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.