Zero Tolerance for Circumvention Schemes: Commerce Catches Duty Dodgers

Emily Bradshaw is a Communications Specialist with the International Trade Administration’s Enforcement & Compliance Unit

ITA’s Enforcement & Compliance unit investigates whether imports are being dumped, or foreign companies are receiving countervailable subsidies, giving them an unfair advantage over U.S. industries. After conducting lengthy and resource-intensive investigations, an antidumping or countervailing duty (AD/CVD) order will be issued if these practices are taking place and the domestic industry is injured.  However, too often the relief that U.S. industries hope will be delivered by an AD/CVD order is thwarted when parties attempt to circumvent the duties.

That is exactly what happened to the U.S. industry producing standard steel welded wire mesh. U.S. companies including Keysteel Corp., Mid-South Wire Company, National Wire LLC, and Oklahoma Steel & Wire Mesh Corp. alleged that companies in Mexico have been circumventing the AD/CVD orders on steel wire mesh. Steel wire mesh has a variety of applications including security fencing, water filtration, particle separation, industrial equipment, and decorative uses in interior design. This industry was worth over $25 billion in 2024 and is expected to grow to over $38 billion1 by 2033, contributing to strong, well-paying U.S. manufacturing jobs around the country, including in Oklahoma, Tennessee, and Texas.

On September 12, 2025, E&C announced its preliminary decision that AD/CVD duties were, in fact, being intentionally circumvented by one Mexican company, Deacero S.A.P.I de C.V. (Deacero). E&C previously found that Deacero was engaged in circumventing AD/CVD duties on another product, prestressed concrete wire strand, and yet, Commerce preliminarily found that Deacero continued to circumvent AD/CVD duties despite receiving explicit directives that this is an unfair trade practice and will be met with duties.  After careful consideration, E&C decided to retroactively apply duties on imports of low carbon steel wire that is produced by Deacero in Mexico and assembled into standard steel welded wire mesh in the United States, effective on April 2, 2024, which is nine months earlier than the initiation of the circumvention inquiry.  Accordingly, Deacero’s entries of this merchandise are now subject to a combined rate of 211.49 percent.  Previously, E&C only required collection as early as the date of initiation of a circumvention inquiry.  This change reflects E&C’s commitment to rigorously defending AD/CVD orders, so that they continue to provide relief to U.S. industry.  

The steel wire mesh circumvention inquiry marks the first instance of applying duties retroactively based on a circumvention finding for the same company under a different AD/CVD order, consistent with recently updated regulations.  E&C is committed to providing the intended relief of American trade remedy laws to U.S. companies and to penalizing unfair actors who formulate circumvention schemes to undermine our laws and regulations.  

For more details, please visit ACCESS.trade.gov referring to case numbers A-201-853 and C-201-854.

If you are a company facing unfair trade that suspects dumping, subsidies, or circumvention of current AD/CVD orders, please contact our petition counseling unit at EC Petition Counseling. 

*Rate updated September 24, 2025