China's Aluminum Sneak Attack via Vietnam Faces U.S. Duties
Published Date: 4/20/2026
Notice
Summary
The U.S. Department of Commerce found that aluminum containers made in Vietnam using Chinese aluminum foil are trying to dodge extra taxes meant for Chinese imports. This means these products might soon face the same duties as those from China, affecting importers and sellers starting April 20, 2026. If confirmed, this will help protect U.S. businesses from unfair pricing tricks.
Analyzed Economic Effects
6 provisions identified: 1 benefits, 4 costs, 1 mixed.
Vietnam-Made China-Foil Goods Now In Scope
Commerce preliminarily found on a country-wide basis that disposable aluminum containers completed in Vietnam using aluminum foil produced in the People's Republic of China are circumventing U.S. antidumping and countervailing duty orders on China. As of the notice applicable April 20, 2026, Commerce preliminarily includes that merchandise within the scope of the China Orders.
Suspension of Liquidation, Huge Cash Deposits
Commerce will direct U.S. Customs and Border Protection to suspend liquidation and require cash deposits on unliquidated entries of the inquiry merchandise that were entered, or withdrawn from warehouse, for consumption on or after October 28, 2024. Where certifications are not met, Commerce intends to require cash deposits at the China-wide AD cash deposit rate of 287.80 percent and the CVD all-others cash deposit rate of 317.85 percent (company-specific rates apply if applicable).
Importer/Exporter Certification Paperwork Rules
Importers and exporters must complete and keep certifications attesting that specific entries of Vietnam-completed aluminum containers were not produced using Chinese-origin aluminum foil, and must upload the importer certification, exporter certification, commercial invoice, bill of lading, and the aluminum mill certificate (identifying country of smelt and cast) into the Document Imaging System (DIS) in ACE at time of entry. Supporting documentation must be retained until the later of five years after the latest entry date or three years after the conclusion of any related U.S. litigation; for unliquidated entries from October 28, 2024 through May 6, 2026, certifications and uploads must be completed no later than June 5, 2026 (entries after May 7, 2026 require certification by the entry summary date).
Convert Non-AD Entries and Pay Deposits
For unliquidated entries of aluminum containers entered as non-AD/CVD type entries (for example, type 01) during October 28, 2024 through May 6, 2026 for which certifications cannot be made, importers must file a Post Summary Correction with CBP to convert those entries to AD/CVD type (for example, to type 03) and pay the required cash deposits consistent with the regulations governing post summary corrections.
Non-China-Foil Vietnam Goods Exempted
Aluminum containers completed in Vietnam using aluminum foil that is not of Chinese origin are not subject to this circumvention inquiry and therefore do not require cash deposits under the China Orders. If you can certify and document non-China origin of the aluminum input, your entries should avoid the suspension and deposit requirements tied to China-origin foil.
Company-Specific Rates May Replace China-Wide Rates
Where companies already have company-specific antidumping or countervailing duty rates under the China Orders, Commerce will use those company-specific cash deposit rates for entries instead of the China-wide AD rate (287.80%) or the CVD all-others rate (317.85%).
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Key Dates
Department and Agencies
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