Rigorous Scrutiny Uncovers Computational Lapses

On May 29, 2025, the U.S. Department of Commerce announced an amended preliminary determination in its ongoing investigation into whether certain corrosion-resistant steel products from Vietnam were sold in the U.S. at less than fair value. The revision followed the identification of multiple significant ministerial errors, primarily arithmetic and clerical mistakes, in the original calculations published in April 2024. These errors, flagged by petitioners and respondents alike, significantly distorted the initially reported dumping margins.

Commerce’s preliminary ruling had already concluded that CORE products from Vietnam were being dumped in the U.S. market, adversely affecting domestic steel manufacturers. However, stakeholders including Hoa Sen Group, Ton Dong A Corporation, the Government of Vietnam, and Maruichi Sun Steel Trading Company contested the integrity of the calculations, triggering a review under U.S. trade law.

Legal Standards for Correcting Significant Errors

According to U.S. trade regulations (19 CFR 351.224), a ministerial error includes miscalculations in arithmetic, inaccurate data entry, or other clerical oversights. An error becomes "significant" when its correction alters the weighted-average dumping margin by at least five absolute percentage points and not less than 25% of the margin itself, or causes the margin to shift from de minimis (less than 2%) to above the legal threshold or vice versa.

Commerce determined that the preliminary margins for at least two major producers, Hoa Sen Group and Ton Dong A, had been substantially impacted by such errors. Upon reevaluation, new figures were calculated and formally published in the Federal Register.

Revised Dumping Margins Reflect Sharper Penalties

As a result of the corrections, the Department issued new weighted-average dumping margins. Hoa Sen Group and its affiliated companies are now facing a dumping margin of 132.10%, one of the highest among named companies. Ton Dong A Corporation’s margin was lowered to 51.64%, still representing a substantial punitive measure.

Other exporters, including China Steel and Nippon Steel Vietnam Joint Stock Company, Hoa Phat Steel Sheet Limited Liability Company, and Maruichi Sun Steel Joint Stock Company, were all assigned a revised margin of 91.87%. The Vietnam-Wide Entity, which includes all producers and exporters not specifically investigated or granted a separate rate, was hit hardest with a 178.89% margin and a 136.57% cash deposit requirement—both based on adverse facts available, suggesting a lack of full cooperation.

Key Takeaways

• The U.S. Department of Commerce amended its CORE antidumping margins for Vietnamese steel exporters after identifying significant ministerial errors.

• Revised dumping margins include 132.10% for Hoa Sen Group, 51.64% for Ton Dong A, and up to 178.89% for the Vietnam-wide entity.

• These amendments may significantly impact Vietnam-U.S. steel trade flows, raising compliance costs and influencing broader economic relations.