This guide helps U.S. food-packaging importers screen thermoformed molded fiber and bagasse products against the current written scopes, manufacturing origin and shipment documentation before comparing sourcing options. It separates the China/Vietnam molded-fiber orders from the distinct paper-plate orders and turns the official rules into a practical procurement workflow.
Last Updated: September 2026
As of September 15, 2026, the U.S. Department of Commerce has antidumping and countervailing duty orders covering thermoformed molded fiber products from China and Vietnam. The written scope can include cellulose-fiber plates, bowls, clamshells, trays and lids, including products made from agricultural residues such as bagasse. Thailand is not named in those specific orders, but that does not make every Thailand-origin product duty-free: certain paper plates from Thailand are covered by a separate U.S. antidumping order. Importers should verify product scope, manufacturing origin and current entry instructions before comparing suppliers.
Official fact: The U.S. Department of Commerce, through the International Trade Administration, published final antidumping and countervailing duty determinations in September 2025. The U.S. International Trade Commission then found material injury to the U.S. industry from the subject imports. On January 27, 2026, Commerce issued the final AD and CVD orders covering thermoformed molded fiber products from China and Vietnam.
| Proceeding | China | Vietnam | Current order date |
|---|---|---|---|
| Thermoformed molded fiber antidumping duty | A-570-182 | A-552-845 | January 27, 2026 |
| Thermoformed molded fiber countervailing duty | C-570-183 | C-552-846 | January 27, 2026 |
AD and CVD are separate remedies. Antidumping duties address sales at less than fair value; countervailing duties address countervailable government subsidies. U.S. Customs and Border Protection explains the distinction in its AD/CVD guidance.
Buyer interpretation: an order date is not a universal duty percentage. Cash-deposit instructions and rates can vary by proceeding and producer/exporter and may change through later administrative action. A cash deposit is also not the same as the final landed duty assessed after liquidation.
Buyer recommendation: identify the product, manufacturer, exporter and actual country of origin first; then verify the current case and entry instructions through Commerce, U.S. Customs and Border Protection, the customs broker and trade counsel. Do not use a preliminary rate, another exporter’s rate or a country-wide headline as a quotation assumption.
The operative rule is Commerce’s written scope. It covers thermoformed molded fiber products made from cellulose fibers, thermoformed with one or more heated molds and dried or cured in the mold. The language applies regardless of shape, function, fiber source or finish and lists foodservice packaging among the examples.
| Factor | What the order says | Procurement implication |
|---|---|---|
| Material | Cellulose fiber | Record the complete material composition; a marketing label alone is insufficient. |
| Fiber source | Virgin or recycled fiber, including agricultural crops, byproducts and residues | Bagasse can fit the fiber-source description, but material does not decide scope by itself. |
| Process | Thermoformed using one or more heated molds and dried or cured in the mold | Obtain a process flow identifying forming, heating, drying and curing stages. |
| Examples | Plates, bowls, clamshells, trays, lids, food-contact and foodservice packaging | A familiar product name does not replace a comparison with the complete scope. |
| Finish | Natural, bleached, dyed, colored, printed, coated, laminated, embossed or otherwise finished products may remain covered | Do not assume printing, coating, trimming or packing changes the scope outcome. |
| Main named origins | China and Vietnam | Establish the legally supportable manufacturing origin, not merely the shipment route. |
| Key exclusion | Products covered by the separate paper-plate orders are excluded from these TMFP orders | For plates, test the separate paper-plate scope and exclusions before reaching a TMFP conclusion. |
The scope also describes thermoformed molded fiber products as relatively dense, with a typical fiber density above 0.5 grams per cubic centimeter, and generally having relatively smooth surfaces. “Typical” should not be converted into a stand-alone buyer threshold. Importers should compare the complete written description and any applicable exclusions.
For commercial product context, review Zhongxin’s molded fiber packaging overview, food packaging portfolio and bagasse tableware range. These product pages do not replace a customs scope or origin determination.
No. “Bagasse” identifies a possible cellulose-fiber source, not a complete customs determination. Agricultural crop residue is expressly included among potential fiber sources in the TMFP scope, so a bagasse bowl, clamshell, tray, plate or lid may meet part of the description. The final analysis still depends on the forming and in-mold drying or curing process, product characteristics, applicable exclusions, actual country of origin and entry-specific facts.
Commerce explains that an AD/CVD scope defines the merchandise to which duties may apply. When a specific product remains uncertain, a Commerce scope ruling and a U.S. Customs and Border Protection classification ruling answer different questions: Commerce determines AD/CVD scope, while U.S. Customs and Border Protection determines HTS classification. One does not automatically substitute for the other.
Not necessarily. The China/Vietnam TMFP written scope excludes products that are covered by the separate paper-plate orders. The March 20, 2025 paper-plate AD orders cover China (A-570-164), Thailand (A-549-849) and Vietnam (A-552-839). Separate paper-plate CVD orders cover China (C-570-165) and Vietnam (C-552-840), not Thailand.
The paper-plate AD scope states that covered plates may be made from several paper sources, including bagasse. It also expressly excludes paper plates molded or pressed directly from paper pulp. That is why neither “bagasse plate = paper-plate order” nor “bagasse plate = TMFP order” is a safe automatic rule.
As a current-status check, Commerce’s May 4, 2026 administrative-review initiation notice lists Thailand certain paper plates under A-549-849. Buyers should therefore treat the Thailand paper-plate AD proceeding as active and verify the current instructions rather than relying on the original investigation rate table.
| Product / origin | First question buyer should check |
|---|---|
| China molded fiber clamshell | Is it within the written scope of the China thermoformed molded fiber AD/CVD orders? |
| Vietnam molded fiber bowl | Is it within the written scope of the Vietnam thermoformed molded fiber AD/CVD orders? |
| Thailand molded fiber clamshell | What is the actual country of origin, and is another trade-remedy order applicable? |
| Thailand bagasse plate | Does it fall within the separate paper-plate AD order, including that order’s exclusions? |
This table is procurement screening logic, not a customs or scope determination.
The first comparison is not “which country has the lowest duty.” It is whether the quoted products are the same for scope, origin, producer/exporter, performance, documentation and commercial terms. Only then can the importer build a defensible landed-cost model.
| Buyer check | China | Vietnam | Thailand |
|---|---|---|---|
| Thermoformed molded fiber AD/CVD order | Check current China orders | Check current Vietnam orders | Not a named country in these specific TMFP orders |
| Separate paper-plate proceeding | Check AD and CVD scopes | Check AD and CVD scopes | Check the Thailand paper-plate AD scope |
| Country-of-origin documentation | Required | Required | Required |
| Product-scope confirmation | Required | Required | Required |
| Producer/exporter and rate check | Where applicable | Where applicable | Where applicable under the applicable order |
| Customs broker / trade counsel review | Recommended | Recommended | Recommended |
After the trade-remedy screen, compare the exact product specification, carton configuration and logistics. Zhongxin’s container-loading and landed-cost guide explains why FOB price alone is not a complete comparison. Which Incoterm a quote is built on decides who pays freight, insurance, duties and destination charges, so it should be fixed in writing before two factories are compared. Its MOQ, mold-cost and lead-time guide helps buyers normalize commercial assumptions by SKU.
Thailand is not named in the specific China/Vietnam TMFP orders. That fact does not establish that a shipment has Thailand origin or that no other duty or trade remedy applies. Country-of-origin analysis must be based on the actual manufacturing facts, not the shipping route or invoice country.
U.S. Customs and Border Protection defines country of origin by manufacture, production or growth and evaluates further processing under the applicable origin rule. Its rulings show that substantial-transformation analysis is fact-specific and considers the totality of the manufacturing circumstances. For a practical example of that analysis, see U.S. Customs and Border Protection Headquarters Ruling H325607.
For a Thailand-origin claim, the purchasing file should connect the purchase order to the real production site and contain:
Shipping from Thailand, using a Thailand invoice or performing minor finishing there does not automatically establish Thailand origin.
A useful document request identifies the product, factory and shipment together. Generic certificates or a company profile cannot answer a product-scope or origin question on their own.
| Document or data | What to verify | Why it matters |
|---|---|---|
| 1. Full legal name of manufacturer | Exact producing entity, not only the seller or brand | Connects production facts to the entry and rate review |
| 2. Factory address | Site and line proposed for the order | Distinguishes manufacturing from trading, storage or transshipment |
| 3. Product specification | Dimensions, depth, shape, weight, finish, lid and intended use | Supports comparison with the written product scope |
| 4. Material composition | Fiber sources, additives, coatings and non-fiber components | Clarifies whether “bagasse” accurately describes the complete construction |
| 5. Manufacturing process | Forming, heated molds, drying or curing, pressing and finishing | Tests the process elements in the TMFP scope |
| 6. Country-of-origin support | Production records and applicable origin analysis | Supports the declared origin with actual manufacturing facts |
| 7. Commercial invoice | Manufacturer/exporter, description, value, quantity and origin consistency | Prevents conflicts between sourcing and entry records |
| 8. Packing list | SKU, carton count, pieces, weights and marks | Connects the customs file to the physical shipment |
| 9. Certificate of origin, where applicable | Issuer, shipment, producer and supporting basis | Supports but does not replace the underlying manufacturing facts |
| 10. Supplier’s HTS classification | Code, rationale and product description | Provides a starting point for broker review, not the final scope answer |
| 11. Current AD/CVD case and rate verification | Case number, producer/exporter combination and current Commerce/CBP instructions | Avoids using an obsolete, preliminary or unrelated rate |
| 12. PO factory confirmation | Written confirmation of the site that will manufacture the order | Prevents a quoted origin from changing after sample approval |
Trade-remedy scope is separate from food-contact, PFAS and compostability verification. Use Zhongxin’s U.S. food-contact and PFAS verification guide and certificate center for those evidence tracks, but do not treat those documents as proof of an AD/CVD conclusion.
Importers cannot assume that it does. The current TMFP scope expressly includes matching products that were finished, packaged or otherwise processed in a third country when that work would not remove the merchandise from scope if performed in the country of manufacture. Listed examples include hot or after pressing, die-cutting, punching, trimming, printing, labeling, coating, laminating, embossing, repacking and denesting.
Therefore, third-country finishing, packaging, trimming, printing, embossing, repacking or similar processing does not necessarily remove subject merchandise from the scope. Transshipment, relabeling, a different invoice country or minor processing must never be used as a substitute for a supportable origin determination.
If the production chain crosses countries, provide the full manufacturing sequence to the customs broker or trade counsel. Where the written scope remains uncertain, the International Trade Administration explains the difference between a Commerce scope ruling and a U.S. Customs and Border Protection classification ruling.
Zhongxin has manufacturing capability in China and Thailand. For a proposed order, buyers can request the legal manufacturer, production site, product specification, manufacturing-origin support, available compliance documents and sample source before confirming bulk production. Zhongxin’s China and Thailand factory overview and Thailand manufacturing guide provide site-level context.
This support should be used for due diligence, not as a tariff guarantee. A U.S. importer remains responsible for obtaining the appropriate classification, scope and entry advice. Buyers evaluating more than one production route can also review the existing China–Thailand dual-source supply guide; the present article is narrower and focuses on U.S. TMFP and paper-plate trade-remedy screening.
For a useful factory-specific response, send Zhongxin:
Do not compare FOB quotations before determining whether the products are actually comparable in customs scope, origin and applicable trade-remedy treatment.
The January 27, 2026 orders list HTSUS subheadings 4823.70.0020 and 4823.70.0040. They also state that imports may be classified under 4823.61.0020, 4823.61.0040, 4823.69.0020, 4823.69.0040 and 4823.90.1000. Buyers can consult the U.S. International Trade Commission Harmonized Tariff Schedule for current tariff text.
HTS numbers are provided for convenience and customs purposes; the written scope description is dispositive. A code alone does not prove that a product is inside or outside an AD/CVD order.
Some may be, but “bagasse” alone does not decide the result. Compare the product’s cellulose-fiber construction, thermoforming and in-mold drying or curing process, characteristics, exclusions and China origin with the written TMFP scope. Plates also require a separate paper-plate scope check.
The specific TMFP orders name China and Vietnam, not Thailand. Importers must still prove the actual manufacturing origin and determine whether another trade-remedy order applies to the product.
No blanket conclusion is valid. Certain paper plates from Thailand are covered by a separate U.S. antidumping order, A-549-849, and that written scope contains product definitions and exclusions. Other duties may also apply, so verify the exact plate and current entry facts.
No. A shipping route, invoice country, repacking or minor finishing does not by itself change origin. The analysis must follow the actual manufacturing facts and the applicable origin and scope rules.
Not necessarily. Product form, depth, construction, manufacturing process and the exclusions in each written scope matter. A plate should be checked against the separate paper-plate scope before the TMFP analysis is completed.
The orders list 4823.70.0020 and 4823.70.0040 and say imports may also be classified under 4823.61.0020, 4823.61.0040, 4823.69.0020, 4823.69.0040 and 4823.90.1000. The codes are for convenience; the written scope description is dispositive.
No. Verify the current Commerce order and scope, U.S. Customs and Border Protection instructions, producer/exporter combination, classification, origin and entry facts with a customs broker or qualified trade counsel. A cash-deposit estimate is not necessarily the final landed duty.
