AgrifoodV ·
The US Department of Commerce has published the final results of the 2023–2024 administrative review of the anti-dumping duty order on frozen pangasius (tra and basa) fillets from Vietnam: the rates for the four companies that were individually examined or granted a separate rate range from USD 0.38 to 1.00/kg, while the Vietnam-wide rate stays at USD 2.39/kg. Since then, a ruling by the US Court of International Trade has forced a revision of the 2021–2022 rate, and the 2025–2026 review has been initiated with 148 companies on the list.
Key points
- The anti-dumping duty order on pangasius fillets from Vietnam (case number A-552-801, issued 12 August 2003) has been continued for another five-year period, effective 24 June 2026.
- Review period 1 August 2023–31 July 2024 (Federal Register, 13 August 2026): two mandatory respondents at USD 1.00 and 0.38/kg; two non-selected companies with separate rates at USD 0.84/kg; the Vietnam-wide rate of USD 2.39/kg is unchanged.
- The US Court of International Trade (CIT) issued its final judgment on 4 September 2026; the 2021–2022 rate rose from USD 0.18 to 0.20/kg for five companies.
- The review for 1 August 2025–31 July 2026 was initiated on 1 October 2026; Commerce intends to issue final results no later than 31 August 2027.
The order remains in force after the fourth sunset review
The anti-dumping duty order on frozen fish fillets from Vietnam was published on 12 August 2003. In December 2025, the US Department of Commerce (Commerce) and the US International Trade Commission (ITC) opened the fourth five-year (sunset) review. Commerce found that revoking the order would likely lead to a continuation or recurrence of dumping; on 24 June 2026 the ITC published its determination that revocation would likely lead to material injury to the US industry. A notice dated 29 June 2026 confirmed that the order is continued, effective 24 June 2026. The next sunset review will be initiated no later than 30 days before the fifth anniversary of the ITC determination.
The order covers frozen fillets of three species, Pangasius bocourti, Pangasius hypophthalmus (also known as Pangasius pangasius) and Pangasius micronemus: regular fillets with or without the belly flap, and fillets cut into strips, chunks, blocks, skewers or any other shape, whether or not breaded or marinated. Excluded from the scope are frozen whole fish (including dressed fish), bone-in steaks and belly-flap nuggets. The goods are classifiable under HTSUS subheading 0304.62.0020 and may enter under 0305.59.0000 and several subheadings of 1604.19; however, the notice states that the written description, not the tariff number, is dispositive.
Results of the 2023–2024 review
The Federal Register notice of 13 August 2026 sets the dumping margins for the period 1 August 2023–31 July 2024. Commerce rescinded the review for 25 companies and for the Vietnam-wide entity because the review requests were withdrawn or no party with standing had requested a review.
| Company group | Rate (USD/kg) | Note |
|---|---|---|
| First mandatory respondent | 1.00 | Individually calculated |
| Second mandatory respondent | 0.38 | Individually calculated |
| Two separate-rate companies not selected for examination | 0.84 | Weighted average of the two respondents |
| Vietnam-wide entity (companies that did not demonstrate separate-rate eligibility) | 2.39 | Unchanged, not reviewed in this period |
Source: US Department of Commerce, Federal Register 91 FR 52286 (13 August 2026). Individual company names are listed in the original notice.
The new cash deposit rates apply to goods entered, or withdrawn from warehouse, for consumption in the US on or after 13 August 2026. Vietnamese exporters that have not been granted a separate rate are subject to the Vietnam-wide rate of USD 2.39/kg. Commerce said it would issue assessment instructions to US Customs and Border Protection (CBP) no earlier than 35 days after publication of the notice.
The court ruling on the 2021–2022 review
The Catfish Farmers of America, together with several US catfish processors, challenged the results of the review covering 1 August 2021–31 July 2022 (Catfish Farmers of America et al. v. United States, Court No. 24-00082). The dispute concerned the treatment of marine insurance in the margin calculation: Commerce had rejected the ministerial error allegation as untimely, but in December 2025 the court directed Commerce to accept it and recalculate. On 4 September 2026, the court issued its final judgment sustaining the recalculation.
According to the notice of 22 September 2026 (applicable from 14 September 2026), the rate for that period’s mandatory respondent rose from USD 0.18 to 0.20/kg and was applied to four separate-rate companies. The four companies whose rates have not been superseded by a later review will make cash deposits at USD 0.20/kg. Entries from the 2021–2022 period remain unliquidated while appeals are still possible.
The 2025–2026 review is under way
The initiation notice of 1 October 2026 includes Vietnamese pangasius fillets in the batch of orders with August anniversary dates, covering 1 August 2025–31 July 2026, with a list of 148 companies for which a review was requested. The case uses the separate-rate mechanism that the US applies to countries it treats as non-market economies, so companies wishing to keep their own rate had to file a separate rate certification or application within 14 calendar days of publication, a deadline that passed in mid-October 2026. Commerce intends to issue the final results no later than 31 August 2027.
What companies should do
The following are recommendations from AgrifoodV, not content of the notices cited above.
- Check the cash deposit rate that applies to your own company against the legal name and the alternative names listed in the notices; a name mismatch or a change in ownership structure can result in shipments being charged the Vietnam-wide rate of USD 2.39/kg.
- Set up a calendar for the procedural milestones of the 2025–2026 review: comments on respondent selection data, questionnaires if issued, and deadlines for factual information and comments. Deadlines are counted only in calendar days after Federal Register publication.
- State clearly in contracts with importers which party bears the difference when the final duty differs from the cash deposit, since liquidation can take several years when litigation is involved.
- When developing new pangasius products for the US market, determine early whether the product falls within the written scope of the order, rather than relying on the HS code.
Companies that need an assessment of the US market and alternative markets for their pangasius product lines can refer to AgrifoodV’s market advisory services.
References
- US Department of Commerce (ITA), “Certain Frozen Fish Fillets From the Socialist Republic of Vietnam: Final Results and Rescission, in Part, of Antidumping Duty Administrative Review; 2023-2024”, 91 FR 52286, FR Doc. 2026-16553, 13 August 2026. federalregister.gov/d/2026-16553 (accessed 3 November 2026).
- US Department of Commerce (ITA), “Certain Frozen Fish Fillets From the Socialist Republic of Vietnam: Notice of Court Decision Not in Harmony With the Final Results of Antidumping Administrative Review; and Notice of Amended Final Results”, 91 FR 60099, FR Doc. 2026-19373, 22 September 2026. federalregister.gov/d/2026-19373 (accessed 3 November 2026).
- US Department of Commerce (ITA), “Certain Frozen Fish Fillets from the Socialist Republic of Vietnam: Continuation of Antidumping Duty Order”, 91 FR 39070, FR Doc. 2026-13037, 29 June 2026. federalregister.gov/d/2026-13037 (accessed 3 November 2026).
- US Department of Commerce (ITA), “Initiation of Antidumping and Countervailing Duty Administrative Reviews”, 91 FR 62477, FR Doc. 2026-20160, 1 October 2026. federalregister.gov/d/2026-20160 (accessed 3 November 2026).
Article by AgrifoodV, compiled from the sources above (accessed 3 November 2026). This content is not a substitute for legal advice.
Cover image: Kampus Production / Pexels
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