Coalition for Fair Trade in Hardwood Plywood files new trade case against imports of hardwood and decorative plywood from China, Indonesia, and Vietnam

The Petition

The Coalition for Fair Trade in Hardwood Plywood (“Coalition” or “Petitioner”) filed new petitions against imports of hardwood and decorative plywood from China, Indonesia, and Vietnam. The antidumping (“AD”) petitions allege that the imports from China, Indonesia, and Vietnam are sold at less than fair value. The countervailing duty (“CVD”) petitions allege that the imports from China, Indonesia, and Vietnam are unfairly subsidized by their respective governments.

Hardwood and decorative plywood is a panel composed of an assembly of two or more layers or plies of wood veneer(s) either in combination with a core or without. The several layers, either with or without the core, are glued or otherwise bonded together to form a finished product. Hardwood and decorative plywood panels can be composed of one or more species of hardwoods, softwoods, or bamboo, in addition to other materials that are used for the core. Hardwood and decorative plywood is primarily manufactured as a panel of varying sizes. Hardwood and decorative plywood is typically comprised of a core sandwiched between two veneers. Hardwood and decorative plywood has a wide variety of uses, including but not limited to wall panels, kitchen cabinet components, seat backs, tables, desktops, drawer sides, furniture, indoor flooring, and more.

Please see below for the full text of the proposed scope for the investigations.

Key Facts

Petitioner: Coalition for Fair Trade in Hardwood Plywood

Foreign Producers/Exporters and U.S. Importers: Please contact Clark Hill’s international trade team for a listing of individual importers and exporters named in the petitions.

AD/CVD Margins: Petitioner alleged the following AD and CVD margins:

• China: AD margin of 474.20% ad valorem, and a CVD margin above de minimis;
• Indonesia: AD margin of 202.80% ad valorem, and a CVD margin above de minimis;
• Vietnam: AD margins from 112.33% to 133.72% ad valorem, and a CVD margin above de minimis.

The Investigation

The U.S. Department of Commerce (“DOC”) and the U.S. International Trade Commission (“ITC”) will conduct the investigations. The ITC will determine if there is a reasonable indication that the imports are injuring or threatening to injure the U.S. industry. The DOC will then determine whether imports are being dumped or unfairly subsidized and will calculate corresponding AD and CVD duty margins that importers will need to pay on their entries.

Importers will be required to deposit the calculated AD/CVD duties on their imports as of the date that the DOC publishes its affirmative preliminary determination in the Federal Register. In this case, the DOC’s preliminary determinations are currently expected by August 15, 2025 (CVD) and October 29, 2025 (AD). Importers should be aware that entries may be subject to cash deposits before these dates if the DOC finds that there is a surge of imports after the petitions were filed.

Next Steps

All U.S. importers and foreign producers are advised to prepare as soon as possible due to the strict statutory deadlines in these cases. If this product is of interest to you, please contact Clark Hill’s international trade team so that we can provide you with additional information.

The Scope

The merchandise covered by these investigations is hardwood and decorative plywood, which is:

The merchandise covered by the investigations is hardwood and decorative plywood, and certain veneered panels as described below. For purposes of this proceeding, hardwood and decorative plywood is defined as a generally flat, multilayered plywood or other veneered panel, consisting of two or more layers or plies of wood veneers in combination with a core or without a core. The veneers, along with the core, may be glued or otherwise bonded together. A hardwood and decorative plywood panel must have at least either the face or back veneer composed of one or more species of hardwood, softwood, or bamboo. Hardwood and decorative plywood may include products that meet the American National Standard for Hardwood and Decorative Plywood, ANSI/HPVA HP-1-2024 (including any revisions to that standard).

For purposes of the investigations a “veneer” is a slice of wood regardless of thickness which is cut, sliced or sawed from a log, bolt, or flitch. The face and back veneers are the outermost veneer of wood on either side of the core irrespective of additional surface coatings or covers as described below. The core of hardwood and decorative plywood consists of the layer or layers of one or more material(s) that are situated between the face and back veneers. The core may be composed of a range of materials, including but not limited to hardwood, softwood, particleboard, or medium density fiberboard (MDF).

All hardwood and decorative plywood is included within the scope of the investigations regardless of whether or not the face and/or back veneers are surface coated or covered and whether or not such surface coating(s) or covers obscures the grain, textures, or markings of the wood. Examples of surface coatings and covers include, but are not limited to: ultra violet light cured polyurethanes; oil or oil-modified or water-based polyurethanes; wax; epoxy-ester finishes; moisture-cured urethanes; paints; stains; paper; aluminum; high pressure laminate; MDF; medium density overlay (MDO); and phenolic film. Additionally, the face veneer of hardwood and decorative plywood may be sanded; smoothed or given a “distressed” appearance through such methods as hand-scraping or wire brushing.

All hardwood and decorative plywood is included within the scope even if it is trimmed; cut-to-size; notched; punched; drilled; or has undergone other forms of minor processing. All hardwood and decorative plywood is included within the scope of the investigation, without regard to dimension (overall thickness, thickness of face veneer, thickness of back veneer, thickness of core, thickness of inner veneers, width, or length). However, the most common panel sizes of hardwood and decorative plywood are 1219 x 1829 mm (48 x 72 inches), 1219 x 2438 mm (48 x 96 inches), and 1219 x 3048 mm (48 x 120 inches). Subject merchandise also includes hardwood and decorative plywood that has been further processed in a third country, including but not limited to trimming, cutting, notching, punching, drilling, or any other processing that would not otherwise remove the merchandise from the scope of the investigations if performed in the country of manufacture of the in-scope product.

The scope of the investigation excludes the following items: (1) structural plywood (also known as “industrial plywood” or “industrial panels”) that (a) is certified, manufactured, and stamped to meet U.S. Products Standard PS 1-09, PS 2-09, PS-122, or PS 2-10 for Structural Plywood (including any revisions to that standard or any substantially equivalent international standard intended for structural plywood), including, but not limited to, the “bond performance” requirements set forth at paragraph 5.8.6.4 of that Standard and the performance criteria detailed at Tables 4 through 10 of that Standard, and (b) has a core made entirely of one or more of the following wood species: Pseudotsuga menziesii (Douglas Fir), Larix occidentalis (Western Larch), Tsuga heterophylla (Western Hemlock), Abies spp. (True Firs like Grand Fir, Pacific Silver Fir), Picea spp. (White Spruce, Engelmann Spruce), Pinus spp. (Lodgepole Pine, Jack Pine), Picea glauca (White Spruce), Pinus banksiana (Jack Pine), and Abies balsamea (Balsam Fir); (2) products which have a face and back veneer of cork; (3) hardwood plywood subject to the antidumping and countervailing duty orders on hardwood plywood from China. See Hardwood Plywood Products from the People’s Republic of China, 83 Fed. Reg. 504 (Dep’t Commerce Jan. 4, 2018) (amended final determination of sales at less than fair value (LTFV) and AD order); and Hardwood Plywood Products from the People’s Republic of China, 83 FR 513 (Jan. 4, 2018) (CVD order); (4) multilayered wood flooring, as described in the antidumping duty and countervailing duty orders on multilayered wood flooring from China. See Multilayered Wood Flooring from the People’s Republic of China, 76 Fed. Reg. 76,690 (December 8, 2011) (amended final determination of sales at less than fair value (LTFV) and AD order); and Multilayered Wood Flooring from the People’s Republic of China, 76 Fed. Reg. 76,693 (Dep’t Commerce December 8, 2011) (countervailing duty order), as amended by Multilayered Wood Flooring from the People’s Republic of China: Amended Antidumping and Countervailing Duty Orders, 77 Fed. Reg. 5,484 (Dep’t Commerce February 3, 2012); (5) multilayered wood flooring with a face veneer of bamboo or composed entirely of bamboo; (6) plywood which has a shape or design other than a flat panel, with the exception of any minor processing described above; (7) products made entirely from bamboo and adhesives (also known as “solid bamboo”); and (8) Phenolic Film Faced Plyform (PFF), also known as Phenolic Surface Film Plywood (PSF), defined as a panel with an “Exterior” or “Exposure 1” bond classification as is defined by The Engineered Wood Association, having an opaque phenolic film layer with a weight equal to or greater than 90g/m3 permanently bonded on both the face and back veneers and an opaque, moisture resistant coating applied to the edges.

Also excluded from the scope of the investigations are wooden furniture goods that, at the time of importation, are fully assembled and are ready for their intended uses. Also excluded from the scope of the investigations is “ready to assemble” (RTA) furniture. RTA furniture is defined as (A) furniture packaged for sale for ultimate purchase by an end-user that, at the time of importation, includes (1) all wooden components (in finished form) required to assemble a finished unit of furniture, (2) all accessory parts (e.g., screws, washers, dowels, nails, handles, knobs, adhesive glues) required to assemble a finished unit of furniture, and (3) instructions providing guidance on the assembly of a finished unit of furniture; (B) unassembled bathroom vanity cabinets, having a space for one or more sinks, that are imported with all unassembled hardwood and hardwood plywood components that have been cut-to-final dimensional component shape/size, painted or stained prior to importation, and stacked within a singled shipping package, except for furniture feet which may be packed and shipped separately; or (C) unassembled bathroom vanity linen closets that are imported with all unassembled hardwood and hardwood plywood components that have been cut-to-final dimensional shape/size, painted or stained prior to importation, and stacked within a single shipping package, except for furniture feet which may be packed and shipped separately.

Also excluded from the scope of the investigations are kitchen cabinets that, at the time of importation, are fully assembled and are ready for their intended uses. Also excluded from the scope of the investigations are RTA kitchen cabinets. RTA kitchen cabinets are defined as kitchen cabinets packaged for sale for ultimate purchase by an end-user that, at the time of importation, includes: (1) all wooden components (in finished form) required to assemble a finished unit of cabinetry; (2) all accessory parts (e.g., screws, washers, dowels, nails, handles, knobs, hooks, adhesive glues) required to assemble a finished unit of cabinetry; and (3) instructions providing guidance on the assembly of a finished unit of cabinetry. Excluded from the scope of the investigations are finished table tops, which are table tops imported in finished form with pre-cut or drilled openings to attach the underframe or legs. The table tops are ready for use at the time of import and require no further finishing or processing. Excluded from the scope of the investigations are finished countertops that are imported in finished form and require no further finishing or manufacturing.

Contact Clark Hill

If you have any questions regarding the content of this alert, please contact Mark Ludwikowski (mludwikowski@clarkhill.com; 202-640-6680), Kevin Williams (kwilliams@clarkhill.com; 312-985-5907), Aristeo Lopez (alopez@clarkhill.com; 202-552-2366), Kelsey Christensen (kchristensen@clarkhill.com; 202-640-6670), Sally Alghazali (salghazali@clarkhill.com; 202-572-8676), or other members of Clark Hill’s International Trade Business Unit.

This publication is intended for general informational purposes only and does not constitute legal advice or a solicitation to provide legal services. The information in this publication is not intended to create, and receipt of it does not constitute, a lawyer-client relationship. Readers should not act upon this information without seeking professional legal counsel. The views and opinions expressed herein represent those of the individual author only and are not necessarily the views of Clark Hill PLC. Although we attempt to ensure that postings on our website are complete, accurate, and up to date, we assume no responsibility for their completeness, accuracy, or timeliness.