196.14% Anti-Dumping Margin on Vietnamese Plywood: Key Compliance Lessons for Wood Product Exporters

On February 24, 2026, the U.S. Department of Commerce (DOC) announced its preliminary determination in the anti-dumping duty (AD) investigation on hardwood plywood from Vietnam: a dumping margin of 196.14%.

If this preliminary finding is confirmed, it will affect all Vietnamese manufacturers exporting these products to the United States — and could also reshape global supply chain strategies for composite wood products.

For wood product manufacturers worldwide — regardless of where your production base is located — the verification logic applied by the DOC in this investigation signals the future focus of international trade compliance.

ICTT summarizes the key takeaways for your strategic reference.

1. Preliminary Determination at a Glance

What does NME treatment mean?Vietnamese production costs are not valued at actual expenses. Instead, they are valued using surrogate prices from Indonesia for similar factors of production (e.g., logs, glue, labor, energy).

Good news for existing shipments:The DOC found no “critical circumstances” because import growth during the comparison period did not exceed the 15% “surge” threshold. Therefore, no retroactive duty collection — a阶段性 relief for manufacturers that have already shipped.

2. Separate Rate Status – 52 Companies Qualified

In NME investigations, the DOC maintains a rebuttable presumption that all enterprises are subject to government control and should receive a single, country‑wide duty rate.

To obtain a separate rate, a company must demonstrate — both in law and in fact — the absence of government control.

In this investigation, 52 Vietnamese companies successfully proved:

• Operational autonomy – Independent export price setting, contract signing

• Management autonomy – Independent selection of management, profit disposition

One company (Kim Tin) failed to respond to supplemental questionnaires and was deemed part of the Vietnam‑wide entity, thus not entitled to a separate rate.

3. Key Verification Challenges Highlighted by the DOC

Focus 1: Closed‑loop Consistency Between Production Records & Financial Accounts

In the preliminary determination, the DOC applied “facts available” (adverse inferences) to one mandatory respondent. The core reason: the company’s audited financial statements revealed significant limitations in its inventory control system and stock management.

From a manufacturing compliance perspective, this exposes two critical gaps:

Consequence: When underlying management records are deemed “unreliable” or “unverifiable,” the DOC will disregard actual costs and substitute highly adverse surrogate data.

Focus 2: Verifiability of Material Consumption Rates (FOP)

The dispute for another respondent centered on Factors of Production (FOP) data. The DOC noted that the company’s reported raw material consumption rates lacked logical support and sufficient evidentiary backing.

For plywood and composite wood products, material consumption rates — such as log yield, veneer waste, glue formulation — are at the heart of cost accounting. International verifiers typically focus on:

• Standards management – Are actual consumption rates within reasonable process ranges?

• Dynamic records – Do daily production requisitions and scrap tickets form a complete data chain supporting reported costs?

4. Final Determination Postponed

At the request of the two mandatory respondents, the DOC has postponed the final determination to no later than July 2026 (135‑day extension). Consequently, provisional measures (cash deposit requirements) are extended for up to six months.

5. How Manufacturers Can Reduce Trade Risk

Based on the verification findings in this case, ICTT recommends that wood product exporters — whether in Vietnam, China, or other sourcing origins — take the following actions:

1. Strengthen the logical chain of original records

Ensure that every document — from purchase contracts, incoming inspection, production requisitions, work‑in‑progress transfers, to finished goods入库 — maintains temporal, spatial, and logical consistency.

2. Increase inventory management transparency

Implement a system that tracks material movement in real time, minimizing “gray areas” between book inventory and physical stock.

3. Objectively assess process waste and yield

Establish scientific consumption standards for logs, veneer, adhesives, and other inputs. Avoid relying on “experience‑based” estimates — document actual consumption.

4. Maintain ownership transparency

As the DOC continues to scrutinize government shareholding, clearly document the independence of pricing, management, and profit decisions.

5. Prepare for post‑shipment verification

Even if your company is not a mandatory respondent in a given investigation, you may be subject to verifications later. Keep all production and financial records for at least 3‑5 years.

Why This Case Matters Beyond Vietnam

The U.S. DOC’s logic in the Vietnamese plywood investigation — especially regarding production record integrity and material consumption verifiability — will likely be applied to future trade remedy investigations involving other countries and other wood products (engineered wood, flooring, veneer, etc.).

For composite wood product manufacturers serving the U.S. market, the message is clear:

How ICTT Can Help

As a specialized third‑party testing, inspection, and certification service provider, ICTT helps wood product and building material manufacturers navigate international trade compliance, including:

• Supply chain traceability audits

• Production record & inventory control review

• Preparation for anti‑dumping / countervailing duty verifications

• Cost documentation and material consumption analysis

We monitor global trade policy developments — from AD/CVD cases to environmental regulations — and provide actionable insights to protect your market access.

Disclaimer: This article is based on the U.S. Department of Commerce’s preliminary determination memorandum issued on February 24, 2026, for informational purposes only and does not constitute legal advice. Exporters should consult qualified trade counsel for binding guidance.

References: U.S. DOC – Preliminary Determination in AD Investigation on Hardwood Plywood from Vietnam (Feb 24, 2026); Federal Register notices.