US Department of Commerce Final Affirmative LTFV Determination — Polypropylene Corrugated Boxes from Vietnam (FR doc 2026-10109)

Mechanism

The antidumping investigation was initiated in April 2025 following a petition by four US domestic polypropylene corrugated box manufacturers (CoolSeal USA Inc., Inteplast Group Corporation, SeaCa Plastic Packaging, and Technology Container Corporation), targeting imports classified under HTSUS subheading 3923.10.9000.

Commerce applied the Vietnam-wide entity treatment — treating all Vietnamese producers/exporters as a single entity — because no Vietnamese producer submitted a full questionnaire response qualifying for a separate rate. The agency then calculated the Vietnam-wide rate exclusively from Adverse Facts Available (AFA), arriving at 130.58%. The preliminary determination (31 December 2025) had set the preliminary AFA rate at 130.58%; the final determination maintains this rate unchanged.

The critical circumstances finding is significant: it means provisional measures (preliminary duties) apply retroactively to entries made 90 days before the publication of the preliminary determination (i.e., from approximately 2 October 2025). US importers that brought in polypropylene corrugated boxes from Vietnam on or after that date face retroactive duty exposure at the provisional rate.

The period of investigation (POI) ran from 1 July 2024 through 31 December 2024. Import volumes under HTSUS 3923.10.9000 from Vietnam grew from USD 16.1 million in 2022 to a pace implying USD 11.1 million for calendar 2024 at lower unit values — the unit-value decline (from ~USD 5.50/kg in 2022–23 to ~USD 2.42/kg in 2024) was central to Commerce's dumping analysis.

A parallel ITC final injury investigation must conclude within 45 days. If the ITC makes an affirmative final injury determination, Commerce will issue an antidumping duty order; AD duties will be deposited on all future entries of subject merchandise.

A parallel China-origin polypropylene corrugated boxes investigation (both LTFV and CVD) was conducted concurrently; the China final determinations are a separate set of Federal Register documents.

Downstream implications

• Retroactive duty exposure for US importers sourcing polypropylene corrugated boxes from Vietnamese converters since October 2025; supply-chain risk for major US retail/e-commerce and FMCG packagers that shifted to Vietnamese-origin corrugated containers after the initial China AD cases.
• Vietnam-as-transshipment check: the AFA Vietnam-wide rate (130.58%) reflects Commerce's concern that no Vietnamese producer was able to demonstrate arm's-length independence from Chinese input pricing — consistent with the broader US enforcement posture that Vietnamese polypropylene converters are embedded in Chinese-controlled resin/masterbatch supply chains.
• Signals Commerce's AFA application cadence against Vietnam: this is the first Commerce AD final determination against Vietnam on the register. The 130.58% AFA rate sets a precedent for future non-cooperating Vietnamese respondents in AD/CVD proceedings.
• ITC injury determination (within 45 days of 20 May 2026) is the next gate: if affirmative, an AD order takes effect; if negative, the investigation terminates without an order.

Open questions

• Will the ITC make an affirmative or negative final injury determination?
• Does the parallel China LTFV/CVD final determination impose a combined AD+CVD rate that structurally forecloses both Chinese and Vietnamese supply?
• Will any Vietnamese producers submit voluntary responses seeking separate-rate treatment in any subsequent administrative review once an order is in place?