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Vietnam Nails: Details of CV Duty Order

The Commerce Department issued a countervailing duty order on steel nails from Vietnam (C-552-819) (here). The order details a "gap period" of no CV duty liability of March 3 - July 9.

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With the issuance of this order, CV duties on steel nails from Vietnam become permanent, and can only be ended under certain conditions, like a sunset review or a changed circumstances review. Commerce will now begin conducting annual administrative reviews on exporters, if requested, to determine final assessments of CV duties and make changes to CV duty cash deposit rates.

Gap Period of No CV Suspension of Liq or CV Duties for March 3 - July 9

For this investigation, the four-month provisional measures period for which the CV suspension of liquidation may remain in effect before the order is issued began on Nov. 3 (the publication date of the preliminary determination) and ended March 3, the date Commerce instructed CBP to terminate suspension of liquidation.

Because the International Trade Commission's final affirmative injury determination wasn't published until July 10, Commerce said all entries of subject merchandise between March 3 and July 9 (the gap period) are not liable for CV duty assessment.

(For entries from Nov; 3 through March 2, suspension of liquidation and CV duty liability remains in effect.)

CV Suspension of Liq Instructions

Suspension of liquidation resumes for all entries of subject merchandise from China with a time of entry on or after July 10, the publication date of the final ITC affirmative injury determination.

CV Cash Deposit Instructions

Commerce will instruct CBP to require, at the same time as importers deposit estimated duties, a cash deposit equal to the CV duty rates listed below:

CompanyCV Rate
Region Industries Co., Ltd.288.56%
United Nail Products Co., Ltd.313.97%
All Other Vietnamese Companies301.27%


ITC final injury determination (Federal Register 01/27/15) is available (here).

(See notice for additional details, including the full scope description, etc. See 1506240025 for summary of ITC vote on injury, and 1505190018 for summary of Commerce's final determination.)

(Federal Register 07/14/15)