UPDATE ON ANTI-CIRCUMVENTION MEASURES FOR HOT-ROLLED COIL (HRC) IMPORTS

UPDATE ON ANTI-CIRCUMVENTION MEASURES FOR HOT-ROLLED COIL (HRC) IMPORTS

The Customs authority has issued new guidance for implementing Decision 612/QD-BCT on temporary anti-circumvention trade remedies for Hot-Rolled Coil (HRC) products. Importers should pay close attention to the following requirements to ensure compliance and avoid unexpected tax exposure.

1. Scope of Application

The measure applies to HRC products with the following criteria:

  • Origin: China
  • HS Codes: 7208.25.00, 7208.26.00, 7208.27.19, 7208.27.99, 7208.36.00 and groups 7211, 7225, 7226
  • Width: > 1,880 mm to ≤ 2,300 mm

2. Anti-Dumping Duty (ADD) Declaration Guidance

Case 1 – DUTY APPLIED:
Applicable when no C/O is provided or the C/O indicates China origin.

  • Declaration code: G217
  • Temporary ADD rate: 27.83%

Case 2 – EXEMPTION:
Applicable when valid proof of origin from countries/territories other than China is provided.

  • Declare at field 1.95 in the import declaration
  • Use exemption code: GK

3. Important Notes on Enforcement

  • Strict inspection and tax collection will be conducted in accordance with:
    • Circular 38/2015/TT-BTC
    • Circular 39/2018/TT-BTC
    • Circular 121/2025/TT-BTC
  • HRC products with width ≤ 1,880 mm remain subject to Decision 1959/QD-BCT

Important:
Importers must carefully verify product specifications and origin documentation to avoid high tax exposure and compliance risks.

4. Recommendations for Businesses

  • Verify product origin before import
  • Prepare valid and complete C/O documentation
  • Ensure correct customs declaration codes
  • Work closely with logistics and customs partners

Conclusion

The anti-circumvention measures on HRC imports will significantly impact import costs. Proper preparation and compliance will help businesses mitigate risks and maintain efficient supply chain operations.

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