of SIMA, the CBSA made preliminary determinations of dumping and subsidizing of truck bodies originating in or exported from China.

[5] On the same date, pursuant to subsection 8(1) of SIMA, provisional duties were imposed on imports of dumped and/or subsidized goods that are of the same description as any goods to which the preliminary determinations apply, and that are released during the period commencing on the day the preliminary determinations were made and ending on the earlier of the day on which the CBSA causes the investigations in respect of any goods to be terminated pursuant to subsection 41(1) of SIMA or the day the CITT makes an order or finding pursuant to subsection 43(1) of SIMA. Where an exporter’s estimated amount of subsidy is insignificant, provisional countervailing duty will not be applied.

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Period of investigation

[6] The period of investigation (POI) for the investigations is July 1, 2024, to June 30, 2025.

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Profitability analysis period

[7] The profitability analysis period (PAP) for the investigations is July 1, 2024, to June 30, 2025.

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Interested parties

[8] Interested parties were notified at the initiation of the investigations and were sent requests for information (RFI). Refer to the Statement of reasons—Initiation of investigations: Truck Bodies (TB 2025 IN) for additional information on interested parties.

Exporters

[9] One exporter, Qingdao CIMC Reefer Trailer Co., Ltd. (CIMC Reefer) provided substantially complete responses to the CBSA’s dumping, subsidy and section 20 RFIs and subsequent supplemental RFIs (SRFI). Footnote 1

Importers

[10] One importer provided a response to the importer RFI and subsequent SRFI, Vanguard Refrigerated Trailer Co., Ltd. (Vanguard). Footnote 2

Surrogates

[11] The CBSA received one response to the surrogate producer RFI and subsequent SRFI from Morgan Truck Body, LLC (Morgan Truck Body), a producer of truck bodies in the United States. Footnote 3

[12] The CBSA also received responses to the surrogate producer RFI from a producer in Thailand, Dee Siam Manufacturing Co., Ltd. (Dee Siam), Footnote 4 and its related suppliers, Dongguan CIMC Vehicle Co., Ltd. (Dongguan CIMC), Footnote 5 and CIMC Vehicle (Jiangmen) Co., Ltd. (CIMC Vehicle). Footnote 6 The CBSA notes that these responses were received over two months after the original RFI deadline, and could not be considered for purposes of the preliminary determinations. Further, due to the processes completed by Dee Siam, the CBSA does not consider the company a suitable surrogate for the purposes of estimating normal values.

Government

[13] The Government of China provided a partially complete response to the government subsidy RFI and subsequent SRFI, Footnote 7 however it did not provide a response to the government Section 20 RFI.

Canadian producers

[14] Four Canadian producers provided a response to the Canadian industry profit survey RFI: Morgan Canada, Footnote 8 Morgan Transit, Footnote 9 Intercontinental Truck Body (B.C.) Inc., Footnote 10 and Intercontinental Truck Body Ltd. Footnote 11 All four producers were sent a supplemental RFI concerning their cost of production of truck bodies. The CBSA received a response from both Morgan Canada Footnote 12 and Morgan Transit. Footnote 13

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Product information

Definition

[15] For the purpose of these investigations, subject goods are defined as:

Truck bodies, having an exterior length of 8.5 feet to 32 feet, inclusively, of maximum exterior width of 103 inches, whether assembled or unassembled, being the structure or fixture designed to be affixed to a truck chassis for the primary purpose of containing or supporting goods for on-road transportation, whether insulated or not, and whether equipped with refrigerating equipment or not, as well as truck body kits, assemblies, or subassemblies, originating in or exported from the People’s Republic of China, excluding:

1. truck bodies for the primary purpose of bulk transporting liquids or gases
2. refuse truck bodies, being specialized truck bodies designed and constructed for the primary purpose of collecting, compacting, and transporting solid waste, of the kind used for municipal waste collection and
3. truck bodies that incorporate a hydraulic or mechanical system that permits the body to be elevated, tipped, or tilted for loading or unloading, such as dump truck bodies used for the transport of bulk materials such as sand, gravel, or demolition debris, and flatbed tow truck bodies used for the transport of vehicles

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Additional product information Footnote 14

[16] A truck body is a broad term that describes the load-carrying structure mounted on a truck chassis (often also known as a “cab chassis”, a “cab and chassis”, or a “cut-away chassis”). A truck body can encompass a wide range of types, including enclosed cargo bodies, refrigerated bodies, and flatbeds.

[17] For greater certainty, the subject goods include enclosed dry freight bodies, refrigerated bodies, and other cargo-carrying truck bodies, whether or not equipped with auxiliary equipment such as liftgates, cargo handling systems, or custom interior fittings, provided that the primary purpose of the body remains the transportation of goods. The presence of such auxiliary equipment or fittings does not alter the classification of the goods as subject truck bodies.

[18] Truck bodies do not include the truck chassis, which include the vehicle’s frame and drivetrain; truck bodies relate only to the structure or fixture that attaches or affixes to the chassis of the vehicle. Trucks and vehicles and their parts, such as wheels, axles, cabs or suspensions are not subject goods.

[19] Goods that are pulled by a truck or truck chassis, rather than mounted onto or affixed to the chassis, are not within the scope of the subject goods. The product definition is limited to truck bodies that form an integral structure of the vehicle itself, not separate towable equipment. For example, semi-trailers, container chassis, and other detachable trailers are not included because they are not “structures designed to be affixed to a truck chassis.” They are instead designed to be hitched to and hauled by a truck, rather than mounted on or affixed to a truck chassis.

[20] As the subject goods expressly have as their primary purpose the transportation of goods (other than bulk liquids or gases), they do not include bodies designed primarily for the transportation of passengers or the provision of non-cargo services, such as recreational vehicles, motorhomes, firetrucks, buses, or designed primarily for other specialized service vehicles such as man-bucket trucks or boom trucks that do not have as their primary purpose the transportation of goods. For greater certainty, the determination of whether a truck body is included in the subject goods is made at the time of importation, based on its design and purpose at that point in time. The fact that equipment or features may later be added to the body post-importation, which alter its use or purpose, does not exclude it from the scope of the subject goods as defined at the time of entry.

[21] The reference to “exterior length” in the product definition means the measurement taken from the outer surface of the front wall of the truck body to the outer surface at the rear of the truck body, excluding any ancillary equipment affixed to the structure. Such excluded equipment includes, but is not limited to, refrigeration units, liftgates, catwalks, aerodynamic fairings, lighting assemblies, or any other removable or accessory components.

[22] The product definition expressly includes subassemblies that are designed and intended to be assembled or constructed into a truck body. This encompasses both completely knocked down (CKD) and semi-knocked down (SKD) truck bodies. In industry practice, CKD and SKD refer to kits consisting of all or most of the subassemblies required to construct a truck body, shipped in a disassembled state for ease of transport or to avoid or minimize duties. A CKD kit generally contains all essential subassemblies in a fully disassembled form, while an SKD kit contains some or most subassemblies that can be quickly joined together. The Subject goods include complete or substantially complete Footnote 15 subassemblies such as subframes, structural frames, walls or wall panels, floors, rear frames, freight doors, roofs, interior fit-out, or electrical systems. The list of components described above is a non-exhaustive list and the absence of a good from that list does not mean the good is excluded.

[23] Although the subject goods include unassembled truck bodies or unassembled assemblies or subassemblies thereof, the subject goods do not include the individual parts or components that may be used to manufacture a truck body or its subassemblies when imported as individual components. For example, steel I-beams, plywood sheets, or sheets of aluminum are not subject goods unless they form part of a subassembly or assembly.

Exclusions

[24] The exemption that excludes truck bodies for the primary purpose of bulk transport of liquids or gases is limited to tanker-style bodies that are specifically designed and constructed for such use. It does not extend to truck bodies used to transport liquids or gases in packaged or containerized form, which remain within the scope of the subject goods.

[25] The exemption for truck bodies that incorporate a hydraulic or mechanical system that permits the body or flatbed to be moved or tilted for the purpose of loading or unloading goods applies to dump trucks and rollback truck bodies. These bodies are distinguishable from subject truck bodies by the presence of an integrated hydraulic or mechanical tilting or lifting mechanism that enables the movement of the body or flatbed, separate from the chassis. This exclusion applies to dump truck bodies designed and constructed for the transport of bulk materials such as sand, gravel, or demolition debris that incorporate a hydraulic or mechanical system that permits the body to be elevated for unloading the payload by tipping. This exclusion likewise applies to rollback truck bodies-also known as rollback tow bodies or slide beds-which are designed and constructed for towing vehicles and which deploy a tilting and sliding flatbed platform to load vehicles. The hydraulic system permits the flatbed to tilt back and slide rearward until it touches the ground, which creates a ramp onto which the vehicle is pulled using a winch system.

[26] The exemption for refuse truck bodies applies to specialized truck bodies designed and constructed for the primary purpose of all three of: collecting, compacting, and transporting solid waste. These bodies are distinguished by integrated features such as hydraulic lifting mechanisms, compactors, and reinforced rear compartments, and are typically configured as front-load, side-load, or rear-load garbage collection vehicles. This exclusion applies narrowly to refuse truck bodies whose core design and function is waste collection and disposal, whether for municipal, commercial or institutional use. It does not extend to other truck bodies that may incidentally be used to transport waste but are not purpose-built refuse bodies. For example, truck bodies for the transportation of specialized or institutional waste (e.g., hospital waste) are not excluded and remain within the scope of the product definition. For clarity, this exemption is limited to purpose-built refuse truck bodies. It does not exclude other truck bodies merely because they can be used to carry waste.

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Production process Footnote 16

[27] The standard production process for truck bodies involves the fabrication of the steel and aluminum subframe and the manufacture of the truck body’s subassemblies.

[28] The manufacturing process for truck bodies begins with the fabrication of the structural subframe. Footnote 17 The subframe is a structure that mounts beneath the truck body frame and connects it securely to the truck chassis, acting as an interface and load distributor. This provides the foundational strength necessary to support the payload and withstand road stresses. The subframe is typically constructed using high-strength steel I-beams, which are arranged longitudinally and transversely to create a rigid platform. These I-beams serve as the primary load-bearing elements and are often reinforced with cross-members welded at regular intervals to ensure structural integrity and torsional resistance. In some configurations, aluminum or galvanized steel may also be used for weight reduction or corrosion resistance. Customers are able to request and build to their unique configuration requirements.

[29] The mounting structure, including the subframe, is engineered to fit with the chassis frame rails of commercial trucks, and the components of the truck body are fabricated to meet the load-bearing, durability, and dimensional requirements of freight transport.

[30] Within the truck body industry, certain elements such as the chassis mounting interface are generally standardized. Many medium- and heavy-duty truck chassis sold in Canada, such as those manufactured by Chevrolet, Freightliner, International, Hino, Isuzu, Ford and Mack, among others, are built with common frame rail spacing within each vehicle class. This allows truck body manufacturers to produce bodies and subframes that can be mounted on multiple brands of chassis within a given class, with minimal modification.

[31] Above this standardized mounting interface, truck bodies can be configured along a spectrum from stock models to highly specialized designs. Standard dry freight van bodies, refrigerated bodies, and flatbeds are built in common lengths and widths for quick delivery, while specialized builds may include custom shelving, bulkheads, refrigeration systems, liftgates, or dimensional changes tailored to a customer’s operations. In all cases, these bodies remain truck-body-specific products, designed to integrate directly with commercial truck chassis.

[32] Once the subframe is complete, the floor assembly is installed. Floors are assembled using softwood, laminated hardwood, aluminum floor or composite materials, which are then fastened securely to the subframe. For refrigerated or specialty bodies, the floor may incorporate insulated panels or aluminum non-slip surfaces designed to maintain temperature control or enhance safety.

[33] In the case of truck bodies with walls (excluding for example flat beds), the walls of the truck body are then erected using a combination of vertical posts (uprights) and horizontally-mounted side rails, typically fabricated from steel, aluminum, or high-strength extrusions. In the case of a platform truck body, side rails may be made of wood. Between these supports, the exterior skin, commonly aluminum panels, can be attached to form the outer shell. The interior may be lined with plywood, fiberglass-reinforced panels, or other durable materials, depending on the intended cargo. In insulated or refrigerated units, foam core insulation is sandwiched between the inner and outer wall panels, using closed-cell polyurethane or similar materials to ensure thermal performance and energy efficiency.

[34] The roof structure (for those truck bodies where a roof is typical, such as dry vans and reefers) is assembled in a similar fashion, using a lightweight but strong aluminum framework, covered with a one-piece aluminum or translucent fiberglass panel. The roof is engineered to withstand snow loads, wind uplift, and low-impact collisions, while minimizing overall weight. Sealing and caulking are applied at all joints to ensure weather-tightness.

[35] The next steps in the manufacturing process where required include the installation of rear and side doors, lighting and electrical systems, mud flaps, bumpers, and protective coatings. If the truck body is a refrigerated unit, additional systems such as refrigeration compressors, ducting, and thermally-isolated bulkheads are installed and tested.

[36] The truck body (including the subframe) is then mounted onto a truck chassis using secure bolting and reinforcement techniques. Mounting brackets, U-bolts, and isolation systems (generally rubber or composite pads between the subframe and chassis used to reduce vibration and noise transfer) connect the truck body directly to the truck chassis.

[37] Throughout the process, manufacturers adhere to transport safety standards and customer specifications, with many steps subject to automated fabrication, computer numerical control cutting, and robotic welding to ensure precision and consistency. Quality assurance checks are performed at each stage to verify structural alignment, material tolerances, and adherence to regulatory codes.

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Classification of imports

[38] The subject goods are normally imported under the following tariff classification numbers:

1. 8707.90.90.10
2. 8707.90.90.39
3. 8707.90.90.40
4. 8707.90.90.90
5. 8708.29.99.90 [39] The listing of tariff classification numbers is for convenience of reference only. The tariff classification numbers include non-subject goods. Also, subject goods may fall under tariff classification numbers that are not listed. Refer to the product definition for authoritative details regarding the subject goods.

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Like goods and class of goods Footnote 18

[40] Subsection 2(1) of SIMA defines “like goods” in relation to any other goods as “…(a) goods that are identical in all respects to the other goods, or (b) in the absence of any such goods…, goods the uses and other characteristics of which closely resemble those of the other goods.” In considering the issue of like goods, the Canadian International Trade Tribunal (CITT) typically looks at a number of factors, including the physical characteristics of the goods, their market characteristics, and whether the domestic goods fulfill the same customer needs as the subject goods.

[41] The complainants state that subject goods and domestically produced goods are substitutable, and comparable in terms of non-price factors such as quality and availability of technical specification. The complainants further state that the goods both compete in the Canadian market, are ultimately sold through the same channels of distribution, and have the same market characteristics. The complainants submit that although domestically produced goods may not be identical to subject goods as certain models may be slightly different, their uses and characteristics are nearly identical.

[42] For the purposes of this analysis, like goods consist of domestically produced truck bodies described in the product definition.

[43] After considering questions of use, physical characteristics and all other relevant factors, the CBSA is of the opinion that subject goods and like goods constitute only one class of goods.

[44] In its preliminary injury inquiry for these investigations, the CITT further reviewed the matter of like goods and classes of goods. On January 13, 2026, the CITT issued its preliminary inquiry statement of reasons, indicating that:

"…the Tribunal sees nothing strongly supporting a finding of multiple classes of goods at this stage of the proceedings. The Tribunal will therefore conduct its analysis on the basis that truck bodies produced in Canada and meeting the product definition constitute like goods in relation to the subject goods and that there is one class of goods." Footnote 19

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Imports into Canada

[45] During the preliminary phase of the investigations, the CBSA refined the estimated volume and value of imports based on information from CBSA import entry documentation and other information received from exporters and importers.

[46] The following table presents the CBSA’s analysis of imports of truck bodies for the purposes of the preliminary determinations:

| Country | % of total import volume |
| --- | --- |
| China | 53% |
| Other | 47% |
| Total | 100% |

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Investigations process

[47] Regarding the dumping investigation, information was requested from all known and potential exporters, producers, vendors and importers, concerning shipments of truck bodies shipped to Canada during the POI.

[48] Regarding the subsidy investigation, information related to potentially actionable subsidies was requested from all known and potential exporters and producers in China. Information was also requested from the Government of China concerning financial contributions made to exporters or producers of truck bodies shipped to Canada during the POI. The Government of China was also requested to forward the RFIs to all subordinate levels of government that had jurisdiction over the exporters.

[49] The Government of China and the exporters/producers were also notified that failure to submit all required information and documentation, including non-confidential versions, failure to comply with all instructions contained in the RFI, failure to permit verification of any information or failure to provide documentation requested during the verification visits or the desk audits may result in the margin of dumping, the amount of subsidy and the assessment of dumping and/or countervailing duties on subject goods being based on facts available to the CBSA. Further, they were notified that non-cooperative parties will not receive an advantage for failing to provide the necessary information.

[50] After reviewing the RFI responses, supplemental RFIs were sent to respondents that filed submissions, in order to clarify information provided and request additional information, where necessary.

[51] Preliminary determinations are based on information that is available in sufficient time to allow the CBSA to make its decision. During the final phase of the investigations, the CBSA will continue to collect and verify information, the results of which will be incorporated into the CBSA’s final decisions, which must be made by June 4, 2026.

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Representations

[52] During the preliminary phase of the investigations, counsel for the complainants made representations concerning RFI responses provided CIMC Reefer, Vanguard, the Government of China, Dee Siam, Dongguan CIMC and CIMC Vehicle. Footnote 20 These representations concern topics including the accuracy and completeness of information provided, and other missing or unclear information provided in the RFI responses. The representations also addressed the section 20 inquiry, arguing that the RFI responses support their section 20 allegations. Additionally, counsel for the complainants provided comments concerning financial information from other U.S. producers of truck bodies. Footnote 21

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Dumping investigation

Normal value

[53] Normal values are generally estimated based on the domestic selling prices of like goods in the country of export, in accordance with the methodology of section 15 of SIMA, or on the aggregate of the cost of production of the goods, a reasonable amount for administrative, selling and all other costs, plus a reasonable amount for profits, in accordance with the methodology of paragraph 19(b) of SIMA.

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Export price

[54] The export price of goods sold to importers in Canada is generally estimated in accordance with the methodology of section 24 of SIMA based on the lesser of the adjusted exporter’s sale price for the goods or the adjusted importer’s purchase price. These prices are adjusted where necessary by deducting the costs, charges, expenses, duties and taxes resulting from the exportation of the goods as provided for in subparagraphs 24(a)(i) to 24(a)(iii) of SIMA.

[55] Where there are sales between associated persons and/or a compensatory arrangement exists, the export price is estimated based on the importer’s resale price of the imported goods in Canada to unrelated purchasers, less deductions for all costs incurred in preparing, shipping and exporting the goods to Canada that are additional to those incurred on the sales of like goods for use in the country of export, all costs included in the resale price that are incurred in reselling the goods (including duties and taxes) or associated with the assembly of the goods in Canada and an amount representative of the average industry profit in Canada as provided for in paragraphs 25(1)(c) and 25(1)(d) of SIMA.

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Margin of dumping

[56] The estimated margin of dumping by an exporter is equal to the amount by which the total estimated normal value exceeds the total estimated export price of the goods, expressed as a percentage of the total estimated export price. All subject goods imported into Canada during the POI are included in the estimation of the margins of dumping of the goods. Where the total estimated normal value of the goods does not exceed the total estimated export price of the goods, the margin of dumping is zero.

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Background of section 20 inquiry

[57] Section 20 is a provision of SIMA that may be applied to determine the normal value of goods in a dumping investigation where certain conditions prevail in the domestic market of the exporting country. In the case of a prescribed country under paragraph 20(1)(a) of SIMA, it is applied where, in the opinion of the CBSA, the government of that country substantially determines domestic prices and there is sufficient reason to believe that the domestic prices are not substantially the same as they would be in a competitive market. Footnote 22

[58] The provisions of section 20 are applied on a sector basis rather than on the country as a whole. The sector reviewed will normally only include the industry producing and exporting the goods under investigation.

[59] The complainants alleged that the conditions described in section 20 of SIMA prevail in the truck bodies sector in China. That is, the complainants allege that this sector in China does not operate under competitive market conditions and consequently, the domestic prices of truck bodies established in China would not be reliable for determining normal values. Footnote 23

[60] The complainants provided a variety of evidence to support the claim that the Government of China substantially determines domestic prices of truck bodies and that the prices are substantially different than they would be in a competitive market. Specifically, the complainants cited specific policies implemented by the Government of China, and provided evidence of state ownership and subsidization in the Automobile Bodies and Trailers Manufacturing sector within the transportation vehicle industry in China, including truck bodies.

[61] At the initiation of the investigation, the CBSA had reviewed the information provided in the complaint and conducted its own research. Based on this information, the CBSA believed that there was reasonable evidence to support an inquiry into the allegations that the measures taken by the Government of China substantially influence prices in the Automobile Bodies and Trailers Manufacturing sector in China.

[62] Consequently, on October 24, 2025, the CBSA included in its investigations, a section 20 inquiry in order to determine whether the conditions set forth in paragraph 20(1)(a) of SIMA prevail in the Automobile Bodies and Trailers Manufacturing sector in China, which includes truck bodies.

[63] As part of this section 20 inquiry, the CBSA sent section 20 RFIs to all potential producers and exporters of truck bodies in China, as well as to the Government of China, requesting detailed information related to the truck bodies sector in China.

[64] Based on the CBSA research and for the purposes of this investigation, the Automobile Bodies and Trailers Manufacturing sector covers the manufacturing of Truck bodies (including enclosed cargo bodies, refrigerated bodies, flatbeds, dump truck bodies, container bodies, detachable bodies etc.), Bus bodies, Vehicle cabs, Trailers and semi-trailers (for freight, special use, etc.), Chassis and body manufacturing (but not full vehicle assembly), and related vehicle body parts.

[65] In the event that the CBSA forms the opinion that domestic prices of truck bodies in China are substantially determined by the government, and there is sufficient reason to believe that the domestic prices are not substantially the same as they would be if they were determined in a competitive market, the normal values of the goods under investigation will be determined, pursuant to paragraph 20(1)(c) of SIMA, where such information is available, on the basis of the domestic selling prices or the aggregate of the cost of production, a reasonable amount for administrative, selling and all other costs, and a reasonable amount for profits of like goods sold by producers in any country designated by the CBSA and adjusted for price comparability; or, pursuant to paragraph 20(1)(d) of SIMA, where such information is available, on the basis of the selling price in Canada of like goods produced and imported from any country designated by the CBSA and adjusted for price comparability.

[66] For the purposes of obtaining information necessary to calculate normal values pursuant to subparagraph 20(1)(c) of SIMA, the CBSA requested information from producers in surrogate countries. As such, the CBSA has selected the United States (US) and Mexico as potential surrogate countries, as both countries have significant domestic production of truck bodies that compete globally and operate under fair market conditions in their domestic markets. The CBSA has sent questionnaires to known producers of truck bodies in these countries.

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Analysis of section 20 conditions

[67] The CBSA has previously formed the opinion that section 20 conditions existed in the dumping investigation of Container Chassis in 2021, Footnote 24 conducted with respect to the Semi-trailer industry sector, which includes container chassis.

[68] The complainants argued that the CBSA’s persuasive evidence in Container Chassis is equally applicable for truck bodies and should lead the CBSA to the same conclusion that the Government of China substantially determines the prices of truck bodies in the Chinese market.

[69] The CBSA is of the view that container chassis, trailers and truck bodies industries share some similarities in their role as critical enablers of freight transport, and integration into the global logistics and supply chain ecosystem. Container chassis and trailers are indispensable in intermodal transport, linking ships, railcars, and trucks, while truck bodies are equally vital in last-mile and regional distribution. Both serve as essential interfaces between cargo and transport vehicles, enabling efficient movement of goods across road, rail, and sea. Both industries are foundational to modern logistics, acting as the physical backbone of cargo movement.

[70] Although container chassis and truck bodies share certain functional similarities and use some of the same basic materials—primarily steel and aluminum—the cost structures of the two product categories differ substantially. For container chassis, steel represents the overwhelming majority of raw material inputs, accounting for approximately 75% of the material inputs for container chassis.

[71] In contrast, truck bodies rely on a much wider assortment of inputs, with no single component typically representing a significant share of the overall material costs.

Government control analysis

[72] This section presents the CBSA’s analysis of the extent to which, if any, the Government of China applies influence over the Automobile Bodies and Trailers Manufacturing sector within which the truck bodies segment operates, by examining the following:

• Industrial plans, directives, regulations and other policy mandates
• Government ownership and control of major producers of truck bodies
• Government subsidization of the truck body industry and intervention in key raw material inputs

National & Provincial 14th Five-Year Plans

[73] The Government of China’s Five-Year Plans are an important economic policy tool within the Chinese socialist market economy. Within each plan, the Government of China maps out its strategies for economic development, setting growth targets and launching economic reforms with respect to key industries.

[74] The complainants stated that the Government of China is proceeding to its next steps in further expanding its influence in the trucking industry by accelerating the construction of a ‘transportation powerhouse’ Footnote 25 and by enhancing the competitive advantage and high quality development of the manufacturing industry. Footnote 26

[75] Additionally, the complainants added that the current 14th FYP emphasizes the development of the logistics industry in several chapters. The Government of China’s stated goals are to build modern logistics, procurement and distribution, production control, operation management, and after-sales service. The following points are included in the 14th Five-year Plan for National Economic and Social Development:

“build modern logistics systems, accelerate the development of cold chain logistics, coordinate the construction of logistics hub facilities, backbone lines, regional distribution centers, and endpoint delivery nodes, improve the facilities and conditions of national logistics hubs and backbone cold chain logistics bases, improve the three-level county, township, and village logistics distribution system”. Footnote 27 [76] The directives in the 14th Five-Year Plan and subsequent action plans from ministries continued to prioritize lowering logistics costs and increasing efficiency. In November 2024, the Ministry of Transport and the National Development and Reform Commission co-issued a new action plan for Reducing Costs, Improving Quality and Increasing Efficiency in Transportation and Logistics. Specifically, the plan states:

“Smooth the terminal circulation network of urban and rural logistics. Optimize and improve the urban freight service network, study and promote medium-sized vans dedicated to urban distribution…, Improve the cold chain logistics facilities at the production site and vigorously develop cold chain logistics for agricultural products.” Footnote 28

14th Five-Year Plan Cold Chain Logistics Development

[77] The 14th FYP logistics policies stress the need to build a modern integrated transportation system for seamless integration between different categories of domestic logistics networks. The following are some of the development goals mentioned:

“accelerate the establishment of a modern cold chain logistics system that is smooth and efficient, safe and green, smart and convenient, and strongly guaranteed; improve the quality and efficiency of cold chain logistics services.” Footnote 29 [78] The 14th FYP cold-chain logistics plan highlights the steady growth of the logistics market and its development toward a more concentrated industry:

“Market entities have continued to grow….Market concentration has increased steadily, and a number of leading enterprises have formed in cold chain warehousing, transportation, distribution, and equipment manufacturing” Footnote 30 [79] The 14th FYP cold-chain logistics plan aims to develop a complete infrastructure and a qualitative cold chain logistics, including refrigerated trucks:

“The level of cold chain logistics technology and equipment shall be significantly improved; the total amount of cold storage and refrigerated trucks shall maintain reasonable and stable growth; regional distribution shall be more optimized and functional types more complete.” [80] The 14th FYP for cold-chain logistics aims, amongst other policies, to:

“Promote the upgrading of cold chain transportation facilities and equipment: …improve the development level of refrigerated trucks… Strictly control the market access conditions for refrigerated trucks… Accelerate the development and manufacturing of light and micro new energy refrigerated trucks… {and} actively promote new refrigerated trucks”. Footnote 31

“Accelerate the process of green development:…Research and formulate energy efficiency standards for cold storage, refrigerated trucks, etc.,… Improve the thermal insulation and flame retardant properties of thermal insulation materials for cold storage, refrigerated trucks, etc.,…encourage the use of green, safe, energy saving, and environmentally friendly refrigerated trucks and supporting equipment and facilities,… Accelerate the elimination of high-emission refrigerated trucks to meet the needs of urban green distribution development, and encourage new or updated refrigerated trucks to adopt new energy models”. Footnote 32

[81] The complainants submitted that the FYP cold-chain logistics plan has spurred a range of related Government of China measures:

• The National Development and Reform Commission issued the Implementation Plan for the Construction of the National Backbone Cold Chain Logistics Bases, which specified systematic arrangements for the layout and construction of the national backbone cold chain logistics bases during the “ 14th Five-Year Plan ” period. Footnote 33
• In February 2022, the All-China Federation of Supply and Marketing Cooperatives issued the 14th Five-Year Plan Development Plan for the Cold Chain Logistics of Public Agricultural Products, which specified the layout of cold chain logistics in the field of agricultural products. Footnote 34
• Also in April 2022, the Ministry of Transport and other five departments jointly issued the Implementation Opinions on Accelerating the High-quality Development of Cold Chain Logistics Transportation, which proposed to cultivate key cold chain transportation enterprises and established a number of well-known cold chain transportation service brands. Footnote 35

14th Five-Year Plan Clean Energy Infrastructure

[82] The complainants submitted also that the Government of China has fostered the development of the domestic new energy vehicle (NEV) industry as one of China’s strategic emerging industries. Footnote 36 The complainants added that the Government of China has actively introduced various policies and standards to promote the development of the Chinese NEV industry, including subsidies, sales tax exemptions, and continues to increase infrastructure construction, invest in the construction of NEV charging infrastructure, promote the construction and operation of charging facilities. Footnote 37

[83] The complainants argued that the impact on the truck body sector has been direct due to demand for Class 4-7 NEV vehicles equipped with truck bodies: policies such as the 14th FYP clean energy infrastructure have pushed sales of new energy refrigerated trucks to 21,368 units in 2024, a year-on-year increase of 350.8%. Footnote 38

[84] The directives in the 14th Five-Year Plan and subsequent action plans from ministries continued also to promote new energy vehicles and clean transportation. The new action plan for Reducing Costs, Improving Quality and Increasing Efficiency in Transportation and Logistics, co-issued in November 2024 by the Ministry of Transport and the National Development and Reform Commission, promotes freight decarbonization by prioritizing two main areas: building zero-emission truck fleets and tracking carbon outputs. Key initiatives under the plan include expanding networks for vehicle charging and for swapping batteries to support adoption of electric trucks. Footnote 39

Other incentive measures and financial support

[85] Beyond the National & Provincial 14th FYP policies, the Government of China expanded incentives for scrapping and replacing transportation equipment in 2025.

[86] In January 2025, the National Development and Reform Commission and the Ministry of Finance of China jointly released a Notice on Enhancing and Expanding the Implementation of the Large-scale Equipment Renewal and Trade-in of Consumer Goods Policies in 2025. This 2025 Program is the second phase of the Large-scale Equipment Renewal and Consumer Goods Trade-in Program initiated in 2024.

[87] This program provides national-level incentives to promote the scrappage and replacement of old passenger cars, trucks, buses, ships, off-road agricultural machineries, and other consumer goods. The 2025 Program extends incentives to the scrapping of old commercial diesel trucks with emission standards at or below China IV, an expansion from China III and below. Footnote 40

[88] Truck owners continue to receive subsidies for their early scrapping of old trucks before the mandatory retirement age and can receive additional subsidies for replacing them with new China VI trucks or new energy trucks, with the total subsidy amounts ranging from ¥10,000 to ¥140,000. Footnote 41

Belt and Road Initiative and Made-in-China 2025 Initiative

[89] The Belt and Road Initiative (BRI), introduced in 2013, is a strategic program aimed at enhancing global connectivity through infrastructure projects across Asia, Europe, Africa, and adjacent seas. The One Belt One Road Action Plan of 2015 outlines its goals, including integrating China further into the global economic system and leveraging regional comparative advantages to strengthen national and global economic ties. Footnote 42 Unlike the FYPs, the BRI distinguishes itself through its international scale and infrastructure focus, though it remains embedded in China's overall planning framework. The 14th FYP itself dedicates a whole chapter called Promote high-quality ‘Belt and Road’ development to the BRI. Footnote 43

[90] The complainants submitted that, in CBSA’s section 20 analysis in Container Chassis, and in respect of the Belt and Road and Made-in-China 2025 initiatives, CBSA stated that:

“{a}s a manufacturer of containers, semi-trailer and other transportation products that are essential to China’s global trade network, CIMC plays a pivotal role in this policy agenda of the GOC.” Footnote 44

Further, CBSA stated that: CIMC has directly benefited from the demand for containers and semi-trailers created by Chinese-led logistics networks BRI. This increase in demand is not limited to only containers, it would also directly benefit CIMC’s sales of ancillary products such as subject container chassis and other semi-trailers as overland trade by road transport brings significant new demand for those products. {emphasis added} Footnote 45

[91] Additionally, the 14th FYP cold-chain logistics plan signals the pivotal role of the BRI in creating new opportunities for cold chain logistics development:

“Implementing high-level opening up creates new opportunities for cold chain logistics development: Adhering to broader, wider, and deeper opening up—especially by thoroughly advancing Belt and Road cooperation and promoting the establishment of a high-standard free trade zone network oriented toward the globe—shall further optimize the regional supply chain environment, effectively leverage China’s super-large-scale market advantages, deepen trade exchanges with relevant countries, expand food import and export scale, promote alignment of domestic and international cold chain logistics standards, learn and disseminate advanced cold chain logistics technologies and management experience, and promote high-quality development of cold chain logistics.” Footnote 46

Vehicle Industry Investment Regulations

[92] The complainants submitted that the 2019 Administrative Regulation on Investment in the Automotive Industry directed investment in the automotive industry into green, fuel-efficient transportation technology, established broad government control of production capacity, research and development activities, and access by new market entrants. The regulation imposed a range of restrictions, aiming to control “new capacity of traditional fuel vehicles, actively promote the healthy and development of new energy vehicles, and strive to build an innovative development system for smart vehicles”. Footnote 47

[93] The Automotive Industry Regulation confirms that investments in special-purpose vehicles and trailer investment projects are subject to restrictions:

“Article 28: Relevant requirements for special-purpose vehicles and trailer investment projects: (1) For new investment projects of special-purpose vehicles and trailer enterprises, the corporate legal person shall establish a product research and development organization, have a professional research and development team, have relevant research and development experience, and have technical research and development of special devices (2) It is forbidden to build new warehouse trucks, pallet trucks, dump trucks and ordinary vans and other general transport vehicles and general transport trailer enterprises investment projects; (3) Special vehicle companies are not allowed to build various types of vehicles Automobile chassis and complete vehicle production capacity, except for the self-made chassis of special operation vehicles”. Footnote 48 [94] The complainants argued that the impact of these regulations and policies is consistent with section 20 factors, as they demonstrate the Government of China’s strict regulation of production, investment, and research and development expenditures in truck bodies, which has a direct effect on pricing.

[95] In its response to the section 20 RFI about the Vehicle Industry Investment Regulations, CIMC Reefer explains that these regulations are generally available and equally apply to all vehicle industries and recognizes that there are certain requirements for investment projects for special-purpose vehicles. Footnote 49

[96] The Regulations provide a clear restriction that bans new investments in the sector:

“Article 28.2.: It is forbidden to invest in new ordinary special-purpose vehicles for transportation and general transportation trailer enterprises such as stake trucks, flat bed, dumper and ordinary vans”. Footnote 50 [97] The complainants also submitted that Transportation and the modern logistics industry are identified in the 2024 Government of China Catalogue as categories of manufacturing that are important to the real economy and which promotes new industrialization. Footnote 51

[98] More specifically, the Government of China has outlined targets to establish a high-end, intelligent, and green manufacturing industry while consolidating the leading position of advantageous industries, such as increasing the proportion of production capacity and expanding high-quality supply and scaling-up security capabilities, notably related to food and energy. The 2024 Catalogue identifies plans to upgrade and renovate highway and road transportation systems to develop a highway intelligent transportation system, freight transportation which feature green infrastructure construction strategies Footnote 52 and the construction of the cold chain logistics of agricultural products, food and medicines. Footnote 53

[99] The complainants argued that the production of truck bodies, particularly refrigerated truck bodies, is integral to the Government of China’s plans for the development of China’s national cold chain logistics base. In pursuit of these objectives, the 2024 Catalogue contemplates necessary industrial structural adjustments to applicable fiscal, taxation, credit, land, import and export, and market supervision policies. Footnote 54

[100] Based on the CBSA’s review of the above evidence presented in the complaint and its own analysis, the CBSA finds that there is a reasonable indication that the presence of government plans, directives and regulations in the Automobile bodies and trailers sectors, which includes truck bodies, suggests that the production and sale of truck bodies may be influenced by non-market factors.

Government ownership and control of major producers

[101] The complainants submitted that the CBSA should find that the Government of China exercises substantial ownership and control over key producers of truck bodies, namely China International Marine Containers (Group) Co., Ltd. (CIMC Group) and Sinotruk Group.

[102] The complainants added that CIMC Group and its subsidiaries are controlled by the Government of China through a complex corporate structure. The complainants argued that CBSA found CIMC Group was a state-owned enterprise (SOE) in CBSA’s section 20 analysis in Container Chassis, which had previously been publicly indicated by the State-owned Assets Supervision and Administration Commission of the State Council (SASAC), with the Government of China ultimately controlling CIMC Group through SASAC Footnote 55.

[103] The State-Owned Assets Supervision and Administration Commission (SASAC), a body under the State Council, oversees the management, performance, and restructuring of central SOEs, acting both as the government’s representative and as an investor. Its role includes appointing and evaluating enterprise leaders, guiding SOE reforms and mergers, and exercising control through investor rights rather than administrative authority.

[104] The complainants submitted that CIMC’s two largest shareholders are Shenzen Capital Holdings Co. Ltd. (Shenzen Capital) (24.64%) and China Merchants (CIMC) Investment Limited (China Merchants) (24.49%). Shenzen Capital and China Merchants are both ultimately owned by SASAC. Footnote 56

[105] As the Government of China did not respond to the section 20 RFI, there is limited public information available about Chinese Automobile Bodies and Trailers Manufacturers or truck bodies producers other than the cooperative exporter/producer CIMC Reefer, a subsidiary of the CIMC group. At this current stage, the CBSA’s analysis focused on the Government of China’s control of CIMC Reefer. The CBSA will continue collecting information from CIMC Reefer about the Government of China’s ownership and the degree of control in relation to the whole industry during the final stage of the investigation.

[106] In its response to section 20 RFI, CIMC Reefer, which is owned by CV Group, states that it is not state-owned nor has state owned interests.

[107] CIMC Reefer is a Chinese manufacturer and exporter of reefer trailers and truck bodies, owned by CV Group, with 62.24% direct ownership and 37.75% indirect ownership through CV Group’s subsidiary, CIMC Vehicle Investment Holdings Co., Ltd. (CV BVI). CV BVI, a holding company, is wholly owned and controlled by CV Group.

[108] CV Group is a publicly listed company on the Shenzhen Stock Exchange, which is in turn controlled by CIMC Group, with 61.34% interest in CV Group (combined direct and indirect interests). CIMC Group is publicly listed on both the Shenzhen Stock Exchange and the Hong Kong Stock Exchange. None of the other CV Group’s shareholders owns more than 5% shareholding interests. Footnote 57

[109] CIMC Group was founded in 1980 as a joint venture, under the leadership of Shenzhen State-owned Assets Supervision and Administration Commission, invested by China Merchants Group and East Asiatic Company in Shenzhen. It came to be listed in Shenzhen Stock Exchange in 1994 and listed in Hong Kong Stock Exchange in December 2012. Currently, CIMC Group is a public A+H share listed company, whose main shareholders are Shenzhen Capital Holdings and China Merchants Group. Footnote 58

[110] The shareholding structure between CIMC Group and its substantial shareholders, as presented below, was illustrated in CIMC Group’s December 31, 2024, Chart of shareholding structure in its annual report Footnote 59:

Text version

• 24.64%: State-owned assets supervision and administration commission of Shenzhen Municipal People's Government
  • Shenzhen Capital Holdings Co., Ltd.
  • 20.00%:
  • Shenzhen Capital International Company Limited
  • Shenzhen Capital (Hong Kong) Container Investment Co., Ltd.
• 24.49%: State-owned assets supervision and administration commission of the state council
  • China Merchants Group Limited
  • China Merchants Steam Navigation Company Limited
  • China Merchants Holdings (Hong Kong) Company Limited
  • China Merchants Industry Holdings Company Limited
  • SOARES LIMITED
  • China Merchants (CIMC) Investmant Limited
• 38.06%: Other A shareholders
• 12.81%: Other H shareholders

[111] Shenzhen Capital Group (SCGC) is a state-owned venture capital and investment group established by the Shenzhen municipal government in 1999, focused on Venture Capital/Private Equity and strategic industry investment. SCGC operates as a policy-aligned investor that backs technology, hard tech, healthcare, new energy, and advanced manufacturing companies while also running broader asset-management activities. Footnote 60

[112] China Merchants Group is a large, diversified Chinese state-owned conglomerate with long-standing operations in shipping, ports, logistics, finance, and related infrastructure; it plays an active role in maritime and trade-related sectors and hosts a number of listed subsidiaries and affiliates. Footnote 61

[113] Both entities, China Merchants Group and Shenzhen Capital Group, are ultimately government controlled or government affiliated rather than purely private: China Merchants is a central SOE supervised by the Chinese government, and Shenzhen Capital Group was established by and remains affiliated with the Shenzhen municipal government, so their ownership and strategic direction are tied to public authorities.

[114] In addition to ownership, the complainants submitted that the evidence suggests that CIMC Group’s governance and management are also controlled by the Government of China. The complainants argued that the ruling Communist Party of China (CPC) forms an integral part of SOEs, and that the CPC places CPC committees at the executive level of SOEs, including SOEs like CIMC Group’s substantial shareholders Shenzhen and China Merchants. This role of the CPC committees with respect to SOEs allows the CPC to exercise control and influence over these entities. Footnote 62

[115] In CIMC Group’s case, Zhu Zhiqiang is currently the Vice-chairman and non-executive Director. Zhu Zhiqiang is also the Deputy Secretary of the Party Committee and the general manager and a director of Shenzhen Capital. He has previously held the roles of deputy chief of the enterprises division I, deputy chief and chief of the strategic development of SASAC. Sun Huirong remains a member of the Party while also serving as a Non-Executive Director for CIMC Group and as the Director of the Asset Management Department of Shenzhen Capital. He has previously held the positions of Senior Manager, Deputy Director of the Strategic Research & Mergers and Acquisitions Department, the Deputy Director of the Asset Management Department and the Director of the Audit Department of Shenzhen Capital.

[116] It is the CBSA’s opinion where a government entity holds a majority equity ownership, or alternatively a substantial equity ownership such as a dominant minority block, whether directly or indirectly, this interest in and of itself may indicate that the government exercises or has the potential to exercise control over the company’s operations generally. This may include control over, for example, the selection of board members, management and the profit distribution. Therefore, it is the CBSA’s opinion that information on the record reasonably supports the argument that CIMC Reefer, a joint venture company that is ultimately owned by CV Group, which is in turn controlled by another publicly listed company CIMC Group, is an SOE that may be controlled by the Government of China through multiple intermediates and ultimately by SASAC.

[117] In its response to the section 20 RFI, CIMC Reefer identified the head of the CCP representatives of CIMC Reefer. CIMC Reefer indicated that no CCP representative within the company has any influence on CIMC Reefer’s operations because of their role as CCP representatives. Footnote 63

[118] CIMC Reefer stated that no members of the board of directors or supervisory body are representatives or employees or appointees of the Government, nor were they appointed or recommended by the Government of China. Footnote 64

[119] CIMC Reefer also indicated that none of the members of the board of CV Group, which ultimately owns CIMC Reefer, are representatives, employees or appointees of the Government of China. Footnote 65

[120] Based on the CBSA’s review of the above evidence presented in the complaint and its own analysis, the CBSA finds that there is a reasonable indication that: the presence of a state-owned and state-controlled enterprise in the Automobile bodies and trailers sector, which happen to be a major market player and also producer of truck bodies, suggests that Government of China may exercise substantial ownership and control over key producers of Automobile bodies and trailers, including truck bodies, namely CIMC Group and its subsidiary CIMC Reefer.

Government subsidization of the truck body industry and intervention in key raw material inputs

[121] The complainants made allegations that the Government of China has subsidized truck bodies production, as well as relevant input materials, most notably steel and aluminum inputs. The complainants added that the Government of China continues to substantially determine domestic prices of subject truck bodies through direct and indirect regulatory actions and subsidies.

[122] The complainants submitted that even prior to 2021 and the adoption of this sector specific five-year plan for cold-chain logistics, the Government of China was “paying unprecedented attention to the development of the cold chain”, Footnote 66 with one report noting the existence of financial subsidies for the development of the cold chain logistics industry from the Department of Commerce and the Department of Finance of Guangdong. Footnote 67

[123] Since 2007, the CBSA has conducted 15 investigations within the steel sector in China along with five administrative reviews involving non-market economy inquiries on Chinese steel products. In all instances, information available to the CBSA indicated that there was reason to believe that section 20 conditions existed in the listed sectors of the steel industry in China and accordingly, the CBSA was of the opinion that the conditions of section 20 were present in these product segments of the Chinese domestic steel sector.

[124] Similarly, previous findings of distortions in the aluminum sector by other investigative authorities show that Chinese aluminum producers benefit from substantial financial and non-financial support, primarily from SOEs and banks. Major beneficiaries of financial support include SOEs and large private firms such as China Hongqiao Group and China Zhongwang. Preferential financing measures include cheap loans, free credit lines, bonds at low rates, export credit insurance, and government grants for industrial development. Tax exemptions and reductions cover areas such as corporate tax discounts, R&D offsets, VAT exemptions, and import tariff rebates. The government provides land and electricity at below-market rates, further supporting aluminum producers.

[125] In response to the subsidy allegation by the complaints, the CBSA initiated the subsidy investigation of truck bodies. At the preliminary stage of the investigation, the CBSA has received information from the Government of China regarding subsidies provided to producers of truck bodies. For the purposes of the preliminary determination, the response is being treated as partially complete.

[126] Based on information received, for purposes of the preliminary determination, the CBSA has identified 31 subsidy programs that may have benefited Chinese exporter/producers of truck bodies. Six of these were found to have benefited CIMC Reefer.

[127] For the purposes of the preliminary determination, the CBSA estimated an amount of subsidy at 0.95% of export price for CIMC Reefer.

[128] Given that CIMC Reefer has been receiving some amount of subsidy from the Government of China through multiple programs, it is reasonable to believe that similar subsidy programs could be available to other truck bodies producers.

[129] The CBSA estimated the amount of subsidy for CIMC Reefer to be below 1% of the export price during the POI, and therefore determined it to be insignificant. The CBSA will continue its subsidy investigation and will update the amount of subsidy during the final phase of the investigation.

Special refinancing for transportation and logistics

[130] In February 2023, the People’s Bank of China, the Ministry of Transport and the China Banking and Insurance Regulatory Commission jointly issued the Notice on Further Improving Financial Support and Services in the Field of Transportation and Logistics driving the high-quality development of the transportation and logistics industry and the construction of a transportation power. The report to the 20th CPC National Congress stresses the needs to accelerate the building of China into a country with strong transportation networks, build an efficient and smooth circulation system, and reduce logistics costs. Footnote 68

[131] The Notice requires that banking and financial institutions should improve guarantee and internal incentive mechanisms, innovate and enrich credit products that meet the needs of the transportation and logistics industry, and earnestly increase credit support.

The following points are included in the notice:

“The models of proactive credit granting and pay-as-you-go lending shall be actively promoted to better meet the needs of market participants for using funds for business purposes… Banking financial institutions shall be encouraged to, on the premise of compliance with laws and regulations and controllable risks, reasonably determine the down payment ratios, loan interest rates and repayment periods of truck loans, and appropriately enhance the tolerance of truck loans and other non-performing loans in the transportation and logistics industries during the specific periods of the COVID-19 pandemic and economic recovery, and specify and implement the institutional arrangements for exemption from liabilities for due diligence.” This aims to strengthen the financing support for policy-oriented development financial instruments to invest in transportation and logistics projects, and encourages financial institutions to provide support for improving the layout of comprehensive transportation network, executing major projects in the “14th Five-Year Plan”. The Notice points out that qualified provinces and cities should actively increase supporting policies such as interest subsidy, guarantee and credit enhancement. Footnote 69

Subsidized steel and aluminum distort the cost of production for Chinese truck bodies

[132] The complainants submitted that Government of China’s subsidization of the steel and aluminum sectors in China are reflected in the price of finished truck bodies sold into the Chinese market.

[133] The complainants argued that, depending on the model, steel and aluminum together make up a substantial share of the raw material inputs used in truck bodies. Footnote 70 Therefore, the complainants argued that the heavily subsidized steel and aluminum supplied by Chinese steel and aluminum producers to the truck body industry creates a cost base that does not reflect competitive market conditions. Footnote 71 The complainants added that the CBSA has consistently found that section 20 conditions exist in relation to both commodity steel and aluminum products themselves and manufactured derivative products, as per the recent Wire Rod investigation. Footnote 72

Government maintains a significant degree of ownership in the steel and aluminum sectors

[134] The complainants submitted that many of the largest Chinese producers of steel and steel products are State-Owned Enterprises (SOEs). For instance, China Baowu Steel Group, by far the world’s largest steel-producing company in 2025, is wholly owned by China’s SASAC. Similarly, Ansteel Group, the world’s third largest producer of steel, and Hesteel Group, the world’s fifth largest producer of steel, and Shougang Group, the world’s ninth largest producer of steel, are wholly state-owned. Footnote 73

[135] In the aluminum sector, the complainants submitted that SOEs are estimated to account for approximately 50% of total primary aluminum output in China. The complaints pointed out that of the three Chinese companies that appear among the world’s ten largest producers of aluminum, two – China Power Investment Corporation and Chalco – are wholly state owned.

Government policy measures distort domestic prices for steel and aluminum

[136] The complainants submitted that a variety of national, provincial and municipal level policies distort prices for steel and aluminum, and derivative products made from those metals. The complainants argued that both steel and aluminum sectors are expressly targeted by the Government of China’s 14th FYP on Developing Raw Material Industry (Raw Materials FYP). The Raw Materials FYP notes that the Government of China shall “promote the development of industries such as steel” and “explore the establishment of peak production mechanism for industries such as steel”. In its most recent annual report, the Government of China noted that it would “continue to regulate crude steel output and promote restructuring of the steel industry through output reduction”. Footnote 74

[137] The complainants added that, in Aluminum Extrusions, the CBSA found that “while the Government of China does not directly set or control the prices” of the downstream product at issue in that case, it was “clear that the Government of China exerts a substantial degree of influence over the aluminum industry in China through its industrial policy measures”. Footnote 75 On that basis of a range of policy measures, regulations controlling productions levels, preferential financing and subsidies, and the control of import and export levels, the CBSA concluded that there was sufficient evidence to conclude that domestic prices of aluminum extrusions were substantially determined by the Government of China. Footnote 76

[138] During its most recent trade policy review of China, the WTO found that the Government of China was engaged in government support for aluminum, which is “likely to have global repercussions.” Footnote 77

[139] The complainants submitted also that the linkage between the raw material-related policy and the automotive and trucking industry is likewise recognized by the Government of China, which has expressly recognized the importance of scaling-up its “development of non-metallic composite materials, high-strength lightweight alloys, high-strength steel and other lightweight materials for the body, parts, and vehicles, and full-function and high-performance vehicle control systems”. Footnote 78

[140] Consequently, the complainants argued that the CBSA’s prior assessment of both steel and aluminum sectors indicate that these sectors are distorted by the Government of China and as a result, prices in China’s domestic market for those commodities are not the same as they would be in a market economy. The complainants submitted that the CBSA should conclude that prices for these two key inputs in the production of truck bodies are unfairly distorted in the Chinese economy.

[141] Based on the CBSA’s review of the above evidence presented in the complaint, the CBSA finds that there is a reasonable indication that the degree of subsidization in the steel and aluminum sectors, the significant presence of state-owned and state-controlled enterprises in those sectors, as well as government policies applicable to those sectors, may result in the provision of steel and aluminum inputs to truck bodies producers at distorted low prices. This may in turn allow Chinese truck bodies producers to sell their products at prices determined by factors other than the market conditions, resulting in prices that may be lower than they would be without government involvement.

Summary of government control analysis

[142] The CBSA analyzed the Government of China’s major macro-economic policies, plans and regulations pertaining to the Automobile Bodies and Trailers Manufacturing sector, which are the 14th Five-Year Plan on National Economic and Social Development, the 14th Five-Year Plan Cold Chain Logistics Development, the 14th Five-Year Plan Clean Energy Infrastructure, the Belt and Road initiative, the Vehicle Industry Investment Regulations, and other incentives policies and financial support.

[143] The Government of China’s policies, plans, and initiatives detailed above indicate the fact that the Government of China is promoting and developing the transportation sector, the Automobile Bodies and Trailers Manufacturing sector industry and the Cold Chain logistics sector with support from related steel and aluminum industries in China.

[144] The Government of China’s role in regulating vehicle investment in the Automobile Bodies and Trailers sector is evidenced by the implementation of controls on production capacity, research and development activities, and access by new market entrants.

[145] The Government of China’s above-mentioned measures may significantly affect the demand and supply balance in the domestic market and therefore could materially alter the domestic prices of Automobile Bodies and Trailers.

[146] In addition to the industrial policies and plans, Chinese state-ownership of the Automobile Bodies and Trailers producers and upstream enterprises involved in the supply of steel and aluminum inputs could also have a significant impact on the domestic prices of truck bodies. Furthermore, the Chinese government’s subsidization of the Automobile Bodies and Trailers Manufacturing sector and indirect subsidization on truck bodies subassemblies through upstream steel and aluminum industries and its Vehicle Industry Investment Regulations may also indicate that the Government of China exerts influence on the pricing in the Automobile Bodies and Trailers Manufacturing sector, which includes truck bodies.

[147] The CBSA has previously issued opinions in respect of the aluminum extrusions sector and eight steel product segments, including sectors of flat-rolled steel, long steel products and fabricated structural steel sector, which are substantially influenced by the Government of China under section 20 conditions. Companies in those sectors may provide the Automobile Bodies and Trailers Manufacturing sector with low priced steel plates, aluminum profiles, aluminum sheets/coils and metal components, which are the key input materials in producing Automobile Bodies and Trailers, including truck bodies.

[148] The Government of China did not provide a response to the CBSA’s Section 20 RFI. The CBSA will use existing evidence on the record, including the Section 20 allegations and evidence submitted by the complainant, in its ongoing Section 20 inquiry.

[149] In conclusion, there is evidence on the record suggesting that Government of China policies, measures and programs may significantly affect prices of Automobile Bodies and Trailers in China.

Price analysis

[150] The CBSA was unable to find representative pricing data for truck bodies sold in China from any publicly available sources.

[151] In its price analysis, the CBSA relied on the responses from one producer that provided a domestic sales database, CIMC Reefer. Footnote 79 The CBSA analyzed price information contained in the domestic sales database of CIMC Reefer’s submission to further assess whether the domestic price of truck bodies sold by CIMC Reefer is distorted compared to other competitive markets.

[152] The CBSA also relied on the response from one surrogate producer in the U.S., namely Morgan Truck Body, LLC Footnote 80 in its pricing analysis.

[153] The CBSA compared CIMC Reefer’s Chinese domestic truck bodies weighted average net selling prices with those of the U.S. surrogate producer. The CBSA also compared the Chinese domestic truck bodies weighted average net selling prices with those of similar models that closely resemble each other of the surrogate U.S. producer, sold by trade level type (Distributor and End-user).

[154] Both results showed that prices of truck bodies sold domestically in China during the POI were significantly lower than prices in the United States. This suggests that pricing in the Automobile Bodies and Trailers Manufacturing sector is not substantially the same as it would be if it were determined in a competitive market.

[155] During the final phase of the investigations, the CBSA will continue its analysis into whether truck bodies prices in China are substantially different than those in competitive markets.

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Preliminary results of the section 20 inquiry

[156] For the purposes of the preliminary determination of dumping, the CBSA has formed the opinion that domestic prices in the Automobile Bodies and Trailers Manufacturing sector in China are substantially determined by the Government of China and that domestic prices are not substantially the same as they would be in a competitive market.

[157] During the final phase of the dumping investigation, the CBSA will continue the Section 20 inquiry and collect and analyze relevant information.

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Preliminary results of the dumping investigation

Cooperative exporters

[158] As part of the Section 20 inquiry, the CBSA identified the United States, and Mexico as reasonable surrogate countries for China, as they produce comparable goods, have globally competitive producers, and operate under market conditions. Surrogate RFIs were sent to 28 potential producers and exporters of truck bodies in the United States and Mexico. The CBSA received one response to the surrogate producer RFI from Morgan Truck Body, a producer of truck bodies in the United States. Footnote 81

[159] As part of the Section 20 inquiry, the RFIs sent to importers requested information on re-sales in Canada of truck bodies imported from sources other than China. The CBSA received one response to the Importer RFI; however, the importer did not provide information concerning the purchase and/or resale of like goods from non-named countries.

[160] As only one surrogate producer provided a response to the surrogate RFI, the CBSA requested additional information concerning the cost of production of truck bodies from the four Canadian producers that responded to the industry profit survey. Two of these producers provided complete responses, Morgan Canada Footnote 82 and Morgan Transit. Footnote 83

[161] For CIMC Reefer, the only exporter that submitted a substantially complete response to the dumping RFI, normal values were estimated following a methodology similar to that of subparagraph 20(1)(c)(ii) of SIMA, based on cost of production information provided by surrogate producers in the United States and Canada, as well as publicly available information from other producers of truck bodies in the United States.

[162] During the POI, all of the subject goods exported to Canada by CIMC Reefer were sold to a related importer, Vanguard. Due to the relationship between the parties involved in the export sales, a reliability test was performed by comparing the export prices estimated in accordance with section 24 of SIMA, to the export prices estimated in accordance with paragraph 25(1)(c) of SIMA. The test revealed that export prices estimated under section 24 were found to be unreliable, and therefore, export prices for CIMC Reefer were estimated in accordance with section 25 of SIMA.

[163] The total estimated normal value compared to the total estimated export price results in an estimated margin of dumping of 137.1% for CIMC Reefer, expressed as a percentage of the export price.

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All other exporters

[164] Although no evidence was found that other exporters had exported subject goods to Canada during the POI, provisional anti-dumping duty is applicable should that change during the final phase of the investigation, or should new exporters begin selling subject goods to Canada.

[165] In establishing the methodology for estimating the normal values and export prices for all other exporters, the CBSA considered all of the information on the administrative record, including the complaint filed by the domestic industry, the CBSA’s estimates at the initiation of the investigation, information submitted by parties that responded to the dumping RFI and surrogate producer RFI, and CBSA customs entry documentation.

[166] The CBSA decided that the normal values estimated for all other potential exporters of subject goods from China would be estimated based on information from the exporter in China that provided a substantially complete RFI response for purposes of the preliminary determination. The CBSA finds this information to be more relevant and reflective of the trading practices of exporters in China than the information provided in the complaint or estimated at initiation.

[167] Based on the facts available, for potential exporters that did not provide a response to the dumping RFI, normal values of subject goods originating in or exported from China were estimated based on the highest amount by which an estimated normal value exceeded the estimated export price (expressed as a percentage of the export price), on an individual transaction basis for the cooperative exporter during the POI. The transactions were examined to ensure that no anomalies were considered, such as very low volumes and values, effects of seasonality, or other business factors.

[168] Using the above methodology, for the preliminary determination, the estimated margin of dumping for all other exporters of subject goods is 345.9%, expressed as a percentage of the export price.

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Summary of preliminary results: Dumping

[169] A summary of the preliminary results of the dumping investigation respecting all subject goods shipped to Canada during the POI are as follows:

| Exporter | Estimated margin of dumping
(% of export price) | Estimated % of total imports
(by volume) |
| --- | --- | --- |
| Qingdao CIMC Reefer Trailer Co., Ltd. | 137.1% | 53% |

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Negligibility

[170] Under section 35 of SIMA, the CBSA is required to terminate an investigation prior to the preliminary determination if the volume of goods of a country is negligible.

[171] Pursuant to subsection 2(1) of SIMA, the volume of goods of a country is considered negligible if it accounts for less than 3% of the total volume of all goods of the same description that are released into Canada from all countries.

[172] The table above confirms that the volume of imports from China is above 3% of the total volume of goods released into Canada. Based on the definition above, the volume of imports from China are not negligible.

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Insignificance

[173] If, in making a preliminary determination, the CBSA determines that the margin of dumping of the goods of an exporter is insignificant pursuant to section 38 of SIMA, the investigation will continue in respect of those goods, but provisional anti-dumping duties will not be imposed on goods of the same description imported during the provisional period. Pursuant to subsection 2(1) of SIMA, a margin of dumping of less than 2% of the export price of the goods is defined as insignificant.

[174] For all exporters in China the estimated margin of dumping, expressed as a percentage of the export price, is above 2% and is, therefore, not insignificant. In respect of these goods, provisional anti-dumping duties will be imposed on goods of the same description imported during the provisional period.

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Subsidy investigation

[175] In accordance with section 2 of SIMA, a subsidy exists where there is a financial contribution by a government of a country other than Canada that confers a benefit on persons engaged in the production, manufacture, growth, processing, purchase, distribution, transportation, sale, export or import of goods. A subsidy also exists in respect of any form of income or price support within the meaning of Article XVI of the General Agreement on Tariffs and Trade, 1994, being part of Annex 1A to the World Trade Organization (WTO) Agreement that confers a benefit.

[176] Pursuant to subsection 2(1.6) of SIMA, a financial contribution exists where:

1. practices of the government involve the direct transfer of funds or liabilities or the contingent transfer of funds or liabilities
2. amounts that would otherwise be owing and due to the government are exempted or deducted or amounts that are owing and due to the government are forgiven or not collected
3. the government provides goods or services, other than general governmental infrastructure, or purchases goods or
4. the government permits or directs a nongovernmental body to do anything referred to in any of paragraphs (a) to (c) above where the right or obligation to do the thing is normally vested in the government and the manner in which the nongovernmental body does the thing does not differ in a meaningful way from the manner in which the government would do it [177] A state-owned enterprise (SOE) may be considered “government” for the purposes of subsection 2(1.6) of SIMA if it possesses, exercises, or is vested with, governmental authority. Without limiting the generality of the foregoing, the CBSA may consider the following factors as indicative of whether the SOE meets this standard: 1) the SOE is granted or vested with authority by statute; 2) the SOE is performing a government function; 3) the SOE is meaningfully controlled by the government; or 4) some combination thereof.

[178] If a subsidy is found to exist, it may be subject to countervailing measures if it is specific. A subsidy is considered to be specific when it is limited, in law or in fact, to a particular enterprise or is a prohibited subsidy. An “enterprise” is defined under SIMA as also including a “group of enterprises, an industry and a group of industries”. Any subsidy which is contingent, in whole or in part, on export performance or on the use of goods that are produced or that originate in the country of export is considered to be a prohibited subsidy and is, therefore, specific according to subsection 2(7.2) of SIMA for the purposes of a subsidy investigation.

[179] In accordance with subsection 2(7.3) of SIMA, notwithstanding that a subsidy is not specific in law, a subsidy may also be considered specific in fact, having regard as to whether:

• there is exclusive use of the subsidy by a limited number of enterprises
• there is predominant use of the subsidy by a particular enterprise
• disproportionately large amounts of the subsidy are granted to a limited number of enterprises and
• the manner in which discretion is exercised by the granting authority indicates that the subsidy is not generally available [180] For purposes of a subsidy investigation, the CBSA refers to a subsidy that has been found to be specific as an “actionable subsidy”, meaning that it is countervailable.

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Preliminary results of the subsidy investigation

[181] At the initiation of the subsidy investigation, the CBSA sent subsidy RFIs to the Government of China, as well as to all known exporters/producers of truck bodies in China.

[182] The Government of China was also requested to forward the subsidy RFI to all subordinate levels of government that had jurisdiction over the exporters. The exporters/producers were requested to forward a portion of the subsidy RFI to their input suppliers, that were asked to respond to questions pertaining to their legal characterization as SOEs.

Government of China

[183] The Government of China provided a response to the Government Subsidy RFI. For the purposes of the preliminary determination, the CBSA is treating the Government of China’s response as partially complete. For programs where complete information was provided by the Government of China, the CBSA used this information in its determination of specificity. For programs where the Government of China’s response was incomplete or contradictory, the CBSA relied on the best information available.

[184] At the initiation of the subsidy investigation, the CBSA requested information on 26 potential subsidy programs that could potentially confer benefits to producers/exporters of truck bodies in China.

[185] The CBSA found an additional 5 potential subsidy programs that were reported by the exporter/producers. In total, and for the preliminary determination, the CBSA found 31 potential subsidy programs that could potentially confer benefits to producers/exporters of truck bodies in China.

[186] The Government of China’s response to the 31 potential subsidy programs fell into one of the three following categories:

1. Programs that were confirmed to be specific
2. Programs without sufficient information to determine specificity or
3. Programs for which there was contradictory evidence [187] For programs in category ii), due to the lack of a information provided by the Government of China with respect to these programs, there is insufficient information on the record to determine whether these programs were specific pursuant to subsection 2(7.2) or subsection 2(7.3) of SIMA; nor is there sufficient information to indicate that the subsidy is not specific pursuant to the criteria set out in subsection 2(7.1) of SIMA. The CBSA has made adverse inferences based on information available on the administrative record, and as a result, programs in category ii) were considered to be specific for the purposes of the preliminary determination.

[188] For programs in category iii), the CBSA weighed the evidence available on the administrative record from both the participating exporters and from the Government of China. The evidence provided by the participating exporters, which includes information on programs that they received during the POI, and which the CBSA found in China’s Notification to the WTO on Subsidies and Countervailing Measures, contradicted the information provided by the Government of China in its response. In instances where the Government of China stated that a subsidy program did not exist, the CBSA found compelling evidence to the contrary from the exporters and/or China’s WTO notification. On the basis of the information available, programs in category iii) were considered to be specific for the purposes of the preliminary determination.

[189] For programs in categories ii) and iii), the Government of China has been requested to provide additional information to address these issues.

[190] For the preliminary determination, the CBSA determined all 31 subsidy programs to be specific, and therefore actionable.

[191] The CBSA will continue to analyze the submitted information during the final phase of the investigation. The CBSA may also consider any other potential subsidy programs that have not yet been identified in its final decision.

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Qingdao CIMC Reefer Trailer Co., Ltd. (CIMC Reefer)

[192] CIMC Reefer is the only producer and exporter of subject goods to Canada that provided a substantially complete response to the Subsidy RFI and to one supplemental Subsidy RFI.

[193] For purposes of the preliminary determination, it is estimated that CIMC Reefer benefitted from six subsidy programs during the subsidy POI:

• Program 17: Preferential Tax Treatment of Additional Calculation and Deduction of Research and Development Expenses
• Program 19: Accelerated depreciation of fixed assets
• Program 31: Reduction on Land Usage Tax
• Program 28: Grant - Bonus for Revenue Exceeding One Billion CNY For the First Time
• Program 29: Grant - Bonus for Integration of Technology and Information
• Program 30: Handling Fees for Withholding Employees' Individual Income Tax on behalf of Taxation Agency [194] For the purposes of the preliminary determination, the above subsidy programs were considered to be specific and therefore actionable. Further, the CBSA considers that financial contributions conferring a subsidy were provided to the exporter pursuant to the above subsidy programs. This decision was made from the analysis of the information provided by CIMC Reefer and by the Government of China.

[195] The estimated amount of subsidy CIMC Reefer is 0.95%, expressed as a percentage of the export price. The CBSA will continue to collect and verify information from CIMC Reefer and the Government of China.

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All exporters: China

[196] Although no evidence was found that other exporters had exported subject goods to Canada during the POI, provisional countervailing duty is applicable should that change during the final phase of the investigation, or should new exporters begin selling subject goods to Canada.

[197] For all other potential exporters of subject goods from China, the CBSA estimated an amount of subsidy on the basis of the following methodology:

1. the highest amount of subsidy for each of the six programs, as found at the preliminary determination, for the exporter located in China for which the CBSA has sufficient information to estimate an amount of subsidy, plus
2. the highest amount of subsidy for the six programs listed in (a), applied to each of the remaining 25 potentially actionable subsidy programs for which sufficient information is not available or has not been provided at the preliminary determination [198] In establishing the methodology for estimating the amount of subsidy for all other potential exporters from China, the CBSA considered all of the information on the administrative record, including the complaint filed by the domestic industry, the CBSA’s estimates at the initiation of the investigation, and information submitted by the exporter and the Government of China.

[199] This methodology relies on information related to potentially actionable subsidies in China, and provides an incentive for exporters to participate, as it may result in the application of a less favourable rate, such that non-cooperative parties do not receive an advantage over those that cooperated during the investigation.

[200] Using the above methodology, for the preliminary determination, the estimated amount of subsidy for all other potential exporters in China is 12.0% expressed as a percentage of the export price.

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Summary of preliminary results: Subsidy

[201] A summary of the preliminary results of the subsidy investigation respecting all subject goods shipped to Canada during the POI follows:

| Exporter | Estimated margin of subsidy
(% of export price) | Estimated % of total imports
(by volume) |
| --- | --- | --- |
| Qingdao CIMC Reefer Trailer Co., Ltd. | 0.95% | 53% |

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Negligibility

[202] Under section 35 of SIMA, the CBSA is required to terminate an investigation prior to the preliminary determination if the volume of goods of a country is negligible.

[203] Pursuant to subsection 2(1) of SIMA, a volume of goods of a country is considered negligible if it accounts for less than 3% of the total volume of all goods of the same description that are released into Canada from all countries.

[204] The table above confirms that the volume of imports from China is above 3% of the total volume of goods released into Canada. Based on the definition above, the volume of imports from China is not negligible.

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Insignificance

[205] If, in making a preliminary determination, the CBSA determines that the amount of subsidy of the goods of an exporter is insignificant, the investigation will continue in respect of those goods but provisional countervailing duty will not be imposed on goods of the same description imported during the provisional period, pursuant to subsections 8(1.3) and 38(1.1) of SIMA.

[206] Pursuant to subsection 2(1) of SIMA, an amount of subsidy less than 1% of the export price of the goods is defined as insignificant. The estimated amount of subsidy of truck bodies exported by CIMC Reefer is below 1% and is, therefore, insignificant. Provisional countervailing duty will not be imposed on goods exported by CIMC Reefer during the provisional period.

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Decisions

[207] On March 6, 2026, pursuant to subsection 38(1) of SIMA, the CBSA made preliminary determinations of dumping and subsidizing respecting truck bodies from China.

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Provisional duty

[208] Pursuant to subsection 8(1) of SIMA, provisional duties payable by the importer in Canada will be applied to dumped and subsidized imports of truck bodies that are released from the CBSA during the period commencing on the day the preliminary determinations are made and ending on the earlier of the day on which the CBSA causes the investigations in respect of any goods to be terminated, in accordance with subsection 41(1), or the day on which the CITT makes an order or finding. The CBSA considers that the imposition of provisional duties is needed to prevent injury. As noted in the CITT’s preliminary determination, there is evidence that discloses a reasonable indication that the dumping and subsidizing of truck bodies have caused or are threatening to cause injury to the domestic industry.

[209] Imports of truck bodies originating in or exported from China, and released by the CBSA on or after March 6, 2026, will be subject to provisional duties equal to the sum of the estimated margin of dumping and the estimated amount of subsidy, expressed as a percentage of the export price of the goods. Appendix 1 contains the estimated margins of dumping, estimated amount of subsidy and the rates of provisional duties. Where the estimated amount of subsidy for a particular exporter is insignificant, the investigation will continue, and provisional countervailing duty will not be imposed on importations of the goods from that particular exporter.

[210] Importers are required to pay provisional duties in cash or it may be guaranteed by posting a surety bond equal to the amount payable. Importers should contact their CBSA regional office if they require further information on the payment of provisional duties or the posting of security. Importers must properly describe the goods that they are importing, whether the information is submitted in paper or electronic format. Customs Memorandum D17-1-1: Documentation Requirements for Commercial Shipments explains the normal customs requirements. However, these requirements are often not enough for SIMA purposes. Consult the "Information Required on Customs Documents" section on the Measures in Force for specific information required for each SIMA measure, as well as Memorandum D14-1-7: Assessment and payment of duties are required under the Special Import Measures Act (SIMA) for more general information.

[211] The CBSA’s Assessment and Revenue Management (CARM) system will generally assign the SIMA code on Commercial Accounting Declarations (CAD). However, when populating pre-CARM entries into CARM, or when accounting for CLVS goods on a Type F CAD, you may be required to self-declare the SIMA code on the CAD. Importers may be assessed an administrative monetary penalty if they fail to provide the required code for any goods subject to SIMA. The imported goods are also subject to the Customs Act. As a result, failure to pay duties within the specified time will result in the application of the provisions of the Customs Act regarding interest.

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Future action

The Canada Border Services Agency

[212] The CBSA will continue its investigations of the dumping and subsidizing of truck bodies and will make final decisions by June 4, 2026.

[213] If the margin of dumping or amount of subsidy of any exporter are found to be insignificant, the CBSA will terminate the investigation in respect of goods of that exporter and any provisional duties paid or security posted will be refunded to importers, as appropriate. If the CBSA is satisfied that the goods were dumped and/or subsidized, final determinations will be made.

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The Canadian International Trade Tribunal

[214] The CITT has begun its inquiry into the question of injury to the Canadian industry. The CITT is expected to issue its finding by July 3, 2026.

[215] If the CITT finds that the dumping has not caused injury, retardation or is not threatening to cause injury, the proceedings will be terminated and all provisional anti-dumping duty collected or security posted will be refunded.

[216] If the CITT makes a finding that the dumping has caused injury, retardation or is threatening to cause injury, anti-dumping duty in an amount equal to the margin of dumping will be levied, collected and paid on imports of truck bodies that are of the same description as goods described in the CITT’s finding.

[217] If the CITT finds that the subsidizing has not caused injury, retardation or is not threatening to cause injury, the proceedings will be terminated and all provisional countervailing duty collected or security posted will be refunded.

[218] If the CITT makes a finding that the subsidizing has caused injury, retardation or is threatening to cause injury, countervailing duty in the amount equal to the amount of subsidy on the imported goods will be levied, collected and paid on imports of truck bodies that are of the same description as goods described in the CITT’s finding.

[219] For purposes of the preliminary determinations of dumping or subsidizing, the CBSA has responsibility for determining whether the actual and potential volume of goods is negligible. After preliminary determinations of dumping or subsidizing, the CITT assumes this responsibility. In accordance with subsection 42(4.1) of SIMA, the CITT is required to terminate its inquiry in respect of any goods if the CITT determines that the volume of dumped or subsidized goods from a country is negligible.

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Retroactive duty on massive importations

[220] Under certain circumstances, anti-dumping and/or countervailing duty can be imposed retroactively on subject goods imported into Canada. When the CITT conducts its inquiry on material injury to the Canadian industry, it may consider if dumped and/or subsidized goods that were imported close to or after the initiation of the investigations constitute massive importations over a relatively short period of time and have caused injury to the Canadian industry. Should the CITT issue a finding that there were recent massive importations of dumped and/or subsidized goods that caused injury, imports of subject goods released by the CBSA in the 90 days preceding the day of the preliminary determinations could be subject to anti-dumping and/or countervailing duty.

[221] In respect of importations of subsidized goods that have caused injury, this provision is only applicable where the CBSA has determined that the whole or any part of the subsidy on the goods is a prohibited subsidy. In such a case, the amount of countervailing duty applied on a retroactive basis will equal the amount of subsidy on the goods that is a prohibited subsidy. An export subsidy is a prohibited subsidy according to subsection 2(1) of SIMA.

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Undertakings

[222] After a preliminary determination of dumping by the CBSA, other than a preliminary determination in which a determination was made that the margin of dumping of the goods is insignificant, an exporter may submit a written undertaking to revise selling prices to Canada so that the margin of dumping or the injury caused by the dumping is eliminated.

[223] Similarly, after the CBSA has rendered a preliminary determination of subsidizing, a foreign government may submit a written undertaking to eliminate the subsidy on the goods exported or to eliminate the injurious effect of the subsidy, by limiting the amount of the subsidy or the quantity of goods exported to Canada. Alternatively, exporters with the written consent of their government may undertake to revise their selling prices so that the amount of the subsidy or the injurious effect of the subsidy is eliminated.

[224] In view of the time needed for consideration of undertakings, written undertaking proposals should be made as early as possible, and no later than 60 days after the preliminary determinations of dumping and subsidizing. Further details regarding undertakings can be found in the CBSA’s Memorandum D14-1-9: Information Pertaining to the Acceptance, Enforcement and Renewal of Undertakings in Dumping and Subsidy Investigations.

[225] Interested parties may provide comments regarding the acceptability of undertakings within nine days of the receipt of an undertaking by the CBSA. The CBSA will maintain a list of parties that wish to be notified should an undertaking proposal be received. Those who are interested in being notified should provide their name, telephone, mailing address and email address to the CBSA using the contact information identified in the Contact us section.

[226] If undertakings were to be accepted, the investigations and the collection of provisional duties would be suspended. Notwithstanding the acceptance of an undertaking, an exporter may request that the CBSA’s investigations be completed and that the CITT complete its injury inquiry.

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Publication

[227] A notice of these preliminary determinations of dumping and subsidizing will be published in the Canada Gazette pursuant to paragraph 38(3)(a) of SIMA.

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Contact us

[228] For further information, please contact the email address identified below:

Email: simaregistry-depotlmsi@cbsa-asfc.gc.ca

Sean Borg
A/Executive Director
Trade and anti-dumping programs directorate

Appendix 1: Summary of estimated margins of dumping, estimated amount of subsidy and provisional duties payable

The following table lists the estimated margin of dumping, the estimated amount of subsidy, and the provisional duty by exporter as a result of the decisions mentioned above. Imports of subject goods released from the Canada Border Services Agency on or after March 6, 2026, will be subject to provisional duty at the rate specified below.

| Exporter | Estimated margin of dumping
(% of export price) | Estimated margin of subsidy
(% of export price) | Provisional duties
(% of export price) |
| --- | --- | --- | --- |
| Qingdao CIMC Reefer Trailer Co., Ltd. | 137.1% | 0.95% 1 | 137.1% |
| All other exporters | 345.9% | 12.0% | 357.9% |
| 1 As the estimated amount of subsidy for Qingdao CIMC Reefer Trailer Co., Ltd. is below 1% and is therefore, insignificant, provisional countervailing duty will not be imposed on goods exported by Qingdao CIMC Reefer Trailer Co., Ltd. during the provisional period. | | | |

Footnotes

Footnote 1 Exhibits 58 (PRO) & 59 (NC) - Response to section 20 RFI from Qingdao CIMC Reefer Trailer Co., Ltd.; Exhibits 63 (PRO) & 64 (NC) - Response to subsidy RFI from Qingdao CIMC Reefer Trailer Co.; Ltd., Exhibits 65 (PRO) & 66 (NC) - Response to dumping RFI from Qingdao CIMC Reefer Trailer Co., Ltd.; Exhibits 107 (PRO) & 108 (NC) - Response to SRFI #1 from Qingdao CIMC Reefer Trailer Co., Ltd.; Exhibits 111 (PRO) and 112 (NC) - Additional response to SRFI #1 from Qingdao CIMC Reefer Trailer Co., Ltd.; Exhibits 117 (PRO) & 118 (NC) - Response to SRFI #2 from Qingdao CIMC Reefer Trailer Co., Ltd.

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Footnote 2 Exhibits 46 (PRO) & 47 (NC) - Response to Importer RFI from Vanguard Refrigerated Trailer Co., Ltd.; Exhibits 105 (PRO) & 106 (NC) - Response to SRFI from Vanguard Refrigerated Trailer Co., Ltd.

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Footnote 3 Exhibits 70 (PRO) & 71 (NC) - Response to Surrogate Producer RFI from Morgan Truck Body LLC; Exhibits 101 (PRO) & 102 (NC) - Response to SRFI from Morgan Truck Body LLC

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Footnote 4 Exhibits 120 (PRO) & 121 (NC) - Response to surrogate producer RFI - from Dee Siam Manufacturing Co., Ltd.

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Footnote 5 Exhibits 125 (PRO) & 126 (NC) - Response to surrogate producer RFI - from Dongguan CIMC Vehicle Co., Ltd.

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Footnote 6 Exhibits 127 (PRO) & 128 (NC) - Response to surrogate producer RFI - from CIMC Vehicle (Jiangmen) Co., Ltd.

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Footnote 7 Exhibits 72 (PRO) & 73 (NC) - Response to government subsidy RFI from Ministry of Commerce of the People's Republic of China; Exhibits 122 (PRO) and 123 (NC) - Response to SRFI#1 from Ministry of Commerce of the People's Republic of China

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Footnote 8 Exhibits 39 (PRO) & 40 (NC) - Response to RFI - industry profit survey from Morgan Canada Corporation

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Footnote 9 Exhibits 49 (PRO) & 50 (NC) - Response to RFI - industry profit survey from Morgan Transit Corporation

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Footnote 10 Exhibits 32 (PRO) & 33 (NC) - Response to RFI - industry profit survey from Intercontinental Truck Body (B.C.) Inc.

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Footnote 11 Exhibits 36 (PRO) & 37 (NC) - Response to RFI - industry profit survey from Intercontinental Truck Body Ltd.

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Footnote 12 Exhibits 75 (PRO) & 76 (NC) - Response to SRFI from Morgan Canada Corporation

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Footnote 13 Exhibits 78 (PRO) & 79 (NC) - Response to SRFI from Morgan Transit Corporation

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Footnote 14 Exhibit 2 - Truck Bodies Complaint (NC), paras. 28-44

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Footnote 15 Substantially complete major subassemblies have the essential characteristics of the complete major subassemblies.

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Footnote 16 Exhibit 2 - Truck Bodies Complaint (NC), paras. 61-70

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Footnote 17 "Fabrication" refers to the process of cutting, shaping, and forming raw materials into the individual structural components that make up the truck body before those parts are joined together in subassemblies. This fabrication process involves cutting steel or aluminum stock (channels, tubes, sheet) to specified dimensions, punching, drilling, or cutting holes and slots for fasteners or wiring, ending or forming panels and structural members to required shapes, and welding, riveting, or otherwise joining smaller pieces to create a larger structural component before it is affixed to the rest of the body.

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Footnote 18 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, paras. 139-168

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Footnote 19 Canadian International Trade Tribunal; Preliminary Injury Inquiry - Truck Bodies - Statement of Reasons (January, 2026), PI-2025-007, paras. 30-31

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Footnote 20 Exhibits 129 (PRO) and 130 (NC) - Comments submitted by counsel for Morgan Canada Corporation and Morgan Transit Corporation regarding the responses to the requests for information (RFI) and responses to the supplemental requests for information (SRFI) from Qingdao CIMC Reefer Trailer Co., Vanguard Refrigerated Trailer Co., Ltd., Government of China, Dee Siam Manufacturing; Exhibits 131 (PRO) & 132 (NC) - Comments submitted by counsel for Morgan Canada Corporation and Morgan Transit Corporation (Morgan) regarding the responses to the requests for information (RFI) from Dongguan CIMC Vehicle Co., Ltd. and CIMC Vehicle (Jiangmen) Co., Ltd.

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Footnote 21 Exhibits 80 (NC) - Additional comments submitted by counsel for Morgan Chelsea Corp regarding financial information from US producers

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Footnote 22 China is a prescribed countries under Section 17.1 of the Special Import Measures Regulations.

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Footnote 23 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, paras. 245 - 247

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Footnote 24 CC 2021 IN, Statement of Reasons - Final Determination (CBSA) at para 148

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Footnote 25 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, para.296 (Exhibit VI-5-8 - GOC Distortion Evidence - Outline of the People's Republic of China 14th Five-Year Plan for National Economic and Social Development and Long-Range Objectives for 2035, (March 12, 2021) (PUBLIC)) p. 26

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Footnote 26 Ibid. (Exhibit VI-5-8 - GOC Distortion Evidence - Outline of the People's Republic of China 14th Five-Year Plan for National Economic and Social Development and Long-Range Objectives for 2035, (March 12, 2021) (PUBLIC)) p. 19

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Footnote 27 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, para.297 (Exhibit VI-5-8 - GOC Distortion Evidence - Outline of the People's Republic of China 14th Five-Year Plan for National Economic and Social Development and Long-Range Objectives for 2035, (March 12, 2021) (PUBLIC)).p 28

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Footnote 28 Exhibit 0133 (NC) - TB 2025 IN PD S20 - Attachment 1 - Notice of the Ministry of Transport and the National Development and Reform Commission on Issuing the Action Plan for Reducing Costs, Improving Quality and Increasing Efficiency in Transportation and Logistics

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Footnote 29 Response to Section 20 RFI from Qingdao CIMC Reefer Trailer Co., Ltd., Exhibit A1(c) - 14th Five-Year Plan Cold Chain Logistics Development Plan (CN and EN), p.11

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Footnote 30 Ibid., 14th Five-Year Plan Cold Chain Logistics Development Plan (CN and EN, p.5

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Footnote 31 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, para.298 (Exhibit VI-5-28 - GOC Distortion Evidence - General Office of the State Council "14th Five-Year Plan Cold Chain Logistics Development Plan" (November 26, 2021) (PUBLIC), p.12.

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Footnote 32 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, para.298 (Exhibit VI-5-28 - GOC Distortion Evidence - General Office of the State Council "14th Five-Year Plan Cold Chain Logistics Development Plan" (November 26, 2021) (PUBLIC), p.20

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Footnote 33 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, para.299 (Exhibit VI-9-1 - CIMC Articles (PUBLIC) - CIMC Vehicles "Gelonghui: CIMC Vehicles' Market Share Further Increases with Rise in Long-term Value of Investment" (April 27, 2022) (PUBLIC), p. 3.

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Footnote 34 Ibis, p.3.

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Footnote 35 Ibid. (Exhibit VI-5-30 - GOC Distortion Evidence - Ministry of Transportation, "Implementation Opinions on Accelerating the High-Quality Development of Cold Chain Logistics Transportation" (April 2022) (PUBLIC))

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Footnote 36 Truck Bodies Complaint, para.301

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Footnote 37 Ibid. (Exhibit VI-5-32 - GOC Distortion Evidence - J. Tian, P. Wang, D. Zhu, "Overview of Chinese new energy vehicle industry and policy development" Green Energy and Resources 2024:2, (May 22, 2024) (PUBLIC). )

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Footnote 38 Truck Bodies Complaint (Exhibit VI-5-33 - GOC Distortion Evidence - IIFIIR - China's Cold Chain Growth (February 6, 2025) (PUBLIC).)

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Footnote 39 Exhibit 0133 (NC) -TB 2025 IN PD S20 - Attachment 2 - Action plan to improve the quality and efficiency of freight transportation and logistics in China, page 4

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Footnote 40 Exhibit 0133 (NC) - TB 2025 IN PD S20 - Attachment 3 - China-scrappage policy-update, page 2 & 3

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Footnote 41 Exhibit 0133 (NC) - TB 2025 IN PD S20 - Attachment 4 - China's expanded incentives for scrapping and replacing transportation equipment, page 2

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Footnote 42 The One Belt One Road Action Plan

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Footnote 43 Exhibits 58 (PRO) & 59 (NC) - QCTC's Response to Section 20 RFI - Public Exhibit A1(a)TB 2025 INQCTC (S20) 14th FYP, Chapter 41, page 158

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Footnote 44 Certain Container Chassis from China (February 3, 2022), CC 2021 IN, Statement of Reasons - Final Determination (CBSA) at para 89.

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Footnote 45 Certain Container Chassis from China (February 3, 2022), CC 2021 IN, Statement of Reasons - Final Determination (CBSA) at para 92.

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Footnote 46 Exhibits 58 (PRO) & 59 (NC) - QCTC's Response to Section 20 RFI - Public Exhibit A1(c) - 14th Five-Year Plan Cold Chain Logistics Development Plan (CN and EN)

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Footnote 47 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, para.304 (Exhibit VI-5-17 - GOC Distortion Evidence - Translated Administrative Regulation on the Investment Management in the Automotive Industry (PUBLIC), p. 2.)

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Footnote 48 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, para.305 (Exhibit VI-5-17 - GOC Distortion Evidence - Translated Administrative Regulations on the Investment Management of the Automobile Industry (PUBLIC), p. 6.)

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Footnote 49 Exhibits 58 (PRO) & 59 (NC) - QCTC's Response to Section 20 RFI, page 4

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Footnote 50 Exhibits 58 (PRO) & 59 (NC) - Response to request for information (RFI) - section 20 from Qingdao CIMC Reefer Trailer Co., Ltd. ("QCTC") (Public Exhibit A1(k)TB 2025 INQCTC (S20)_2025-12-04; p. 23, Article 28.2.)

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Footnote 51 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint para.307 (Exhibit VI-5-26 - GOC Distortion Evidence - Translated Catalogue on Industrial Structure Adjustment Guidance, 2024 (PUBLIC), pp. 2, 22, 59.)

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Footnote 52 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, para.307 (Exhibit VI-5-26 - GOC Distortion Evidence - Translated Catalogue on Industrial Structure Adjustment Guidance, 2024 (PUBLIC), p. 53.

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Footnote 53 Ibid. (Exhibit VI-5-26 - GOC Distortion Evidence - Translated Catalogue on Industrial Structure Adjustment Guidance, 2024 (PUBLIC), p. 59.)

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Footnote 54 Ibid. (Exhibit VI-5-26 - GOC Distortion Evidence - Translated Catalogue on Industrial Structure Adjustment Guidance, 2024 (PUBLIC), p. 4.)

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Footnote 55 Certain Container Chassis from China (February 3, 2022), CC 2021 IN, Statement of Reasons - Final Determination (CBSA) at paras 105-106.

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Footnote 56 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, para. 278

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Footnote 57 Exhibits 58 (PRO) & 59 (NC) - Response to request for information (RFI) - section 20 from Qingdao CIMC Reefer Trailer Co., Ltd. ("QCTC")

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Footnote 58 Exhibit 0133 (NC) - TB 2025 IN PD S20 - Attachment 5 -CIMC 2024 Annual report, page 213

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Footnote 59 Exhibit 0133 (NC) - TB 2025 IN PD S20 - Attachment 6 - Equity Structure Chart

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Footnote 60 About Us - Shenzhen Capital Group Co., Ltd.

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Footnote 61 CMG Introduction-Introduction-China Merchants Group

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Footnote 62 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, para. 285

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Footnote 63 Exhibits 58 (PRO) & 59 (NC) - Response to (RFI) - section 20 from Qingdao CIMC Reefer Trailer Co., Ltd. ("QCTC") Confidential Narrative p.19

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Footnote 64 Ibid., p. 12

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Footnote 65 Ibid., p. 13

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Footnote 66 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, para. 300, Public Exhibit VI-5-31 - GOC Distortion Evidence - Netherlands Ministry of Foreign Affairs "A quick Scan of Cold Chain Logistics Sectors in China's Greater Bay Area" (2020) at 21

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Footnote 67 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, Public Exhibit VI-5-31 - GOC Distortion Evidence - Netherlands Ministry of Foreign Affairs "A quick Scan of Cold Chain Logistics Sectors in China's Greater Bay Area" (2020) at 17

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Footnote 68 Exhibit 0133 (NC) - TB 2025 IN PD S20 - Attachment 7 - Notice by the People's Bank of China, the Ministry of Transport and the China Banking and Insurance Regulatory Commission of Further Providing Effective Financial Support and Services in the Fields of Transportation and Logistics

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Footnote 69 Exhibit 0133 (NC) - TB 2025 IN PD S20 - Attachment 8 - Special refinancing for transportation and logistics

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Footnote 70 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, Joint Declaration of Joel Chandonnet & Rick Rovito at para 27, Table 1.& para. 260 at Table 1

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Footnote 71 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, para. 260, Joint Declaration of Joel Chandonnet & Rick Rovito at Table 1

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Footnote 72 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, para. 261

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Footnote 73 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, para. 264

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Footnote 74 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, para. 268

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Footnote 75 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, para 263, Certain Aluminum Extrusions (3 March 2009) 4214-22 AD/1379, 4218-26 CV/124, Statement of Reasons - Final Determination (CBSA) at Appendix 3

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Footnote 76 Certain Aluminum Extrusions (3 March 2009) 4214-22 AD/1379, 4218-26 CV/124, Statement of Reasons - Final Determination (CBSA) at Appendix 3

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Footnote 77 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, Exhibit VI-5-15 - GOC Distortion Evidence - WTO, China Trade Policy Review WT/TPR/S/458/Rev.1 (November 19, 2024) (PUBLIC), p. 69.

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Footnote 78 Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, Exhibit VI-5-17 - GOC Distortion Evidence - Translated Administrative Regulation on Investment Management in the Automotive Industry (PUBLIC), p. 2.

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Footnote 79 Exhibits 65 (PRO) & 66 (NC) - Response to dumping RFI - Qingdao CIMC Reefer Trailer Co., Ltd.

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Footnote 80 Exhibits 70 (PRO) & 71 (NC) - Response to Surrogate Producer RFI - Morgan Truck Body, LLC.

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Footnote 81 Exhibits 70 (PRO) & 71 (NC) - Response to Surrogate Producer RFI from Morgan Truck Body LLC

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Footnote 82 Exhibits 75 (PRO) & 76 (NC) - Response to SRFI from Morgan Canada Corporation

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Footnote 83 Exhibits 78 (PRO) & 79 (NC) - Response to SRFI from Morgan Transit Corporation

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Date modified:

2026-03-20