US trailer group pursues duty investigation on trailers and components

Although the case is formally titled “Van-Type Trailers and Subassemblies from Canada, China, and Mexico”, the filing’s scope reveals that the bulk of the volume arises from the additional trailer categories brought under the petitions Harmonized Tariff Schedule (HTS) coverage.

The filing, brought by Great Dane, Stoughton Trailers and Wabash National, is broader in scope than van-type category that figured prominently in an earlier Section 232 derivative-classification inclusion petition. That petition, through which importers seek to have downstream, “derivative” products covered by the Section 232 aluminum and steel tariff regime, was submitted earlier this year by a differently named coalition that included these three firms and one additional participant. While tangential to the current case, it illustrates that the companies have pursued other remedies and are now advancing a substantially wider set of claims.

The petition covers trailers and semi-trailers for the transport of goods, parts for trailers and semi-trailers including axles, wheels and related running-gear components; and a broad range of fabricated metal structures such as iron and steel roofing, siding, flooring, doors, thresholds, windows and structural assemblies used in trailer construction. It also includes various motor-vehicle body parts and accessories, including sheet-metal elements, structural reinforcements, and other subassemblies, captured under the relevant commercial automotive HTS classifications.

Those three companies represent a substantial share of North American dry van and refrigerated trailer production and were also central participants in the submission of a Section 232 derivative petition regarding two HTS codes under a different coalition name. That coalition, the Ad Hoc Coalition of Dry Van and Reefer (refrigerated truck) Producers, included the three ATMC petitioners, as well as a Strick Trailers—which is not included in the current AD/CVD investigation request.

The Commerce secretary ultimately approved derivative coverage for one of the classifications—8716.39.0040, a decision published on Aug. 1. It denied the request for 8716.90.5050 (parts for trailers and semi-trailers used in the transport of goods) due to its overlap with other Section 232 automotive and truck investigations.

Differences between trade remedies and Section 232 authority

Unlike the Section 232 derivative case, the current petition incorporates a wide range of products including platform and agricultural trailers, trailer and semi-trailer parts, steel structural components, and aluminum wheels.

Moreover, AD/CVD duties are quasi-judicial outcomes: They are initiated through a petition, adjudicated by the Department of Commerce (DOC) and the International Trade Commission (ITC), and imposed only if Commerce finds dumping or subsidization and the ITC finds material injury or threat.

In contrast, Section 232 actions and derivative inclusions, are rooted in national-security authority and can be reshaped, withdrawn, or expanded at the discretion of the executive branch.

This means that, once in place, AD/CVD duties typically remain in place for many years. They do not fluctuate with administration-level trade strategy, persisting regardless of changes in broader tariff policy and geopolitical posture. Their only periodic check is the statutory five-year sunset review, in which the DOC and ITC reassess whether removing the duties would likely lead to the continuation or recurrence of dumping, subsidization, or injury.

If both agencies affirm, the duties continue; if not, they terminate.

Import patterns across subject countries

Within the subheadings that fall under trailers and semi-trailers for the transportation of goods, the HTS code subject to Section 232 derivative inclusion earlier in the year only covered van-type trailers, of which Mexico was by far the dominant supplier of imports to the US market.

Imports under this code rose steadily from 2015 through 2019, fell sharply during the initial pandemic years, then climbed again in 2022 and 2023 before easing back in 2024.

Current year-to-date (January-July) imports under this primary 10-digit code are at their lowest level since 2020.

That said, when you include the broader eight-digit code 8716.39.00 code used in the AD/CVD petition (leaving out the “40” on the end) to include trailers and semi-trailers used in agriculture, transporting motor vehicles, platform-type trailers/semi-trailers, and the “not elsewhere specified or included” category, the data presents higher levels of imports, though the cyclical patterns are the same as the more specific van-type subcategory.

In other words, the import data shows the competitive pressure facing US producers is not coming primarily from van-type trailers, like those petitioned and approved in the Section 232 inclusion procedure earlier this year.

The Ad Hoc Coalition of Dry Van and Reefer Producers cited ACT Research in showing van-type trailers account for roughly three-quarters of all US truck-trailer sales, while imports from Mexico, Canada, and China totaled only 48,751 van-type units in 2024 according to Census data—significant but not overwhelming.

By contrast, imports across all trailer categories reached 169,515 units, meaning more than 120,000 of the imported trailers were non-van-type models.

That imbalance indicates foreign producers have made their largest inroads not in the dry-van/reefer segment that dominates US demand, but in the more fragmented ecosystem of platform trailers, agricultural trailers, specialty equipment, and other commercial-use units where domestic manufacturing is less concentrated.

Mexico remains the leading supplier overall, but China and Canada account for a much larger share of imports in these non-van-type categories, showing the import surge that the petition references is driven more by these ancillary segments than by van-type trailers themselves.

One product category in which China is still a dominant supplier is in door assemblies (including cabs) for use in tractors and special-purpose vehicles.

Industry stakeholders and their positions

The petition comes against the backdrop of longstanding divisions within the domestic trailer sector.

Utility Trailer Manufacturing, a major US producer that opposed the earlier Section 232 derivative petition, argued the framework could expose US companies to double Section 232 duties on the same aluminum—once when importing billet smelted abroad and again when a finished trailer returns to the US after assembly in Canada and Mexico.

Vanguard Trailer Holdings raised similar concerns around the same time, emphasizing the potential unintended consequences for companies with cross-border manufacturing footprints.

Hyundai Translead, the largest truck-trailer OEM in North America by 2024 output, according to Trailer Bodybuilder data contained in the Ad Hoc Coalition of Dry Van and Reefer Producers’ Section 232 derivative petition, is likely to be the producer most affected by the investigation.

The company, a subsidiary of Hyundai Motor Company in Korea, maintains a US headquarters but builds all its North American trailer production in Mexico.

Domestic manufacturers routinely cite this structure as a mechanism through which large volumes of competitively priced equipment enter the US market.

Taken together, Hyundai Translead, Utility Trailer, Vanguard, and the three ATMC petitioners accounted for roughly three-quarters of all North American truck-trailer output in 2024, according to the same Trailer Bodybuilder data.

Their positions on trade remedies therefore shape much of the commercial landscape the ITC must evaluate.

Potential market impact

With Mexico overwhelmingly the primary exporter in these HTS categories, the outcome of the investigation by the DOC and ITC would shape the competitive landscape and the structure of the US trailer supply chain for years to come.

The most impactful aspect of AD/CVD duties is that they are not applied as a single, uniform tariff.

Commerce sets them on a company-specific or country-wide basis depending on the evidence in the record, resulting in a range of deposit rates that can vary significantly among foreign producers. Often the country AD/CVD rate sets the baseline, while specific companies are singled out and subject to higher rates.

The breadth of the petition and the concentration of imports in non-van-type categories is poised to influence far more than the narrow van-type segment named in the title.