CUSTOMS ENFORCEMENT | 2026-09-23

Hangers Assembled in Cambodia From Chinese and Vietnamese Wire Are Circumventing the Orders — and the Duties Reach Back to August 2025

A section 781(b) third-country determination suspends entries made on or after August 12, 2025 and collects cash deposits at the Vietnam rates: 220.68 percent antidumping and 31.58 percent countervailing.

On September 22, 2026 the U.S. Department of Commerce published a preliminary affirmative determination that steel wire garment hangers completed in Cambodia, using steel wire — or steel wire and paper accessories — produced in China or Vietnam, are circumventing the antidumping duty order on hangers from China and the antidumping and countervailing duty orders on hangers from Vietnam. The determination is country-wide. Commerce will direct CBP to suspend liquidation and collect cash deposits on

On September 22, 2026 the U.S. Department of Commerce published a preliminary affirmative determination of circumvention concerning steel wire garment hangers, in cases A-570-918, A-552-812 and C-552-813. Commerce preliminarily determines that hangers completed in Cambodia using (1) steel wire or (2) steel wire and paper accessories produced in China or Vietnam are circumventing the existing orders, on a country-wide basis, and should be brought inside their scope.

For California apparel importers — and for the retailers and distributors whose goods arrive on hangers rather than in cartons — this determination is worth close attention, because the exposure it creates is already more than a year old.

A different circumvention theory than the one in the brake drums case

Commerce is acting here under section 781(b) of the Tariff Act of 1930, which addresses merchandise completed or assembled in a third country from inputs produced in a country subject to an order. That is a distinct theory from section 781(d), the later-developed-merchandise provision Commerce applied to compacted graphite iron brake drums from China one day earlier.

The distinction is worth holding onto, because the two describe the two most common commercial responses to an order. Section 781(d) reaches a change in the product. Section 781(b) reaches a change in the route. An importer that responded to the China and Vietnam hanger orders by sourcing finished hangers from a Cambodian assembler, while the wire itself continued to come from China or Vietnam, is exactly the fact pattern 781(b) exists for.

How the orders and the inquiry line up

Commerce published the antidumping duty order on hangers from China on October 6, 2008, at 73 FR 58111. The Vietnam orders followed on February 5, 2013 — the antidumping order at 78 FR 8105 and the countervailing duty order at 78 FR 8107.

On August 12, 2025, Commerce initiated country-wide circumvention inquiries under section 781(b), published at 90 FR 38723. On December 31, 2025 it identified Alpha Hanger (Cambodia) Co., Ltd as the sole mandatory respondent in the inquiries.

Thirteen months of retroactive exposure

Under 19 CFR 351.226(l)(2), Commerce will direct CBP to suspend liquidation and require cash deposits of estimated antidumping or countervailing duties on unliquidated entries of the inquiry merchandise entered, or withdrawn from warehouse, for consumption on or after August 12, 2025 — the publication date of the initiation notice.

That is the single most important sentence in the determination. The reach-back runs to the initiation date, not to the determination date, and here those are thirteen months apart. An importer that brought hangers in from Cambodia through the autumn of 2025 and across all of 2026, cleared entry without incident, and sold the garments long ago is now looking at entries that will be suspended and assessed.

This is the recurring misunderstanding in circumvention practice. Importers assume the rule changes on the day Commerce announces it. It does not. The initiation notice is the marker, and it is public when it publishes — which is precisely why monitoring initiation notices in your product area is a compliance function, not a legal nicety.

The rates: Vietnam's, not China's

Where the orders of two countries could both apply to a single entry, Commerce states that it intends to instruct CBP to suspend the entry and collect cash deposits at the rates applicable to the Vietnam orders — that is, the antidumping cash deposit rate established for the Vietnam-wide entity, 220.68 percent, and the countervailing duty cash deposit rate established for all other companies, 31.58 percent.

Those deposits are collected under third-country case numbers A-555-812 for the Vietnam antidumping side and C-555-813 for the Vietnam countervailing side.

Commerce describes this as consistent with its recent determinations, citing its approach in the light-walled rectangular pipe and tube proceeding from Korea, where it suspended entries and collected at the highest available rate for merchandise found to be circumventing multiple orders. The practical consequence: where the record cannot establish which of two subject countries supplied the input, the importer pays at the higher exposure until it can.

Combined, an importer without a company-specific rate faces deposits exceeding 250 percent of entered value on hangers that were sourced precisely to avoid those orders.

The certification program, and what it does and does not allow

Commerce is establishing a certification program, but it is narrower than importers will hope.

Commerce preliminarily finds that no exporter of hangers from Cambodia is eligible to certify that its hangers were produced using steel wire, or steel wire and paper accessories, sourced from a country other than China or Vietnam. In other words, the "our wire came from somewhere else entirely" certification is not available at this stage.

What is available — to parties other than those to which Commerce applied adverse facts available — is a certification that the entries were produced using Chinese rather than Vietnamese steel wire or accessories. To certify away from the Vietnam orders, the importer and exporter must provide documentation to CBP at the time of entry supporting the claim that the inputs were sourced from China.

Commerce adds that if it later determines — for example in a certification review — that a party has demonstrated it should be allowed to certify that the origin of the wire is neither Chinese nor Vietnamese, it intends to release certification language and establish such a program at that time.

Two things follow for importers. First, a certification is a documented factual claim made to CBP at entry, with the evidentiary and penalty consequences that attach to any such claim — it is not a box to tick. Second, the only currently available certification moves an entry from the Vietnam rates to the China rates; it does not remove it from the orders.

What California apparel importers should do now

First, determine where your hangers were assembled and, separately, where the wire came from. Those are different questions with different answers, and the second is the one that governs. A Cambodian commercial invoice tells you about assembly, not about input origin.

Second, identify unliquidated entries back to August 12, 2025. Those are the entries suspension reaches.

Third, ask your supplier for mill documentation on the wire, and be realistic about whether it exists. If you intend to certify Chinese input origin, the documentation has to satisfy CBP at entry, not satisfy you in retrospect.

Fourth, treat this as a country of origin and substantial transformation question at its core. Assembly in a third country does not confer origin for trade remedy purposes simply because it changed the article's appearance, and a supplier's assurance about origin is not a substitute for the analysis.

Fifth, check bond sufficiency before CBP does. Deposits above 250 percent of entered value change continuous bond arithmetic quickly, and an insufficient bond becomes its own enforcement problem independent of the duties.

Sixth, if entries are already suspended, get advice before filing anything that certifies facts to CBP. Importers who have worked through a CF-28 request for information or CF-29 notice of action know that the moment documentation becomes a representation to the agency is the moment the stakes change.

Where this stands

This is a preliminary determination, and interested parties are invited to comment. Commerce may revise its analysis in the final determination. But suspension of liquidation and the cash deposit requirement operate now, and they apply to entries made over the last thirteen months.

Importers moving apparel through the Long Beach and Los Angeles complex should be running the input-origin question this week rather than after a CBP notice arrives. Trembach Law Firm advises importers on circumvention and scope inquiries, certification obligations and the CBP enforcement that follows them. Call (818) 514-7680 or request a consultation.

Frequently Asked Questions

How far back do the duties reach?

Under 19 CFR 351.226(l)(2) Commerce will direct CBP to suspend liquidation and require cash deposits on unliquidated entries entered, or withdrawn from warehouse for consumption, on or after August 12, 2025 — the publication date of the initiation notice, thirteen months before the determination. The reach-back runs to the initiation date, not to the determination date.

Which rates apply where both the China and Vietnam orders could reach an entry?

Commerce intends to instruct CBP to suspend and collect at the rates applicable to the Vietnam orders: the antidumping cash deposit rate for the Vietnam-wide entity, 220.68 percent, and the countervailing duty rate for all other companies, 31.58 percent. Those deposits are collected under third-country case numbers A-555-812 and C-555-813.

Does this only affect the company Commerce investigated?

No. The determination is country-wide. Alpha Hanger (Cambodia) Co., Ltd was identified on December 31, 2025 as the sole mandatory respondent, but the finding reaches hangers completed in Cambodia from Chinese or Vietnamese steel wire generally.

How is this different from the brake drums circumvention finding?

Commerce acted here under section 781(b), which addresses merchandise completed or assembled in a third country from inputs produced in a country subject to an order — a change in the route. The brake drums determination used section 781(d), later-developed merchandise — a change in the product. Between them the two provisions cover the most common commercial responses to an order.

I imported hangers from Cambodia in 2025 and already sold the goods. Am I exposed?

Potentially yes. Entries made from August 12, 2025 onward that remain unliquidated can be suspended and assessed even though they cleared entry without incident at the time. This is the recurring misunderstanding in circumvention practice: the rule does not change on the day Commerce announces it, and the initiation notice is the public marker.

This article is provided for general informational purposes only and is not legal advice. Reading it does not create an attorney-client relationship. Trade remedy and circumvention matters turn on the specific products, supply chains and entry records involved, and no particular outcome is guaranteed. Consult a qualified attorney about your own circumstances.

Contact Trembach Law Firm at (818) 514-7680 for a confidential consultation.

Trembach Law Firm | 27001 Agoura Road, Suite 350, Calabasas, CA 91301