U.S. Initiates Circumvention Inquiries on Steel Wire Garment Hangers Involving Cambodia

Estimated reading time: 5 minutes

Background on the Case

The U.S. Department of Commerce announced the start of new circumvention inquiries. These focus on steel wire garment hangers. The concern is that hangers made in Cambodia, using Chinese or Vietnamese materials, may be avoiding trade duties.

M&B Metal Products Co., Inc., a U.S. company, asked Commerce to investigate. They said that steel wire or steel wire with paper parts from China or Vietnam are being sent to Cambodia. In Cambodia, the wire is used to make hangers. The hangers are then shipped to the United States.

This may be a way to avoid paying antidumping and countervailing duties placed on hangers from China and Vietnam.

Orders in Place

There are already orders to stop dumping and unfair support of steel wire garment hangers from:

  • People’s Republic of China (China)
  • Socialist Republic of Vietnam (Vietnam)

These orders help protect American companies from unfairly cheap imports.

What Is Being Investigated

The investigation covers hangers made in Cambodia from:

  • Steel wire
  • Steel wire and paper accessories

The materials are made in China or Vietnam and then shipped to the U.S. from Cambodia.

Reason for the Inquiry

Under U.S. law, Commerce looks at these cases if:

  • The final product shipped to the U.S. is similar to what is already covered by orders.
  • Parts or pieces come from a country subject to an order, but assembly is done in a different country.
  • The assembly or finishing in the new country is minor.
  • The value of the parts from the original country is a big part of the final product’s value.
  • Taking action is needed to stop people from getting around (circumventing) the trade orders.

Factors Studied

Commerce will study details about assembly in Cambodia, including:

  • Investment in factories in Cambodia
  • Level of research and development there
  • Nature of the production process
  • Size and extent of production facilities
  • How much value is added by Cambodia compared to the whole product

They will also look at:

  • Trade patterns (where parts and finished goods are coming from or going)
  • Company relationships across countries
  • Increases in imports to Cambodia since U.S. orders began

What Happens Next

Commerce will:

  • Use U.S. Customs and Border Protection (CBP) data to find which exporters to ask for information.
  • Send questions to the largest producers and exporters in Cambodia.
  • Review trade and company data to decide if duties should be applied.

If companies do not answer questions fully, Commerce may use facts that go against those companies.

What Could Change

If Commerce finds that hangers from Cambodia are really just made from Chinese or Vietnamese parts and are meant to avoid duties, it can:

  • Order customs to collect cash deposits for these products
  • Continue or start “suspension of liquidation” (holding off on final duty assessments) on suspected products
  • Apply duties on entries made after the date of this notice (August 12, 2025)

Timeline

Commerce plans to:

  • Make preliminary decisions within 150 days of August 12, 2025
  • Make final decisions within 300 days

Contact Information

For questions, contact Samuel Frost at the U.S. Department of Commerce, 202-482-8180.

This notice was dated August 6, 2025 and signed by Abdelali Elouaradia, Deputy Assistant Secretary for Enforcement and Compliance.


Legal Disclaimer

This article includes content collected from the Federal Register (federalregister.gov). The content is not an official government publication. This article is for informational purposes only and does not constitute legal advice. For case-specific consultation, please contact us. Read our full Legal Disclaimer, which also includes information on translation accuracy.