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Steel Wheels Trade Investigation Initiation from China

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Filed March 19th, 2026
Detected March 21st, 2026
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Summary

The U.S. Department of Commerce has initiated a country-wide circumvention inquiry into steel wheels imported from Vietnam. This investigation will determine if these imports are circumventing existing antidumping and countervailing duties on steel wheels from China. The inquiry was requested by domestic interested parties Accuride Corporation and Maxion Wheels USA LLC.

What changed

The U.S. Department of Commerce (Commerce) has initiated a circumvention inquiry concerning steel wheels imported from Vietnam. This action stems from a request by domestic producers Accuride Corporation and Maxion Wheels USA LLC, who allege that steel wheels finished in Vietnam using Chinese-produced hot-rolled steel are circumventing existing antidumping and countervailing duty (AD/CVD) orders on steel wheels from China. The inquiry will determine if these Vietnamese imports should be included within the scope of the existing AD/CVD orders.

This initiation means that importers and exporters of steel wheels from Vietnam, particularly those utilizing Chinese-origin steel, should prepare for potential inclusion in the AD/CVD orders. While no specific compliance deadline is provided in this initiation notice, companies involved in this trade should review the scope of the existing orders and the details of the circumvention inquiry. Failure to comply with any resulting duties could lead to significant financial penalties and trade restrictions.

What to do next

  1. Review the scope of existing AD/CVD orders on steel wheels from China.
  2. Monitor the progress and findings of the circumvention inquiry initiated by Commerce.
  3. Assess potential exposure to AD/CVD duties if circumvention is found.

Source document (simplified)

Content

SUMMARY:

In response to a request from Accuride Corporation (Accuride) and Maxion Wheels USA LLC (Maxion) (domestic interested parties),
the U.S. Department of Commerce (Commerce) is initiating a country-wide circumvention inquiry to determine whether imports
of certain steel wheels from the Socialist Republic of Vietnam (Vietnam) are circumventing the antidumping duty (AD) and countervailing
duties (CVD) orders on certain steel wheels from the People's Republic of China (China).

DATES:

Applicable March 19, 2026.

FOR FURTHER INFORMATION CONTACT:

Thomas Cloyd, AD/CVD Operations, Enforcement and Compliance, International Trade Administration, U.S. Department of Commerce,
1401 Constitution Avenue NW, Washington, DC 20230; telephone: (202) 482-1246.

SUPPLEMENTARY INFORMATION:

Background

On January 14, 2026, pursuant to section 781(b) of the Tariff Act of 1930, as amended (the Act), and 19 CFR 351.226(i), Accuride
and Maxion (domestic interested parties) filed a circumvention inquiry request alleging that certain steel wheels finished
in Vietnam, using hot-rolled steel (HRS) produced in China, and subsequently exported from Vietnam to the United States are
circumventing the AD and CVD Orders on certain steel wheels from China (1) and, accordingly, should be included within the scope of the Orders. (2) On January 26, 2026, NCC Vietnam Company, Ltd. (NCC Vietnam) submitted adequacy comments alleging the legal requirements to
initiate a circumvention inquiry have not been met. (3) On February 2, 2026, domestic interested parties submitted rebuttal comments. (4) On February 9, 2026, we issued a supplemental questionnaire to domestic interested parties to clarify the period of inquiry
and period of comparison. (5) The domestic interested parties responded on February 12, 2026. (6)

Scope of the Orders

The merchandise subject to the Orders is certain on-the-road steel wheels, discs, and rims for tubeless tires, with a nominal rim diameter of 22.5 inches and 24.5
inches, regardless of width. Imports of the subject merchandise are currently classified under the following Harmonized Tariff
Schedule of the United States (HTSUS) subheadings: 8708.70.4530, 8708.70.4560, 8708.70.6030, 8708.70.6060, and 8716.90.5059.
Merchandise meeting the scope description may also enter under the following HTSUS subheadings: 4011.20.1015, 4011.20.5020,
and 8708.99.4850. While HTSUS subheadings are provided for convenience and customs purposes, the written description of the
scope of the Orders is dispositive. For a full description of the scope of the Orders, see the Initiation Checklist. (7)

Merchandise Subject to the Circumvention Inquiry

The circumvention inquiry covers certain steel wheels finished in Vietnam using HRS produced in China and subsequently exported
from Vietnam to the United States.

Initiation of Circumvention Inquiry

Section 351.226(d) of Commerce's regulations states that if Commerce determines that a request for a circumvention inquiry
satisfies the requirements of 19 CFR 351.226(c), then Commerce “will accept the request and initiate a circumvention inquiry.”
Section 351.226(c)(1) of Commerce's regulations, in turn, requires that each request for a circumvention inquiry allege “that
the elements necessary for a circumvention determination under section 781 of the Act exist” and be “accompanied by information

  reasonably available to the interested party supporting these allegations.” Domestic interested parties allege circumvention
  pursuant to section 781(b) of the Act (merchandise completed or assembled in other foreign countries).

Section 781(b)(1) of the Act provides that Commerce may find circumvention of an order when merchandise of the same class
or kind subject to the order is completed or assembled in a foreign country other than the country to which the order applies.
In conducting a circumvention inquiry, under section 781(b)(1) of the Act, Commerce relies on the following criteria: (A)
merchandise imported into the United States is of the same class or kind as any merchandise produced in a foreign country
that is the subject of an AD or CVD order; (B) before importation into the United States, such imported merchandise is completed
or assembled in another foreign country from merchandise which is subject to the order or is produced in the foreign country
that is subject to the order; (C) the process of assembly or completion in the foreign country referred to in section (B)
is minor or insignificant; (D) the value of the merchandise produced in the foreign country to which the AD or CVD order applies
is a significant portion of the total value of the merchandise exported to the United States; and (E) the administering authority
determines that action is appropriate to prevent evasion of such order.

In determining whether the process of assembly or completion in a foreign country is minor or insignificant under section
781(b)(1)(C) of the Act, section 781(b)(2) of the Act directs Commerce to consider: (A) the level of investment in the foreign
country; (B) the level of research and development in the foreign country; (C) the nature of the production process in the
foreign country; (D) the extent of production facilities in the foreign country; and (E) whether or not the value of processing
performed in the foreign country represents a small proportion of the value of the merchandise imported into the United States.
However, no single factor, by itself, controls Commerce's determination of whether the process of assembly or completion in
a foreign country is minor or insignificant. (8) Accordingly, it is Commerce's practice to evaluate each of these five factors as they exist in the foreign country, depending
on the totality of the circumstances of the particular circumvention inquiry. (9)

In addition, section 781(b)(3) of the Act sets forth additional factors to consider in determining whether to include merchandise
assembled or completed in a foreign country within the scope of an AD or CVD order. Specifically, Commerce shall take into
account such factors as: (A) the pattern of trade, including sourcing patterns; (B) whether the manufacturer or exporter of
the merchandise that was shipped to the foreign country is affiliated with the person who, in the foreign country, uses the
merchandise to complete or assemble the merchandise which is subsequently imported into the United States; and (C) whether
imports of the merchandise into the foreign country have increased after the initiation of the investigation that resulted
in the issuance of such order.

Analysis

Based on our analysis of the domestic interested parties' circumvention inquiry request and supplemental questionnaire response,
we determine that the Domestic Interested Parties have satisfied the criteria under 19 CFR 351.226(c), and thus, pursuant
to 19 CFR 351.226(d)(1)(iii), we have accepted the request and are initiating the requested circumvention inquiry of the Orders. For a full discussion of the basis for our decision to initiate the requested circumvention inquiry, see the Initiation Checklist. The Initiation Checklist is available on ACCESS. ACCESS is available to registered users at https://access.trade.gov.

As explained in the Initiation Checklist, the information provided by Domestic Interested Parties warrants initiating this
circumvention inquiry on a country-wide basis. Commerce has taken this approach in prior circumvention inquiries, where the
facts warranted initiation on a country-wide basis. (10)

As such, Commerce intends to issue questionnaires to solicit information from producers and exporters in Vietnam concerning
their shipments to the United States and the origin of hot-rolled steel manufactured in China and finished into “steel wheels”
(i.e., the merchandise subject to the Orders).

Respondent Selection

Commerce intends to base respondent selection on U.S. Customs and Border Protection (CBP) data. Commerce intends to place
the CBP data on the record within five days of the publication of this initiation notice, which will be available on Enforcement
and Compliance's Antidumping and Countervailing Duty Centralized Electronic Service System (ACCESS). ACCESS is available to
registered users at https://access.trade.gov. Comments regarding the CBP data and respondent selection should be submitted within seven days after placement of the CBP
data on the record of the inquiry.

Commerce intends to establish a schedule for questionnaire responses after respondent selection. A company's failure to completely
respond to Commerce's requests for information may result in the application of partial or total facts available, pursuant
to section 776(a) of the Act, which may include adverse inferences, pursuant to section 776(b) of the Act.

Suspension of Liquidation

Pursuant to 19 CFR 351.226(l)(1), Commerce intends to notify CBP of this initiation and direct CBP to continue the suspension
of liquidation of entries of products subject to this circumvention inquiry that were already subject to the suspension of
liquidation under the Orders and to apply the cash deposit rates that would be applicable if the products were determined to be covered by the scope of
the Orders. Should Commerce issue affirmative preliminary or final circumvention determinations, Commerce will follow the suspension of
liquidation rules under 19 CFR 351.226(l)(2)-(4). In the event that Commerce issues an affirmative preliminary or final circumvention
determination that the products are circumventing the Orders, Commerce will instruct CBP to continue the

  suspension of liquidation of previously suspended entries and to apply the applicable cash deposit rate.

Commerce will also instruct CBP to begin the suspension of liquidation and application of cash deposits for any unliquidated
entries not yet suspended, entered, or withdrawn from warehouse, for consumption, on or after the date of publication of the
notice of initiation of the circumvention inquiries pursuant to paragraphs (l)(2)(ii) and (l)(3)(ii). In addition, pursuant
to paragraphs (l)(2)(iii)(A) and (l)(3)(iii)(A), Commerce may instruct CBP to begin the suspension of liquidation and application
of cash deposits for any unliquidated entries not yet suspended, entered, or withdrawn from warehouse, for consumption, prior
to the date of initiation of the circumvention inquiries, but not for such entries prior to November 4, 2021, the effective
date of these provisions in the Final Rule. (11) These rules will not affect CBP's authority to take any additional action with respect to the suspension of liquidation or
related measures for these entries, as stated in 19 CFR 351.226(l)(5).

Notification to Interested Parties

In accordance with 19 CFR 351.226(d) and section 781(b) of the Act, Commerce determines that domestic interested parties'
request for a circumvention inquiry satisfies the requirements of 19 CFR 351.226(c). Accordingly, Commerce is notifying all
interested parties of the initiation of this circumvention inquiry to determine whether steel wheels finished in Vietnam using
HRS produced in China, and subsequently exported from Vietnam to the United States, are circumventing the Orders. In addition, we have included a description of the products that are the subject to this inquiry and an explanation of Commerce's
decision to initiate this inquiry as provided in the accompanying Initiation Checklist. (12) In accordance with 19 CFR 351.226(e)(1), Commerce intends to issue its preliminary circumvention determination no later than
150 days from the date of publication of the notice of initiation of this circumvention inquiry in the
Federal Register
. Furthermore, in accordance with section 781(f) of the Act and 19 CFR 351.226(e)(2), unless the circumvention inquiries are
rescinded, in whole or in part, or the deadline for the final circumvention deadlines is extended, Commerce intends to issue
its final determinations within 300 days from the date of publication of the notice of initiation of the circumvention inquiries
in the
Federal Register
.

This notice is published in accordance with section 781(b) of the Act, and 19 CFR 351.226(d)(1)(iii).

Dated: March 16, 2026. Christopher Abbott, Deputy Assistant Secretary for Policy and Negotiations, performing the non-exclusive functions and duties of the Assistant
Secretary for Enforcement and Compliance. [FR Doc. 2026-05443 Filed 3-18-26; 8:45 am] BILLING CODE 3510-DS-P

Footnotes

(1) See Certain Steel Wheels from the People's Republic of China: Antidumping and Countervailing Duty Orders, 84 FR 24098 (May 24, 2019) (Orders).

(2) See Domestic Interested Parties' Letter, “Request for Circumvention Ruling (Vietnam)” dated January 14, 2026 (Circumvention Inquiry
Request).

(3) See NCC Vietnam's Letter, “Comments on Accuride and Maxion Circumvention Inquiry Request,” dated January 26, 2026.

(4) See Domestic Interested Parties' Letter, “Response to Comments on the Adequacy of the Request for a Circumvention Inquiry,” dated
February 2, 2026.

(5) See Commerce's Letter, “Request for Circumvention Inquiry (Vietnam) Supplemental Questionnaire” dated February 9, 2026.

(6) See Domestic Interested Parties' Letter, “Response to Supplemental Questionnaire” dated February 12, 2026

(7) See Checklist, “Vietnam Assembly Circumvention Initiation Checklist,” dated concurrently with, and hereby adopted by, this notice
(Initiation Checklist).

(8) See Statement of Administrative Action Accompanying the Uruguay Round Agreements Act, H.R. Doc. 103-316, Vol. 1 (1994), at 893.

(9) See Uncovered Innerspring Units from the People's Republic of China: Final Affirmative Determination of Circumvention of the
Antidumping Duty Order,
83 FR 65626 (December 21, 2018), and accompanying Issues and Decision Memorandum at 4.

(10) See, e.g., Hydrofluorocarbon Blends from the People's Republic of China: Initiation of Circumvention Inquiry on the Antidumping
Duty Order,
88 FR 74150 (October 30, 2023); see also Hydrofluorocarbon Blends from the People's Republic of China: Initiation of Circumvention Inquiries on the Antidumping
Duty Order,
88 FR 43275 (July 7, 2023); Certain Corrosion-Resistant Steel Products from the Republic of Korea and Taiwan: Initiation of Anti-Circumvention Inquiries
on the Antidumping Duty and Countervailing Duty Orders,
83 FR 37785 (August 2, 2018); Carbon Steel Butt-Weld Pipe Fittings from the People's Republic of China: Initiation of Anti-Circumvention Inquiry on the
Antidumping Duty Order,
82 FR 40556, 40560 (August 25, 2017) (stating at initiation that Commerce would evaluate the extent to which a country-wide
finding applicable to all exports might be warranted); and Certain Corrosion-Resistant Steel Products from the People's Republic of China: Initiation of Anti-Circumvention Inquiries
on the Antidumping Duty and Countervailing Duty Orders,
81 FR 79454, 79458 (November 14, 2016) (stating at initiation that Commerce would evaluate the extent to which a country-wide
finding applicable to all exports might be warranted).

(11) See Regulations to Improve Administration and Enforcement of Antidumping and Countervailing Duty Laws, 86 FR 52300, 52345 (September 20, 2021) (Final Rule).

(12) See Initiation Checklist at 4, 6.

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CFR references

19 CFR 351.226

Named provisions

Scope of the Orders Merchandise Subject to the Circumvention Inquiry Initiation of Circumvention Inquiry

Classification

Agency
ITA
Filed
March 19th, 2026
Instrument
Enforcement
Legal weight
Binding
Stage
Final
Change scope
Substantive
Document ID
19 CFR 351.226(i) / Section 781(b) of the Tariff Act of 1930

Who this affects

Applies to
Importers and exporters
Industry sector
4231 Wholesale Trade
Activity scope
Import/Export of Steel Wheels Trade Enforcement
Geographic scope
United States US

Taxonomy

Primary area
International Trade
Operational domain
Compliance
Topics
Trade Enforcement Antidumping and Countervailing Duties

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