In general, PCBs are used for packing, storing or transporting other merchandise and are typically made by cutting, scoring, die-cutting and then folding corrugated polypropylene sheets into containers.

On March 18, 2025, a coalition of U.S. producers of polypropylene corrugated boxes (PCBs) filed petitions with the U.S. Department of Commerce (DOC) and the U.S. International Trade Commission (ITC) requesting the imposition of antidumping duties on U.S. imports of PCBs from the People’s Republic of China and the Socialist Republic of Vietnam, as well as countervailing duties on Chinese PCBs. On the same date, the ITC issued its notice of institution of antidumping and countervailing duty investigations: Investigation Nos. 701-TA-757 and 731-TA-1737-1738 (Preliminary).

Dumping Margins and Countervailing Subsidies Alleged in the Petitions

The coalition that filed the petitions include CoolSeal USA Inc., Inteplast Group Corporation, SeaCa Plastic Packaging and Technology Container Corp. These petitioners allege dumping margins ranging from 74.63 percent to 83.49 percent ad valorem for China and a dumping margin of 40.85 percent ad valorem for Vietnam. In addition, the petitioners allege that China is subsidizing Chinese PCB producers with preferential lending, income tax reductions and deductions, import tariff exemptions and the provision of goods (polypropylene, calcium carbonate and pigment) and services (electricity) for less than adequate remuneration.

Proposed Scope of Investigations

The proposed scope of the investigations is as follows:

The merchandise covered by these investigations is Polypropylene Corrugated Boxes (“PCBs”). PCBs are boxes, totes, or other containers made of corrugated polypropylene sheets, also known as polypropylene hollow core sheets, polypropylene twin wall sheets, or multi wall sheets. Such polypropylene sheets are typically produced using a continuous extrusion process from a plastic resin consisting of 50 percent or more polypropylene.

PCBs are covered by the scope irrespective of the particular mix of polypropylene homo-polymer, polypropylene co-polymer, recycled or virgin polypropylene, or ancillary chemicals such as electrostatic agents or flame retardants. PCBs are formed by corrugated polypropylene sheets cut to discrete lengths, scored for folding edges, and die-cut into specific box formats. PCBs may be printed with ink or digital designs. PCBs may enter the United States in folded form or may enter unfolded and later be constructed to form a box shape with a bottom wall and side walls. Unfolded and constructed PCBs may have manufacturers’ joints to retain their final shape.

The subject merchandise includes PCBs with or without handles, with or without lids or tops, with or without reinforcing wire, and whether in a one-piece or multi-piece configuration.

The products subject to the investigations are currently classified in the Harmonized Tariff Schedule of the United States (HTSUS) under statistical reporting number 3923.10.9000. Although the HTSUS statistical reporting number is provided for convenience and customs purposes, the written description of the merchandise is dispositive.

In general, PCBs are used for packing, storing or transporting other merchandise and are typically made by cutting, scoring, die-cutting and then folding corrugated polypropylene sheets into containers.

Foreign Producers and U.S. Importers Named in the Petition

For a list of foreign producers/exporters alleged by petitioners, please see Appendix 1. For a list of importers alleged by petitioners, please see Appendix 2.

Anticipated Schedule for ITC and DOC Preliminary Investigations

The anticipated schedule for the ITC and DOC preliminary investigations is as follows:

Importantly, under the U.S. trade remedy laws, if the ITC renders negative injury determinations in its preliminary investigations, the proceedings are terminated and do not move on to the DOC. As such, it can be quite beneficial for entities opposed to the imposition of antidumping or countervailing duties to participate actively in the ITC’s preliminary investigations.

For More Information

If you have any questions about this Alert, or if your company may be interested in participating in the ITC of DOC investigations, please contact Geoffrey M. Goodale, Eduardo Ramos-Gómez, Bei Wang, Raul Rangel Miguel, Hoang Minh Duc, Taylor Hertzler, any of the attorneys in our International Practice Group or the attorney in the firm with whom you are regularly in contact.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.