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Scope of the measure

The product covered by the Orders is hardwood and decorative plywood from China. For a complete description of the scope of the orders, see Appendix. Merchandise Subject to the Anti-Circumvention Inquiries These anti-circumvention inquiries cover plywood completed in Vietnam using plywood components (face veneer, back veneer, and/or either an assembled core or individual core veneers) manufactured in China, or Chinese components (assembled cores, multi-ply core panels, or individual core veneers) combined in Vietnam with other components (face and/or back veneers) manufactured in Vietnam or third countries, and subsequently exported to the United States. Specifically, these inquiries will cover plywood completed in Vietnam using: (1) Face veneer, back veneer, and assembled core components manufactured in China; and (2) face veneer, back veneer, and individual core veneers produced in China. Additionally, these inquiries will also examine, should such production scenarios exist, plywood completed in Vietnam using: (1) Fully assembled veneer core platforms manufactured in China and face and/or back veneers produced in Vietnam or third countries; (2) multi-ply panels of glued core veneers manufactured in China that are combined in Vietnam to produce veneer core platforms and combined with either a face and/or back veneer produced in China, Vietnam, or a third country; and (3) core veneers manufactured in China and processed into a veneer core platform in Vietnam and combined with a face and/ or back veneer produced in Vietnam or other third country. A veneer core platform is defined as two or more wood veneers that form the core of an otherwise completed hardwood plywood product (i.e., a hardwood plywood product to which the outer (face and back) veneers have not yet been affixed (see Petitioner's Request at Exhibit 11). Initiation of Anti-Circumvention Inquiry Proceedings Section 781(b) of the Act and 19 CFR 351.225(h) provide that Commerce may find circumvention of an AD or CVD order when merchandise of the same class or kind subject to the order is completed or assembled in another foreign country before being exported to the United States. In conducting anti-circumvention inquiries under section 781(b)(1) of the Act, Commerce relies upon the following criteria: (A) Merchandise imported into the United States is of the same class or kind as merchandise produced in a foreign country that is the subject of an AD or CVD order or finding; (B) before importation into the United States, such imported merchandise is completed or assembled in another foreign country from merchandise which is produced in the foreign country that is subject to the order; (C) the process of assembly or completion in another foreign country is minor or insignificant; (D) the value of the merchandise produced in the foreign country to which the AD or CVD order applies is a significant portion of the total value of the merchandise exported to the United States; and (E) Commerce determines that action is appropriate to prevent evasion of such order or finding. As discussed below, the petitioner provides evidence with respect to these criteria. A. Merchandise of the Same Class or Kind The petitioner states that, pursuant to section 781(b)(1)(A) of the Act, the inquiry merchandise being completed in Vietnam and imported into the United States is of the same class or kind as the merchandise subject to the Orders. The petitioner further argues that the products being completed in Vietnam are identical to the subject merchandise produced in China and are entering the United States under the same Harmonized Tariff Schedule subheadings as subject plywood from China. See Petitioner's Request at 33-34. Id. According to the petitioner, the main components of plywood include face and back veneers, and/or either an assembled core or individual core veneers. B. Completion of Merchandise in Another Foreign Country The petitioner contends that section 781(b)(1)(B)(ii) of the Act covers the completion of plywood in Vietnam, because the main components in the production of plywood are manufactured in China, the country to which the Orders apply. The petitioner also asserts that fully- or partially-assembled cores, or individual core veneers, produced in China that are combined in Vietnam with face and/or back veneers produced in Vietnam or a third country should be covered by the Orders; according to the petitioner, the vast majority of the cost of the finished plywood, in terms of materials, labor, and investment, is related to the production of the Chinese components (including core veneers in particular). Id. at 34-35. See Petitioner's Clarification at 2-6.

Scope text quoted verbatim from the Federal Register notice. Scope text retrieved: 2026-10-19T16:17:45Z. Record last fetched: 2026-10-16T16:08:03Z. Verify against the official notice before relying on it.

HTS codes covered by this order

The scope text also references HS prefix(es) 441232, 441294, 940390 that we do not yet resolve against our USITC HTS reference table; they are shown verbatim instead of being guessed.

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