# Certain Steel Wheels From the People's Republic of China: Initiation of Circumvention Inquiries on the Antidumping and Countervailing Duty Orders
**AGENCY:**
Enforcement and Compliance, International Trade Administration, Department of Commerce.
**SUMMARY:**
In response to a request from Accuride Corporation (Accuride) and Maxion Wheels USA LLC (Maxion) (domestic interested parties), the U.S. Department of Commerce (Commerce) is initiating a country-wide circumvention inquiry to determine whether imports of certain steel wheels from Thailand are circumventing the antidumping duty (AD) and countervailing duties (CVD) orders on certain steel wheels from the People's Republic of China (China).
**DATES:**
Applicable March 19, 2026.
**FOR FURTHER INFORMATION CONTACT:**
Thomas Cloyd, AD/CVD Operations, Enforcement and Compliance, International Trade Administration, U.S. Department of Commerce, 1401 Constitution Avenue NW, Washington, DC 20230; telephone: (202) 482-1246.
**SUPPLEMENTARY INFORMATION:**
**Background**
On January 14, 2026, pursuant to section 781(b) of the Tariff Act of 1930, as amended (the Act), and 19 CFR 351.226(i), Accuride and Maxion (domestic interested parties) filed a circumvention inquiry request alleging that certain steel wheels finished in Thailand using hot-rolled steel (HRS) produced in China, and subsequently exported from Thailand to the United States are circumventing the AD and CVD orders on certain steel wheels from China [^1] and, accordingly, should be included within the scope of the *Orders.*[^2] On January 26, 2026, an interested party, Asia Wheel Co., Ltd. (Asia Wheel), filed adequacy comments alleging the legal requirements to initiate a circumvention inquiry had not been met. [^3] On February 2, 2026, domestic interested parties filed rebuttal comments in response to Asia Wheel's adequacy comments. [^4] On February 9, 2026, we issued a supplementary questionnaire to domestic interested parties to clarify the period of inquiry and period of comparison. [^5] The domestic interested parties responded on February 12, 2026. [^6]
[^1]*See Certain Steel Wheels from the People's Republic of China: Antidumping and Countervailing Duty Orders,* 84 FR 24098 (May 24, 2019) ( *Orders* ).
[^2]*See* Domestic Interested Parties' Letter, “Request for Circumvention Ruling (Thailand),” dated January 14, 2026 (Circumvention Inquiry Request).
[^3]*See* Asia Wheel's Letter, “Adequacy Comments,” dated January 26, 2026.
[^4]*See* Domestic Interested Parties' Letter, “Response to Comments on the Adequacy of the Request for a Circumvention Inquiry,” dated February 2, 2026.
[^5]*See* Commerce's Letter, “Supplemental Questionnaire,” dated February 9, 2026.
[^6]*See* Domestic Interested Parties' Letter, “Response to Supplemental Questionnaire,” dated February 12, 2026. In accordance with 19 CFR 351.226(d)(1)(ii), the domestic interested parties' timely response extended the deadline for initiation of this circumvention inquiry by 30 days to March 16, 2026.
**Scope of the Orders**
The merchandise subject to the *Orders* is certain on-the-road steel wheels, discs, and rims for tubeless tires, with a nominal rim diameter of 22.5 inches and 24.5 inches, regardless of width. Imports of the subject merchandise are currently classified under the following Harmonized Tariff Schedule of the United States (HTSUS) subheadings: 8708.70.4530, 8708.70.4560, 8708.70.6030, 8708.70.6060, and 8716.90.5059. Merchandise meeting the scope description may also enter under the following HTSUS subheadings: 4011.20.1015, 4011.20.5020, and 8708.99.4850. While HTSUS subheadings are provided for convenience and customs purposes, the written description of the scope of the *Orders* is dispositive. For a full description of the scope of the *Orders, see* the Initiation Checklist. [^7]
[^7]*See* Checklist, “Thailand Assembly Circumvention Initiation Checklist,” dated concurrently with, and hereby adopted by, this notice (Initiation Checklist).
**Merchandise Subject to the Circumvention Inquiry**
The circumvention inquiry covers certain steel wheels finished in Thailand using HRS produced in China and subsequently exported from Thailand to the United States.
**Initiation of Circumvention Inquiry**
Section 351.226(d) of Commerce's regulations states that if Commerce determines that a request for a circumvention inquiry satisfies the requirements of 19 CFR 351.226(c), then Commerce “will accept the request and initiate a circumvention inquiry.” Section 351.226(c)(1) of Commerce's regulations, in turn, requires that each request for a circumvention inquiry allege “that the elements necessary for a circumvention determination under section 781 of the Act exist” and be “accompanied by information reasonably available to the interested party supporting these allegations.” Domestic interested parties alleged circumvention pursuant to section 781(b) of the Act (merchandise completed or assembled in other foreign countries).
Section 781(b)(1) of the Act provides that Commerce may find circumvention of an order when merchandise of the same class or kind subject to the order is completed or assembled in a foreign country other than the country to which the order applies. In conducting a circumvention inquiry, under section 781(b)(1) of the Act, Commerce relies on the following criteria: (A) merchandise imported into the United States is of the same class or kind as any merchandise produced in a foreign country that is the subject of an AD or CVD order; (B) before importation into the United States, such imported merchandise is completed or assembled in another foreign country from merchandise which is subject to the order or is produced in the foreign country that is subject to the order; (C) the process of assembly or completion in the foreign country referred to in section (B) 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) the administering authority determines that action is appropriate to prevent evasion of such order.
In determining whether the process of assembly or completion in a foreign country is minor or insignificant under section 781(b)(1)(C) of the Act, section 781(b)(2) of the Act directs Commerce to consider: (A) the level of investment in the foreign country; (B) the level of research and development in the foreign country; (C) the nature of the production process in the foreign country; (D) the extent of production facilities in the foreign country; and (E) whether or not the value of processing performed in the foreign country represents a small proportion of the value of the merchandise imported into the United States. However, no single factor, by itself, controls Commerce's determination of whether the process of assembly or completion in a foreign country is minor or insignificant. [^8] Accordingly, it is Commerce's practice to evaluate each of these five factors as they exist in the foreign country, depending on the totality of the circumstances of the particular circumvention inquiry. [^9]
[^8]*See* Statement of Administrative Action Accompanying the Uruguay Round Agreements Act, H.R. Doc. 103-316, Vol. 1 (1994), at 893.
[^9]*See Uncovered Innerspring Units from the People's Republic of China: Final Affirmative Determination of Circumvention of the Antidumping Duty Order,* 83 FR 65626 (December 21, 2018), and accompanying Issues and Decision Memorandum at 4.
In addition, section 781(b)(3) of the Act sets forth additional factors to consider in determining whether to include merchandise assembled or completed in a foreign country within the scope of an AD or CVD order. Specifically, Commerce shall take into account such factors as: (A) the pattern of trade, including sourcing patterns; (B) whether the manufacturer or exporter of the merchandise that was shipped to the foreign country is affiliated with the person who, in the foreign country, uses the merchandise to complete or assemble the merchandise which is subsequently imported into the United States; and (C) whether imports of the merchandise into the foreign country have increased after the initiation of the investigation that resulted in the issuance of such order.
**Analysis**
Based on our analysis of the domestic interested parties' circumvention inquiry request and supplemental questionnaire response, we determine that requesters have satisfied the criteria under 19 CFR 351.226(c), and thus, pursuant to 19 CFR 351.226(d)(1)(iii), we have accepted the request and are initiating the requested circumvention inquiry of the *Orders.* For a full discussion of the basis for our decision to initiate the requested circumvention inquiry, *see* the Initiation Checklist. The Initiation Checklist is available on ACCESS. ACCESS is available to registered users at *https://access.trade.gov.*
As explained in the Initiation Checklist, the information provided by requesters' warrants initiating this circumvention inquiry on a country-wide basis. Commerce has taken this approach in prior circumvention inquiries, where the facts warranted initiation on a country-wide basis. [^10] As such, Commerce intends to issue questionnaires to solicit information from producers and exporters in Thailand concerning their shipments to the United States and the origin of steel plates being further processed into steel wheels ( *i.e.,* the merchandise subject to the *Orders* ).
[^10]*See, e.g., Hydrofluorocarbon Blends from the People's Republic of China: Initiation of Circumvention Inquiry on the Antidumping Duty Order,* 88 FR 74150 (October 30, 2023); *see also Hydrofluorocarbon Blends from the People's Republic of China: Initiation of Circumvention Inquiries on the Antidumping Duty Order,* 88 FR 43275 (July 7, 2023); *Certain Corrosion-Resistant Steel Products from the Republic of Korea and Taiwan: Initiation of Anti-Circumvention Inquiries on the Antidumping Duty and Countervailing Duty Orders,* 83 FR 37785 (August 2, 2018); *Carbon Steel Butt-Weld Pipe Fittings from the People's Republic of China: Initiation of Anti-Circumvention Inquiry on the Antidumping Duty Order,* 82 FR 40556, 40560 (August 25, 2017) (stating at initiation that Commerce would evaluate the extent to which a country-wide finding applicable to all exports might be warranted); and *Certain Corrosion-Resistant Steel Products from the People's Republic of China: Initiation of Anti-Circumvention Inquiries on the Antidumping Duty and Countervailing Duty Orders,* 81 FR 79454, 79458 (November 14, 2016) (stating at initiation that Commerce would evaluate the extent to which a country-wide finding applicable to all exports might be warranted).
**Respondent Selection**
Commerce intends to base respondent selection on U.S. Customs and Border Protection (CBP) data. Commerce intends to place the CBP data on the record within five days of the publication of this initiation notice, which will be available on Enforcement and Compliance's Antidumping and Countervailing Duty Centralized Electronic Service System (ACCESS). ACCESS is available to registered users at *https://access.trade.gov.* Comments regarding the CBP data and respondent selection should be submitted within seven days after placement of the CBP data on the record of the inquiry.
Commerce intends to establish a schedule for questionnaire responses after respondent selection. A company's failure to completely respond to Commerce's requests for information may result in the application of partial or total facts available, pursuant to section 776(a) of the Act, which may include adverse inferences, pursuant to section 776(b) of the Act.
**Suspension of Liquidation**
Pursuant to 19 CFR 351.226(l)(1), Commerce will notify CBP of this initiation and direct CBP to continue the suspension of liquidation of entries of products subject to this circumvention inquiry that were already subject to the suspension of liquidation under the *Orders* and to apply the cash deposit rates that would be applicable if the products were determined to be covered by the scope of the *Orders.* Should Commerce issue affirmative preliminary or final circumvention determinations, Commerce will follow the suspension of liquidation rules under 19 CFR 351.226(l)(2)-(4). In the event that Commerce issues an affirmative preliminary or final circumvention that the products are circumventing the Orders, Commerce will instruct CBP to continue the suspension of liquidation of previously suspended entries and to apply the applicable cash deposit rate.
Commerce will also instruct CBP to begin the suspension of liquidation and application of cash deposits for any unliquidated entries not yet suspended, entered, or withdrawn from warehouse, for consumption, on or after the date of publication of the notice of initiation of the circumvention inquiries pursuant to paragraphs (l)(2)(ii) and (l)(3)(ii). In addition, pursuant to paragraphs (l)(2)(iii)(A) and (l)(3)(iii)(A), Commerce may instruct CBP to begin the suspension of liquidation and application of cash deposits for any unliquidated entries not yet suspended, entered, or withdrawn from warehouse, for consumption, prior to the date of initiation of the circumvention inquiries, but not for such entries prior to November 4, 2021, the effective date of these provisions in the *Final Rule.*[^11] These rules will not affect CBP's authority to take any additional action with respect to the suspension of liquidation or related measures for these entries, as stated in 19 CFR 351.226(l)(5).
[^11]*See Regulations to Improve Administration and Enforcement of Antidumping and Countervailing Duty Laws,* 86 FR 52300, 52345 (September 20, 2021) ( *Final Rule* ).
**Notification to Interested Parties**
In accordance with 19 CFR 351.226(d) and section 781(b) of the Act, Commerce determines that the domestic interested parties' request for a circumvention inquiry satisfies the requirements of 19 CFR 351.226(c). Accordingly, Commerce is notifying all interested parties of the initiation of this circumvention inquiry to determine whether certain steel wheels finished in Thailand using HRS produced in China, which are subsequently exported from Thailand to the United States, are circumventing the *Orders.* In addition, we have included a description of the products that are the subject to this inquiry and an explanation of Commerce's decision to initiate this inquiry as provided in the accompanying Initiation Checklist. [^12] In accordance with 19 CFR 351.226(e)(1), Commerce intends to issue its preliminary circumvention determination no later than 150 days from the date of publication of the notice of initiation of this circumvention inquiry in the *Federal Register* . Furthermore, in accordance with section 781(f) of the Act and 19 CFR 351.226(e)(2), unless the circumvention inquiry is rescinded, in whole or in part, or extended, Commerce intends to issue its final determination within 300 days from the date of publication of the notice of initiation of the circumvention inquiry in the *Federal Register* .
[^12]*See* Initiation Checklist at 4, 6.
This notice is published in accordance with section 781(b) of the Act, and 19 CFR 351.226(d)(1)(iii).
Dated: March 16, 2026.
Christopher Abbott,
Deputy Assistant Secretary for Policy and Negotiations, performing the non-exclusive functions and duties of the Assistant Secretary for Enforcement and Compliance.