Commerce Finalizes Circumvention Finding on Cambodia-Finished Hangers
Supply Chain

Commerce Finalizes Circumvention Finding on Cambodia-Finished Hangers

Commerce issued a final affirmative circumvention determination on steel wire garment hangers completed in Cambodia from Chinese or Vietnamese inputs, with continuing cash deposits and a certification process.

3 min read
Back to News
In this article
Share this article

At a glance

  • Commerce found that Cambodia-completed steel wire hangers made with Chinese or Vietnamese inputs and exported to the United States circumvent the China order or the Vietnam orders.
  • The final determination matches the preliminary one, and the notice was published November 6, 2026.
  • Cash deposits and the certification process continue, and importers and producers must keep supporting documentation.

The U.S. Department of Commerce has issued a final affirmative determination that steel wire garment hangers completed in Cambodia from Chinese or Vietnamese steel wire, or steel wire and paper accessories, are circumventing existing U.S. trade orders. Under section 781(b) of the Tariff Act of 1930, Commerce found that such hangers, when exported to the United States, fall within the scope of the China order or the Vietnam orders. Hangers made with Chinese-origin inputs are subject to the China order, and those made with Vietnamese-origin inputs are subject to the Vietnam orders. Commerce made the determination on a country-wide basis. The determination is dated October 30, 2026, and the Federal Register notice was published on November 6, 2026.

The inquiries reach only hangers that are completed in Cambodia and then exported from Cambodia to the United States. Commerce opened the country-wide inquiries on August 12, 2025, to decide whether these hangers circumvent the China order or the Vietnam orders and should fall within their scope. The underlying orders are the China antidumping order published October 6, 2008, and the Vietnam antidumping and countervailing duty orders published February 5, 2013.

The final finding matches the preliminary determination, which was published September 22, 2026. Commerce said it invited comments on the preliminary determination and received none from any interested party. The final notice carries no decision memorandum, and the deadline for the final determination had been extended to October 30, 2026.

Cash deposits and entries covered

Commerce said it will direct U.S. Customs and Border Protection (CBP) to keep suspending liquidation and collecting cash deposits of estimated antidumping or countervailing duties on unliquidated entries of hangers from Cambodia. That instruction covers entries made or withdrawn from warehouse for consumption on or after August 12, 2025, the Federal Register publication date of the inquiry initiation. It rests on the affirmative final country-wide determination under 19 CFR 351.226(l)(3) and remains in effect until further notice. Commerce also continues to apply, for the final determination, the cash deposit requirements and certification process set out in the preliminary determination.

For Cambodian hanger entries that could be subject to both the China and Vietnam orders, Commerce told CBP, citing the preliminary determination, to suspend entries and collect deposits at the Vietnam order rates. Those rates are 220.68 percent for antidumping duties, the rate established for the Vietnam-wide entity under case number A-555-812, and 31.58 percent for countervailing duties, the rate for all other companies under case number C-555-813. Entries certified as made with Chinese-origin inputs are treated differently. Where the producer, exporter and importer have made that certification in Commerce's dual circumvention certification program, Commerce directed CBP, citing the preliminary determination, to suspend liquidation and require cash deposits at the China hanger antidumping rate under case number A-555-918.

Certification and recordkeeping

Commerce has put in place a certification program that lets parties certify that hangers exported from Cambodia were made with Chinese rather than Vietnamese steel wire or steel wire and paper accessories. To certify that shipments are outside the Vietnam orders, the importer, exporter and producer must give CBP documentation at the time of entry supporting the claim that the inputs came from China. The program excludes parties to which Commerce applied adverse facts available. Commerce said it may later consider a more general program, such as certification that hangers were not made with Chinese or Vietnamese inputs. Commerce also found, in the preliminary determination and continuing in the final one, that no Cambodian hanger exporter is eligible to certify the origin of the steel, or steel and paper, inputs used to produce hangers in Cambodia.

Under the notice, importers and producers of Cambodian hangers must keep their certifications and supporting documentation for covered entries. The retention period runs until the later of five years after the latest entry date of the covered entries or three years after any U.S. court litigation concerning those entries ends. Commerce or CBP may verify the claims in those certifications and documents.

Scope exclusions

The notice's scope language excludes wooden, plastic and other hangers not made of steel wire from the China order, along with chrome-plated steel wire hangers. The chrome-plated exclusion applies only to hangers with a diameter of 3.4 mm or greater. For the Vietnam orders, the same language excludes wooden, plastic and other non-steel-wire hangers, steel wire hangers with swivel hooks, steel wire hangers with permanently affixed clips, and chrome-plated steel wire hangers. Under the Vietnam orders as well, chrome-plated hangers are excluded only at a diameter of 3.4 millimeters or greater.

Get Business Technology Updates

Practical guidance on complex operations, integration, portals, analytics, automation, custom software, trusted records, and fit-for-purpose engineering.

No spam. Unsubscribe anytime.