On February 26, 2025, two U.S. chassis manufacturers representing the domestic industry – petitioners Cheetak Chassis Corporation and Stoughton Trailers, LLC – filed petitions with the Department of Commerce seeking the initiation of dumping and countervailing duty investigations into certain chassis and subassemblies imported from Mexico, Thailand, and Vietnam that are allegedly being or are likely to be sold at less than normal value and are being subsidized by the governments of those countries. The petitions allege these “unfairly traded imports have materially injured the U.S. domestic industry producing chassis and threaten to cause further material injury if relief is not granted.” The petitioners claim that they have been forced to compete with imports dumped at substantial margins: Mexico – 32.37%; Thailand – 234.06%; and Vietnam – 304.68%. Regarding countervailable subsidies, the petitioners claim that the governments of Mexico and Thailand provide support to their industrial chassis manufacturers that have allowed for expansion of their producers’ capacity, production and exports to the United States.

The physical characteristics of the covered products, which define the scope of the proposed investigations, are as follows:

The merchandise covered by these investigations consists of chassis and subassemblies thereof, whether finished or unfinished, whether assembled or unassembled, whether coated or uncoated, regardless of the number of axles, for carriage of containers, or other payloads (including self-supporting payloads) for road, marine roll-on/roll-off (RORO) and/or rail transport. Chassis are typically, but are not limited to, rectangular framed trailers with a suspension and axle system, wheels and tires, brakes, a lighting and electrical system, a coupling for towing behind a truck tractor, and a locking system or systems to secure the shipping container or containers to the chassis using twistlocks, slide pins or similar attachment devices to engage the corner fittings on the container or other payload.

These products are used in transportation of typically intermodal (e.g., ship, rail, truck) cargo containers in shipments from one location to another. Chassis may be imported into the United States in a fully assembled form or imported as subassemblies, with most or all of the integral items required to assemble a chassis into its finished form.

The Department of Commerce’s International Trade Administration (ITA) has 20 days to review and decide if the petitions meet all statutory requirements. If so, and the investigation is initiated, interested parties will have an opportunity to enter an appearance and file comments. 

Thompson Hine LLP’s International Trade practice group has attorneys and professionals who handle such trade remedy cases and who are available to provide further details on this action.

Photo of David M. Schwartz David M. Schwartz

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping…

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping (AD), countervailing duty (CVD) and safeguard litigation, international trade policy, and cross-border compliance issues affecting goods, services, technology and investments that involve transportation, customs, export controls, economic sanctions, anti-boycott and anti-bribery laws and regulations.

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Michelle Li Michelle Li

Michelle focuses her practice on assisting clients in a wide range of industries with trade remedy proceedings. Her experience includes representing clients before the U.S. Department of Commerce, U.S. International Trade Commission, U.S. Court of International Trade, and U.S. Court of Appeals for…

Michelle focuses her practice on assisting clients in a wide range of industries with trade remedy proceedings. Her experience includes representing clients before the U.S. Department of Commerce, U.S. International Trade Commission, U.S. Court of International Trade, and U.S. Court of Appeals for the Federal Circuit. She also advises on import entry clearance and other customs and importation issues involving food, drug, medical, and tobacco products regulated by the FDA and consumer products regulated by the U.S. Consumer Product Safety Commission.

Photo of Kerem Bilge Kerem Bilge

Kerem advises U.S. and foreign clients on a broad range of international trade and customs matters. He represents clients in antidumping and countervailing duty proceedings before U.S. government agencies and courts. Kerem also assists clients with import compliance, including identifying risks and developing…

Kerem advises U.S. and foreign clients on a broad range of international trade and customs matters. He represents clients in antidumping and countervailing duty proceedings before U.S. government agencies and courts. Kerem also assists clients with import compliance, including identifying risks and developing strategies to remain compliant with U.S. Customs and Border Protection requirements.