This radical departure from 8 years of legal precedent relates to the use of a new surrogate country, Indonesia, to value inputs of raw materials used in fish processing. Because Vietnam is considered to be a “non market economy” by the US Government, the US DOC uses third country prices to value Vietnamese inputs.
Indonesia has been rejected in prior reviews due to poor data quality and lack of viable financial statements. The DOC itself declared that Indonesia is not “economically comparable” to Vietnam for a majority of the months covered by the review period, and then barred Vietnam from citing to this decision on the untenable position that it was “new information.”
In the final results, the DOC based its valuation of whole live fish prices – the primary input in the fish fillet case – on one Indonesian government pricing study which showed radical fluctuations in pricing and was not based on actual prices, but on calculated national averages from a handful of districts.
The DOC engineered this punitive result after intense political lobbying on behalf of the US domestic industry, the Catfish Farmers of America (CFA). There was no attempt to hide the multiple high-level meetings and lobbying efforts made on behalf of the CFA directly to the DOC. It clearly draws into question the fairness of the process and the alleged “neutral” nature of the DOC decision-makers. Vietnamese respondents have fully cooperated with DOC through multiple on-site verifications and the filing of full and complete responses and data over nearly 18 months.
For the past 8 years, the DOC has consistently used Bangladesh to value Vietnamese fish inputs, continually rejecting Philippines and Indonesia due to the poor quality of the pricing data, the lack of publicly available financial data, and the fact that these countries have no exports to other countries. No material changes had been made to these facts in this review.
Bangladesh is farming Pangasius Hypophthalmus in ponds like Vietnam. Producers in the two countries share the reasonably comparable production cost and revenue. While Indonesia farms five different catfish species. Thus, there is even no specific data in its output of Pangasius Hypophthalmus.
In fact, the DOC continued to follow this well-reasoned policy even through the most recent new shipper review, published only a few weeks ago. There was no record evidence in the 8th review that Indonesia had improved its position as a viable surrogate country or that the data was any more reliable. We must therefore believe that domestic politics played a very obvious role in this decision.
The final duty rates for the reviewed companies – although not effective until a final determination is made – average between $0.19/kg and $1.34/kg, with all other separate rates companies receiving a $0.77/kg duty rate. These exceed 100% in additional duties. These rates effectively bar the reviewed Vietnamese exporters from the US market and are punitive, not remedial.
VASEP, together with individual fish exporters and the relevant trade remedy bureaus of the Vietnamese Government are studying all options in addressing this punitive result and its legality under U.S. law and the WTO. Further, there will be a comprehensive review of its impact on bi-lateral relations.
VASEP
(seafood.vasep.com.vn) In 2025, Vietnam’s pangasius export turnover reached nearly USD 2.2 billion, up 8% year-on-year. This result indicates that pangasius exports maintained their growth momentum despite significant volatility in the global market environment. In December 2025, pangasius export value reached USD 200 million, up 10% compared to December 2024. This solid performance in the final month of the year reflects increased import demand for consumption and inventory replenishment in key markets.
(seafood.vasep.com.vn) In 2025, Vietnam’s tuna exports to Spain experienced significant fluctuations. According to Vietnam Customs, during the first 11 months of 2025, export turnover for the first 11 months of the year edged up by 0.3% year-on-year, reaching nearly $15 million.
(seafood.vasep.com.vn) Deputy Prime Minister Bui Thanh Son has signed Decision No. 16/QD-TTg, dated January 5, 2026, approving the implementation plan for the Vietnam-Israel Free Trade Agreement (VIFTA). Under the plan, in the coming period, ministries, ministerial-level agencies, government-affiliated entities and People’s Committees of provinces and centrally-run cities must institutionalize and execute tasks focused on the dissemination of information regarding VIFTA and the Israeli market; legislative and institutional development, as well as enhancing competitiveness and human resource growth...
(seafood.vasep.com.vn) Beyond achieving double-digit growth, Vietnam’s fish cake and surimi exports are showing a notable year-end "inflection point": the EU his accelerating with nearly twofold growth, China & Hong Kong are rising sharply, while the largest market, South Korea, signaled a slowdown in November. According to Vietnam Customs data, export turnover of fish cake and surimi reached $327 million in the first 11 months of 2025, up 22% year-on-year; November 2025 alone accounted for $35 million, marking a 5% increase. This serves as a critical foundation for exporters to reassess market structures and competitive intensity while finalizing order strategies for 2026.
(seafood.vasep.com.vn) Ca Mau, widely regarded as the nation’s “shrimp capital”, continued its strong performance in 2025 as shrimp output reached nearly 600,000 tons, maintaining its position as Vietnam’s leading shrimp-producing locality.
(seafood.vasep.com.vn) On December 29, 2025, at the 2025 Pangasius Industry Review Conference held in Can Tho City, the Vietnam Pangasius Association announced that fingerling prices have surged to record levels due to acute supply shortages.
(seafood.vasep.com.vn) While Vietnam’s shrimp exports to the EU maintained positive growth momentum in 2025, several new regulations related to animal welfare are transitioning from “ethical recommendations” to mandatory requirements, likely reshaping the shrimp supply chain for this market from 2026 onwards.
(seafood.vasep.com.vn) Vietnam’s seafood exports reached $989.5 million in November 2025, up 64.6% year-on-year. The robust monthly performance played a pivotal role in driving the total export turnover for the first 11 months of 2025 to $10.5 billion, representing a 19% increase compared with the same period in 2024.
(vasep.com.vn) Vietnam’s crab exports reached USD 81 million in the first 11 months of 2025, with the United States accounting for more than 82% of total value. While newly imposed reciprocal tariffs and the enforcement of provisions under the U.S. Marine Mammal Protection Act (MMPA) pose significant challenges for Vietnam, the European Union is emerging as a promising growth market.
(seafood.vasep.com.vn) The Ca Mau Department of Agriculture and Environment has recently issued a plan to develop specialized crab raw material zones serving official export channels, covering a scale of around 50,000 hectares. This marks a significant shift in the sea crab industry towards professional production aligned with market requirements.
VASEP - HIỆP HỘI CHẾ BIẾN VÀ XUẤT KHẨU THỦY SẢN VIỆT NAM
Chịu trách nhiệm: Ông Nguyễn Hoài Nam - Phó Tổng thư ký Hiệp hội
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Trưởng Ban Biên tập: Bà Phùng Thị Kim Thu
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