THE NUMBERS: PRELIMINARY DUTY RATES AT A GLANCE
Sources: U.S. Department of Commerce preliminary determinations; Wiley Rein LLP press releases, January 21 and February 26, 2026. Rates are preliminary and subject to change in final determinations. Combined rates represent the arithmetic sum of CVD and AD preliminary rates and do not reflect possible interactions or adjustments. Importers should verify current cash deposit rates and consult trade counsel. UNDERSTANDING THE TWO CASES: AD AND CVD EXPLAINED Antidumping and countervailing duty cases are distinct legal proceedings that address different forms of unfair trade, but they frequently travel together because the same conditions that generate government subsidies often also enable below-cost pricing. Antidumping duties address pricing behavior: specifically, sales of merchandise in the United States at prices below the exporter’s home-market price or below the cost of production. Commerce calculates a “dumping margin” for each investigated producer and applies that margin as a duty to bring the import price up to a fair level. The AD preliminary rates in this case are substantial. China’s country-wide rate of 187.27 percent reflects the extent to which Chinese producers — many of whom declined to cooperate fully with Commerce’s requests for data — are pricing product below any reasonable measure of cost. Vietnam’s country-wide AD rate of 196.14 percent is even higher, suggesting that Vietnamese producers are selling into the U.S. market at less than half of what fair pricing would require. Indonesia’s rates of 19.98 percent to 84.94 percent reflect a wider range of producer behavior. Countervailing duty investigations examine government behavior: the provision of financial benefits — loans at below-market rates, grants, subsidized raw materials, land use concessions, tax incentives — that give foreign manufacturers a cost advantage unavailable to unsubsidized competitors. Commerce’s January 16
CVD preliminary determinations found actionable subsidies in all three countries. China’s country-wide CVD rate of 81.34 percent reflects the extensive role of government-directed financing and input subsidies in the Chinese plywood industry. Indonesia’s wide range of 2.40 percent to 128.66 percent indicates significant variation between producers in their reliance on government support. Vietnam’s 4.37 percent to 26.75 percent range suggests a less pervasive subsidy regime but one that nonetheless provides meaningful competitive advantage. THE COALITION’S STRATEGY: WHY ALL THREE COUNTRIES SIMULTANEOUSLY Pursuing trade remedy cases against three countries at once is unusual and logistically demanding. It requires building parallel evidentiary records, tracking subsidy programs across multiple national regulatory environments, and sustaining the legal and administrative burden of simultaneous Commerce and ITC proceedings. The CFTHP’s decision to proceed on all three fronts at once reflects hard lessons learned from the 2018 China orders. When Commerce imposed AD/CVD orders on Chinese hardwood plywood in 2018, the predictable response was production and export diversion. Vietnamese imports of Chinese plywood cores surged almost immediately, and finished product entered the U.S. market under Vietnamese origin labels at prices that reflected China’s subsidized cost structure, not Vietnam’s. Commerce subsequently found circumvention of the China orders with respect to certain Vietnamese-processed CONTINUED ON PAGE 44 >
SURFACE & PANEL •SUMMER 2026
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