Statement of reasons—Final decisions: Truck Bodies (TB 2025 IN)

Concerning the final decisions with respect to the dumping and subsidizing of truck bodies originating in or exported from China.

Decision

Ottawa, June 19, 2026

On June 4, 2026, pursuant to paragraph 41(1)(a) of the Special Import Measures Act (SIMA), the Canada Border Services Agency terminated the subsidy investigation respecting the subsidizing of truck bodies originating in or exported from the People’s Republic of China by Qingdao CIMC Reefer Trailer Co., Ltd.

On the same day, pursuant to paragraph 41(1)(b) of SIMA, the Canada Border Services Agency made a final determination respecting the dumping of truck bodies originating in or exported from the People’s Republic of China.

Statement of reasons—Final decisions: Truck Bodies (TB 2025 IN)

(PDF, 749 KB)

Summary

[1] On September 5, 2025, the Canada Border Services Agency (CBSA) received a written complaint from Morgan Canada Corporation and Morgan Transit Corporation (collectively, “the complainants”) alleging that imports of truck bodies originating in or exported from the People’s Republic of China (China) are being injuriously dumped and subsidized.

[2] On September 26, 2025, pursuant to paragraph 32(1)(a) of the Special Import Measures Act (SIMA), the CBSA informed the complainants that the complaint was properly documented. On October 3, 2025, the CBSA informed the Government of China that a properly documented complaint had been filed. At that time, the Government of China was provided with a non-confidential version of the subsidy complaint and was invited for consultations pursuant to Article 13.1 of the Agreement on Subsidies and Countervailing Measures, prior to the initiation of the subsidy investigation. The CBSA did not receive any request for consultations.

[3] The complainants provided evidence to support the allegations that truck bodies from China have been dumped and subsidized, as well as evidence that discloses a reasonable indication that the dumping and subsidizing have caused injury or are threatening to cause injury to the Canadian industry producing like goods.

[4] On October 24, 2025, pursuant to subsection 31(1) of SIMA, the CBSA initiated investigations respecting the dumping and subsidizing of truck bodies from China.

[5] Upon receiving notice of the initiation of the investigations, the Canadian International Trade Tribunal (CITT) commenced a preliminary injury inquiry, pursuant to subsection 34(2) of SIMA, into whether the evidence discloses a reasonable indication that the dumping and subsidizing of the above-mentioned goods have caused injury or are threatening to cause injury to the Canadian industry producing the like goods.

[6] On December 23, 2025, pursuant to subsection 37.1(1) of SIMA, the CITT made a preliminary determination that there is evidence that discloses a reasonable indication that the dumping and subsidizing of truck bodies from China have caused or are threatening to cause injury to the domestic industry.

[7] On March 6, 2026, as a result of the CBSA’s preliminary investigations and pursuant to subsection 38(1) of SIMA, the CBSA made preliminary determinations of dumping and subsidizing of truck bodies originating in or exported from China.

[8] On the same date, pursuant to subsection 8(1) of SIMA, provisional duties were imposed on imports of dumped and subsidized goods that are of the same description as any goods to which the preliminary determinations apply, and that are released during the period commencing on the day the preliminary determinations were made and ending on the earlier of the day on which the CBSA causes the investigations in respect of any goods to be terminated pursuant to subsection 41(1) of SIMA or the day the CITT makes an order or finding pursuant to subsection 43(1) of SIMA. Where an exporter’s estimated amount of subsidy is insignificant, provisional countervailing duty will not be applied.

[9] Based on the available evidence, the CBSA is satisfied that truck bodies originating in or exported from China have been dumped. Therefore, on June 4, 2026, the CBSA made a final determination of dumping pursuant to paragraph 41(1)(b) of SIMA in respect of those goods.

[10] Based on the available evidence, the CBSA is satisfied that truck bodies originating in or exported from China by Qingdao CIMC Reefer Trailer Co., Ltd. have been subsidized by an insignificant amount. Therefore, on June 4, 2026, the CBSA terminated the subsidy investigation pursuant to paragraph 41(1)(a), in respect of those goods.

[11] The CITT’s inquiry into the question of injury to the Canadian industry is continuing, and the CITT will issue its decision by July 3, 2026. Provisional anti-dumping duties will continue to be imposed on the subject goods from China until the CITT renders its decision.

Period of investigation

[12] The period of investigation (POI) for the investigations is July 1, 2024, to June 30, 2025.

Profitability analysis period

[13] The profitability analysis period (PAP) for the investigations is July 1, 2024, to June 30, 2025.

Interested parties

[14] Interested parties were notified at the initiation of the investigations and were sent Requests for Information (RFI). Refer to the Statement of reasons—Initiation of investigations: Truck Bodies (TB 2025 IN) for additional information on interested parties.

Exporters

[15] One exporter, Qingdao CIMC Reefer Trailer Co., Ltd. (CIMC Reefer) provided substantially complete responses to the CBSA’s dumping, subsidy and section 20 RFIs and subsequent supplemental RFIs (SRFI).^{Footnote 1} On-site verification was conducted at CIMC Reefer’s premises in March 2026.

Importers

[16] One importer provided a response to the importer RFI and subsequent SRFI, Vanguard Refrigerated Trailer Co., Ltd. (Vanguard).^{Footnote 2} Verification of the information provided by Vanguard was conducted in March 2026.

Surrogates

[17] The CBSA received one response to the surrogate producer RFI and subsequent SRFIs from Morgan Truck Body, LLC (Morgan Truck Body), a producer of truck bodies in the United States.^{Footnote 3} Verification of the information provided by Morgan Truck Body was conduced in March 2026.

[18] Although Thailand was not identified as a potential surrogate country at the initiation of the investigation, the CBSA received a voluntary response from a producer in Thailand, Dee Siam Manufacturing Co., Ltd. (Dee Siam).^{Footnote 4} As part of Dee Siam’s responses to the surrogate producer RFI, the CBSA also received submissions from Dee Siam’s related suppliers, namely Dongguan CIMC Vehicle Co., Ltd.,^{Footnote 5} and CIMC Vehicle (Jiangmen) Co., Ltd.^{Footnote 6} Dee Siam and CIMC Reefer are ultimately owned by the same company, CIMC Group, which the CBSA is of the opinion is a State Invested Enterprise (SIE) that may be controlled by the Government of China. The CBSA notes that the responses from Dee Siam and its related suppliers were received over two months after the original RFI deadline.

[19] Due to the lateness of this submission, the CBSA could not examine the data provided in detail or arrange for the verification of the exporters’/producers’ information in a timely manner, in accordance with the legislative timelines pursuant to SIMA. Further, as Dee Siam purchased inputs from related parties in China, where the CBSA has initiated an inquiry into whether the conditions of section 20 exist, the CBSA finds that Dee Siam is not an appropriate surrogate for purposes of determining normal values.

Government

[20] The Government of China provided a partially complete response to the government subsidy RFI and subsequent SRFIs,^{Footnote 7} however it did not provide a response to the government Section 20 RFI. Verification of the information provided by the Government of China with respect to the subsidy investigation was conducted in March 2026.

Canadian producers

[21] Four Canadian producers provided a response to the Canadian industry profit survey RFI: Morgan Canada,^{Footnote 8} Morgan Transit,^{Footnote 9} Intercontinental Truck Body (B.C.) Inc.,^{Footnote 10} and Intercontinental Truck Body Ltd.^{Footnote 11} The CBSA also received responses to subsequent SRFIs from both Morgan Canada^{Footnote 12} and Morgan Transit.^{Footnote 13} Verification of the information provided by Morgan Canada and Morgan Transit was conducted in March 2026.

Product information

Definition

[22] For the purpose of these investigations, subject goods are defined as:

Truck bodies, having an exterior length of 8.5 feet to 32 feet, inclusively, of maximum exterior width of 103 inches, whether assembled or unassembled, being the structure or fixture designed to be affixed to a truck chassis for the primary purpose of containing or supporting goods for on-road transportation, whether insulated or not, and whether equipped with refrigerating equipment or not, as well as truck body kits, assemblies, or subassemblies, originating in or exported from the People’s Republic of China, excluding:

truck bodies for the primary purpose of bulk transporting liquids or gases
refuse truck bodies, being specialized truck bodies designed and constructed for the primary purpose of collecting, compacting, and transporting solid waste, of the kind used for municipal waste collection and
truck bodies that incorporate a hydraulic or mechanical system that permits the body to be elevated, tipped, or tilted for loading or unloading, such as dump truck bodies used for the transport of bulk materials such as sand, gravel, or demolition debris, and flatbed tow truck bodies used for the transport of vehicles

[23] Refer to the Statement of reasons—Initiation of investigations: Truck Bodies (TB 2025 IN) for additional product information, production process information and the classification of imports.

Like goods and class of goods^{Footnote 14}

[24] Subsection 2(1) of SIMA defines “like goods” in relation to any other goods as “… (a) goods that are identical in all respects to the other goods, or (b) in the absence of any such goods…, goods the uses and other characteristics of which closely resemble those of the other goods.” In considering the issue of like goods, the Canadian International Trade Tribunal (CITT) typically looks at a number of factors, including the physical characteristics of the goods, their market characteristics, and whether the domestic goods fulfill the same customer needs as the subject goods.

[25] The complainants state that subject goods and domestically produced goods are substitutable, and comparable in terms of non-price factors such as quality and availability of technical specification. The complainants further state that the goods both compete in the Canadian market, are ultimately sold through the same channels of distribution, and have the same market characteristics. The complainants submit that although domestically produced goods may not be identical to subject goods as certain models may be slightly different, their uses and characteristics are nearly identical.

[26] For the purposes of this analysis, like goods consist of domestically produced truck bodies described in the product definition.

[27] After considering questions of use, physical characteristics and all other relevant factors, the CBSA is of the opinion that subject goods and like goods constitute only one class of goods.

[28] In its preliminary injury inquiry for these investigations, the CITT further reviewed the matter of like goods and classes of goods. On January 13, 2026, the CITT issued its preliminary inquiry statement of reasons, indicating that:

"…the Tribunal sees nothing strongly supporting a finding of multiple classes of goods at this stage of the proceedings. The Tribunal will therefore conduct its analysis on the basis that truck bodies produced in Canada and meeting the product definition constitute like goods in relation to the subject goods and that there is one class of goods."^{Footnote 15}

Imports into Canada

[29] During the final phase of the investigations, the CBSA refined the estimated volume and value of imports based on information from CBSA import entry documentation and other information received from the exporter and importer.

[30] The following table presents the CBSA’s analysis of imports of truck bodies for the purposes of the final determinations:

Table 1: Import volume of truck bodies
(July 1, 2024, to June 30, 2025)
Country	% of total import volume
China	52.4%
Other	47.6%
Total	100%

Investigations process

[31] Regarding the dumping investigation, information was requested from all known and potential exporters, producers, vendors and importers, concerning shipments of truck bodies shipped to Canada during the POI.

[32] Regarding the subsidy investigation, information related to potentially actionable subsidies was requested from all known and potential exporters and producers in China. Information was also requested from the Government of China concerning financial contributions made to exporters or producers of truck bodies shipped to Canada during the POI. The Government of China was also requested to forward the RFIs to all subordinate levels of government that had jurisdiction over the exporters.

[33] The Government of China and the exporters/producers were also notified that failure to submit all required information and documentation, including non-confidential versions, failure to comply with all instructions contained in the RFI, failure to permit verification of any information or failure to provide documentation requested during the verification visits or the desk audits may result in the margin of dumping, the amount of subsidy and the assessment of dumping and/or countervailing duties on subject goods being based on facts available to the CBSA. Further, the Government of China and the exporters/producers were notified that determinations on the basis of facts available could be less favorable to them than if complete, verifiable information was made available.

[34] After reviewing the RFI responses, SRFIs were sent to responding parties, in order to clarify information provided and request additional information, where necessary.

[35] Details pertaining to the information submitted by companies in response to the dumping and subsidy RFIs, as well as the results of the CBSA’s investigations, are provided in the Results of the dumping investigation and Results of the subsidy investigation sections of this document, respectively.

[36] As part of the final phase of the investigations, case briefs and reply submissions were provided by counsel representing the complainants, the exporter of subject goods from China, and on behalf of the Government of China. A summary of the representations is provided in Appendix 2.

Dumping investigation

[37] The following presents the final results of the investigation into the dumping of truck bodies originating in or exported from China.

Normal value

[38] Normal values are generally determined based on the domestic selling prices of like goods in the country of export, in accordance with the methodology of section 15 of SIMA, or on the aggregate of the cost of production of the goods, a reasonable amount for administrative, selling and all other costs, plus a reasonable amount for profits, in accordance with the methodology of paragraph 19(b) of SIMA.

[39] Where, in the opinion of the CBSA, sufficient information has not been furnished or is not available, normal values are determined pursuant to a ministerial specification in accordance with subsection 29(1) of SIMA.

Export price

[40] The export price of goods sold to importers in Canada is generally determined in accordance with the methodology of section 24 of SIMA based on the lesser of the adjusted exporter’s sale price for the goods or the adjusted importer’s purchase price. These prices are adjusted where necessary by deducting the costs, charges, expenses, duties and taxes resulting from the exportation of the goods as provided for in subparagraphs 24(a)(i) to 24(a)(iii) of SIMA.

[41] Where there are sales between associated persons and/or a compensatory arrangement exists, the export price is based on the importer’s resale price of the imported goods in Canada to unrelated purchasers, less deductions for all costs incurred in preparing, shipping and exporting the goods to Canada that are additional to those incurred on the sales of like goods for use in the country of export, all costs included in the resale price that are incurred in reselling the goods (including duties and taxes) or associated with the assembly of the goods in Canada and an amount representative of the average industry profit in Canada as provided for in paragraphs 25(1)(c) and 25(1)(d) of SIMA.

[42] Where, in the opinion of the CBSA, sufficient information has not been furnished or is not available, export prices are determined pursuant to a ministerial specification under subsection 29(1) of SIMA.

Margin of dumping

[43] The margin of dumping by exporter is equal to the amount by which the total normal value exceeds the total export price of the goods, expressed as a percentage of the total export price. All subject goods shipped to Canada during the POI are included in the calculation of the margins of dumping of the goods. Where the total normal value of the goods does not exceed the total export price of the goods, the margin of dumping is zero.

Background of section 20 inquiries

[44] Section 20 is a provision of SIMA that may be applied to determine the normal value of goods in a dumping investigation where certain conditions prevail in the domestic market of the exporting country. In the case of a prescribed country (which includes China) under paragraph 20(1)(a) of SIMA, it is applied where, in the opinion of the CBSA, the government of that country substantially determines domestic prices and there is sufficient reason to believe that the domestic prices are not substantially the same as they would be in a competitive market.^{Footnote 16}

[45] The provisions of Section 20 are applied on a sector basis rather than on the country as a whole. The relevant sector, namely the Automobile Bodies and Trailers Manufacturing sector, includes the industry producing and exporting the goods under investigation.

[46] The complainants alleged that the conditions described in section 20 of SIMA prevail in the truck bodies industry in China. That is, the complainants allege that this industry in China does not operate under competitive market conditions and consequently, the domestic prices of truck bodies established in China would not be reliable for determining normal values.^{Footnote 17}

[47] Based on the CBSA’s research and for the purposes of this investigation, the Automobile Bodies and Trailers Manufacturing sector covers the manufacturing of truck bodies (including enclosed cargo bodies, refrigerated bodies, flatbeds, dump truck bodies, container bodies, detachable bodies etc.), bus bodies, vehicle cabs, trailers and semi-trailers (for freight, special use, etc.), chassis and body manufacturing (but not full vehicle assembly), and related vehicle body parts. As such, for the purposes of the Section 20 inquiry, the Automobile Bodies and Trailers Manufacturing sector in China, which includes the truck bodies industry, is the sector under review.

[48] In the event that the CBSA forms the opinion that domestic prices of truck bodies in China are substantially determined by the government, and that there is sufficient reason to believe that the domestic prices are not substantially the same as they would be if they were determined in a competitive market, the normal values of the goods under investigation will be determined, pursuant to paragraph 20(1)(c) of SIMA, where such information is available, on the basis of the domestic selling prices or the aggregate of the cost of production, a reasonable amount for administrative, selling and all other costs, and a reasonable amount for profits of like goods sold by producers in any country designated by the CBSA and adjusted for price comparability; or, pursuant to paragraph 20(1)(d) of SIMA, where such information is available, on the basis of the selling price in Canada of like goods produced and imported from any country designated by the CBSA and adjusted for price comparability.

[49] For the purposes of obtaining information necessary to calculate normal values pursuant to subparagraph 20(1)(c) of SIMA, the CBSA requested information from producers in surrogate countries. As such, the CBSA selected the United States (US) and Mexico as potential surrogate countries, as both countries have significant domestic production of truck bodies that compete globally and operate under fair market conditions in their domestic markets. The CBSA sent questionnaires to known producers of truck bodies in these countries.

Analysis of section 20 conditions

[50] The CBSA has previously formed the opinion that section 20 conditions existed in the dumping investigation of Container Chassis^{Footnote 18} in 2021, conducted with respect to the semi-trailer industry sector, which includes container chassis.

[51] The complainants argued that the CBSA’s persuasive evidence in Container Chassis is equally applicable to truck bodies and should lead the CBSA to the same conclusion that the Government of China substantially determines the prices of truck bodies in the Chinese market.

[52] The CBSA is of the view that container chassis, trailers and truck bodies industries share some similarities in their role as critical enablers of freight transport, and integration into the global logistics and supply chain ecosystem. Container chassis and trailers are indispensable in intermodal transport, linking ships, railcars, and trucks, while truck bodies are equally vital in last-mile delivery and regional distribution. Both serve as essential interfaces between cargo and transport vehicles, enabling efficient movement of goods across road, rail, and sea. Both industries are foundational to modern logistics, acting as the physical backbone of cargo movement.

[53] Although container chassis and truck bodies share certain functional similarities and use some of the same basic materials—primarily steel and aluminum—the cost structures of the two product categories differ substantially. For container chassis, steel represents the overwhelming majority of raw-material inputs, accounting for approximately 75% of the material inputs for container chassis.^{Footnote 19}

[54] In contrast, truck bodies incorporate a much broader range of inputs, none of which typically accounts individually for more than 10 to 15% of the material inputs total costs.

[55] Taking into account the above similarities and distinctions, some information available for the semi-trailer industry sector of the container chassis investigation with regard to the existence section 20 conditions may apply to the Automobile Bodies and Trailers Manufacturing sector.

Government control analysis

[56] This section presents the CBSA’s analysis of the extent to which, if any, the Government of China applies influence over the Automobile Bodies and Trailers Manufacturing sector within which the truck bodies industry operates, by examining the following:

Industrial plans, directives, regulations and other Government policy mandates
Government ownership and control of major producers of truck bodies
Government intervention in key raw material inputs

Industrial plans, directives, regulations and other policy mandates

National & Provincial 14th Five-Year Plans

[57] The Government of China’s Five-Year Plans are an important economic policy tool within the Chinese market economy. Within each plan, the Government of China maps out its strategies for economic development, setting growth targets and launching economic reforms with respect to key industries.

[58] The complainants stated that the Government of China is expanding its influence in the trucking industry by accelerating the construction of a ‘transportation powerhouse’^{Footnote 20} and by enhancing the competitive advantage and high quality development of the manufacturing industry.^{Footnote 21}

[59] Additionally, the complainants added that the current 14th FYP emphasizes the development of the logistics industry in several chapters. The Government of China’s stated goals are to build modern logistics, procurement and distribution, production control, operation management, and after-sales service. The following points are included in the 14th Five-year Plan for National Economic and Social Development:

“build modern logistics systems, accelerate the development of cold chain logistics, coordinate the construction of logistics hub facilities, backbone lines, regional distribution centers, and endpoint delivery nodes, improve the facilities and conditions of national logistics hubs and backbone cold chain logistics bases, improve the three-level county, township, and village logistics distribution system”.^{Footnote 22}

[60] The directives in the 14th Five-Year Plan and subsequent action plans from ministries continued to prioritize lowering logistics costs and increasing efficiency. In November 2024, the Ministry of Transport and the National Development and Reform Commission co-issued a new action plan for Reducing Costs, Improving Quality and Increasing Efficiency in Transportation and Logistics. Specifically, the plan states:

“Smooth the terminal circulation network of urban and rural logistics. Optimize and improve the urban freight service network, study and promote medium-sized vans dedicated to urban distribution…, Improve the cold chain logistics facilities at the production site and vigorously develop cold chain logistics for agricultural products.”^{Footnote 23}

[61] These plans and directives, which are closely related to the Automobile Bodies and Trailers Manufacturing sector, likely promote the development and use of truck bodies and trailers, affecting the demand and supply balance in the domestic market and therefore the domestic prices of the trucking industry and consequently the domestic prices of truck bodies.

14th Five-Year Plan Cold Chain Logistics Development

[62] The 14th FYP logistics policies stress the need to build a modern integrated transportation system for seamless integration between different categories of domestic logistics networks. The following are some of the development goals mentioned:

“accelerate the establishment of a modern cold chain logistics system that is smooth and efficient, safe and green, smart and convenient, and strongly guaranteed; improve the quality and efficiency of cold chain logistics services.”^{Footnote 24}

[63] The 14th FYP cold-chain logistics^{Footnote 25} plan highlights the steady growth of the logistics market and its development toward a more concentrated industry:

“Market entities have continued to grow… Market concentration has increased steadily, and a number of leading enterprises have formed in cold chain warehousing, transportation, distribution, and equipment manufacturing”^{Footnote 26}

[64] The 14th FYP cold-chain logistics plan aims to develop a complete infrastructure and a qualitative cold chain logistics, including refrigerated trucks:

“The level of cold chain logistics technology and equipment shall be significantly improved; the total amount of cold storage and refrigerated trucks shall maintain reasonable and stable growth; regional distribution shall be more optimized and functional types more complete.”^{Footnote 27}

[65] The 14th FYP for cold-chain logistics aims, amongst other policies, to:

“Promote the upgrading of cold chain transportation facilities and equipment: …improve the development level of refrigerated trucks… Strictly control the market access conditions for refrigerated trucks… Accelerate the development and manufacturing of light and micro new energy refrigerated trucks… {and} actively promote new refrigerated trucks.”^{Footnote 28}

“Accelerate the process of green development:…Research and formulate energy efficiency standards for cold storage, refrigerated trucks, etc.,… Improve the thermal insulation and flame retardant properties of thermal insulation materials for cold storage, refrigerated trucks, etc.,…encourage the use of green, safe, energy saving, and environmentally friendly refrigerated trucks and supporting equipment and facilities,… Accelerate the elimination of high-emission refrigerated trucks to meet the needs of urban green distribution development, and encourage new or updated refrigerated trucks to adopt new energy models.”^{Footnote 29}

[66] The complainants submitted that the FYP cold-chain logistics plan has spurred a range of related Government of China measures:

The National Development and Reform Commission issued the Implementation Plan for the Construction of the National Backbone Cold Chain Logistics Bases, which specified systematic arrangements for the layout and construction of the national backbone cold chain logistics bases during the “14th Five-Year Plan” period^{Footnote 30}
In February 2022, the All China Federation of Supply and Marketing Cooperatives issued the 14th Five-Year Plan Development Plan for the Cold Chain Logistics of Public Agricultural Products, which specified the layout of cold chain logistics in the field of agricultural products^{Footnote 31}
Also in April 2022, the Ministry of Transport and five other departments jointly issued the Implementation Opinions on Accelerating the High-quality Development of Cold Chain Logistics Transportation, which proposed to cultivate key cold chain transportation enterprises and established a number of well-known cold chain transportation service brands^{Footnote 32}

[67] According to the plans and directives outlined above, developing cold chain logistics infrastructure is crucial for promoting regional and rural transportation, as well as last-mile delivery in China. In this regard, it is evident that the Chinese government has implemented several specific policies to promote the development and use of refrigerated trucks, including their truck bodies. These policies likely affect domestic supply and demand in the domestic market and alter domestic prices for Automobile Bodies and Trailers.

14th Five-Year Plan Clean Energy Infrastructure

[68] The complainants also submitted that the Government of China has fostered the development of the domestic new energy vehicle (NEV) industry as one of China’s strategic emerging industries.^{Footnote 33} The complainants added that the Government of China has actively introduced various policies and standards to promote the development of the Chinese NEV industry, including subsidies, and sales tax exemptions, and continues to increase infrastructure construction, invest in the construction of NEV charging infrastructure, and promote the construction and operation of charging facilities.^{Footnote 34}

[69] The complainants argued that the impact on the truck body sector has been direct due to demand for Class 4-7 NEV vehicles equipped with truck bodies: policies such as the 14th FYP clean energy infrastructure have pushed sales of new energy refrigerated trucks to 21,368 units in 2024, a year-on-year increase of 350.8%.^{Footnote 35}

[70] The directives in the 14th Five-Year Plan and subsequent action plans from ministries continued also to promote new energy vehicles and clean transportation. The new action plan for Reducing Costs, Improving Quality and Increasing Efficiency in Transportation and Logistics, co-issued in November 2024 by the Ministry of Transport and the National Development and Reform Commission, promotes freight decarbonization by prioritizing two main areas: building zero-emission truck fleets and tracking carbon outputs. Key initiatives under the plan include expanding networks for vehicle charging and for swapping batteries to support adoption of electric trucks.^{Footnote 36}

[71] The use of such policies and measures likely affect the demand and supply balance in the domestic market and therefore the domestic prices in the trucking industry and consequently the domestic prices of truck bodies.

Other incentive measures and financial support

[72] Beyond the National & Provincial 14th FYP policies, the Government of China expanded incentives for scrapping and replacing transportation equipment in 2025.

[73] In January 2025, the National Development and Reform Commission and the Ministry of Finance of China jointly released a Notice on Enhancing and Expanding the Implementation of the Large-scale Equipment Renewal and Trade-in of Consumer Goods Policies in 2025. This 2025 Program is the second phase of the Large-scale Equipment Renewal and Consumer Goods Trade-in Program initiated in 2024.

[74] This program provides national-level incentives to promote the scrappage and replacement of old passenger cars, trucks, buses, ships, off-road agricultural machineries, and other consumer goods. The 2025 Program extends incentives to the scrapping of old commercial diesel trucks with emission standards at or below China IV, an expansion from China III and below.^{Footnote 37}

[75] Truck owners continue to receive subsidies for their early scrapping of old trucks before the mandatory retirement age and can receive additional subsidies for replacing them with new China VI trucks or new energy trucks, with the total subsidy amounts ranging from ¥10,000 to ¥140,000.^{Footnote 38}

[76] These programs and incentive measures cited above are promoting large-scale equipment upgrades and trade-ins in the transportation sector which in turn increase the investment in the purchase of transportation equipment and machinery in the Chinese economy. The use of such policies and measures can likely affect the demand and supply balance in the domestic market and therefore the domestic prices in the trucking industry and consequently the domestic prices of truck bodies.

Special refinancing for transportation and logistics

[77] The complainants submitted that even prior to 2021 and the adoption of this sector specific five-year plan for cold-chain logistics, the Government of China was “paying unprecedented attention to the development of the cold chain,”^{Footnote 39} with one report noting the existence of financial subsidies for the development of the cold chain logistics industry from the Department of Commerce and the Department of Finance of Guangdong.^{Footnote 40}

[78] In February 2023, the People’s Bank of China, the Ministry of Transport and the China Banking and Insurance Regulatory Commission jointly issued the Notice on Further Improving Financial Support and Services in the Field of Transportation and Logistics driving the high-quality development of the transportation and logistics industry and the construction of a transportation power. The report to the 20th CPC National Congress stresses the needs to accelerate the building of China into a country with strong transportation networks, build an efficient and smooth circulation system, and reduce logistics costs.^{Footnote 41}

[79] The Notice requires that banking institutions should improve their organizational guarantee and internal incentive mechanisms, innovate and enrich credit products that meet the needs of the transportation and logistics industry, and earnestly increase credit support. The following points are included in the notice:

“The models of proactive credit granting and pay-as-you-go lending shall be actively promoted to better meet the needs of market participants for using funds for business purposes… Banking financial institutions shall be encouraged to, on the premise of compliance with laws and regulations and controllable risks, reasonably determine the down payment ratios, loan interest rates and repayment periods of truck loans, and appropriately enhance the tolerance of truck loans and other non-performing loans in the transportation and logistics industries during the specific periods of the COVID-19 pandemic and economic recovery, and specify and implement the institutional arrangements for exemption from liabilities for due diligence.”

[80] This aims to strengthen the financing support for policy-oriented development of financial instruments to invest in transportation and logistics projects, and encourages banking institutions to provide financial support for improving the layout of comprehensive transportation network, executing major projects in the 14th Five-Year Plan. The Notice points out that qualified provinces and cities should actively increase supporting policies such as interest subsidy, guarantee and credit enhancement.^{Footnote 42}

Belt and Road Initiative and Made-in-China 2025 Initiative

[81] The Belt and Road Initiative (BRI), introduced in 2013, is a strategic program aimed at enhancing global connectivity through infrastructure projects across Asia, Europe, Africa, and adjacent seas. The One Belt One Road Action Plan of 2015 outlines its goals, including integrating China further into the global economic system and leveraging regional comparative advantages to strengthen national and global economic ties.^{Footnote 43} Unlike the FYPs, the BRI distinguishes itself through its international scale and infrastructure focus, though it remains embedded in China's overall planning framework. The 14th FYP itself dedicates a whole chapter called Promote high-quality ‘Belt and Road’ development to the BRI.^{Footnote 44}

[82] The complainants submitted that, in CBSA’s section 20 analysis in Container Chassis, and in respect of the Belt and Road and Made-in-China 2025 initiatives, CBSA stated that:

“{a}s a manufacturer of containers, semi-trailer and other transportation products that are essential to China’s global trade network, CIMC plays a pivotal role in this policy agenda of the GOC.”^{Footnote 45}

Further, CBSA stated that: CIMC has directly benefited from the demand for containers and semi-trailers created by Chinese-led logistics networks BRI. This increase in demand is not limited to only containers, it would also directly benefit CIMC’s sales of ancillary products such as subject container chassis and other semi-trailers as overland trade by road transport brings significant new demand for those products. {emphasis added}^{Footnote 46}

[83] Additionally, the 14th FYP cold-chain logistics plan signals the pivotal role of the BRI in creating new opportunities for cold chain logistics development:

“Implementing high-level opening up creates new opportunities for cold chain logistics development: Adhering to broader, wider, and deeper opening up—especially by thoroughly advancing Belt and Road cooperation and promoting the establishment of a high-standard free trade zone network oriented toward the globe—shall further optimize the regional supply chain environment, effectively leverage China’s super-large-scale market advantages, deepen trade exchanges with relevant countries, expand food import and export scale, promote alignment of domestic and international cold chain logistics standards, learn and disseminate advanced cold chain logistics technologies and management experience, and promote high-quality development of cold chain logistics.”^{Footnote 47}

[84] The use of such policies and measures likely affect the demand and supply balance in the domestic market and therefore the domestic prices in the trucking industry and consequently the domestic prices of truck bodies.

Vehicle industry investment regulations

[85] The complainants submitted that the 2019 Administrative Regulation on Investment in the Automotive Industry directed investment in the automotive industry into green, fuel-efficient transportation technology, established broad government control of production capacity, research and development activities, and access by new market entrants. The regulation imposed a range of restrictions, aiming to control “new capacity of traditional fuel vehicles, actively promote the development of new energy vehicles, and strive to build an innovative development system for smart vehicles”.^{Footnote 48}

[86] The Automotive Industry Regulation confirms that investments in special-purpose vehicles and trailer investment projects are subject to restrictions:

“Article 28: Relevant requirements for special-purpose vehicles and trailer investment projects: (1) For new investment projects of special-purpose vehicles and trailer enterprises, the corporate legal person shall establish a product research and development organization, have a professional research and development team, have relevant research and development experience, and have technical research and development of special devices (2) It is forbidden to build new warehouse trucks, pallet trucks, dump trucks and ordinary vans and other general transport vehicles and general transport trailer enterprises investment projects; (3) Special vehicle companies are not allowed to build various types of vehicles Automobile chassis and complete vehicle production capacity, except for the self-made chassis of special operation vehicles”.^{Footnote 49}

[87] The complainants argued that the impact of these regulations and policies is consistent with section 20 factors, as they demonstrate the Government of China’s strict regulation of production, investment, and research and development expenditures in truck bodies, which may have the effect of distorting market prices.

[88] In its response to the section 20 RFI about the Vehicle Industry Investment Regulations, CIMC Reefer explains that these regulations are generally available and equally apply to all vehicle industries and recognizes that there are certain requirements for investment projects for special-purpose vehicles and trailers.^{Footnote 50}

[89] The Regulations provide a clear restriction that bans new investments in the sector:

“Article 28.2.: It is forbidden to invest in new ordinary special-purpose vehicles for transportation and general transportation trailer enterprises such as stake trucks, flat bed, dumper and ordinary vans”.^{Footnote 51}

[90] Article 28 of the regulations lists requirements for investment projects for trailers and special-purpose vehicles, which include various truck bodies. These requirements, which impose technical barriers and limit certain new market entrants, demonstrate the Government of China’s intention to promote and direct investment in certain trailers and truck bodies products and this may have the effect of distorting market prices in the Automobile Bodies and Trailers Manufacturing sector.

[91] The transportation and the modern logistics industry are identified in the 2024 Government of China Catalogue as categories of manufacturing that are important to the real economy and which promotes new industrialization.^{Footnote 52}

[92] More specifically, the Government of China has outlined targets to establish a high-end, intelligent, and green manufacturing industry while consolidating the leading position of advantageous industries, such as increasing the proportion of production capacity and expanding high-quality supply and scaling-up security capabilities, notably related to food and energy. The 2024 Catalogue identifies plans to upgrade and renovate highway and road transportation systems to develop highway intelligent transportation system, freight transportation which feature green infrastructure construction strategies^{Footnote 53} and the construction of the cold chain logistics of agricultural products, food and medicines.^{Footnote 54}

[93] The production of truck bodies, particularly refrigerated truck bodies, is integral to the Government of China’s plans for the development of China’s national cold chain logistics base. In pursuit of these objectives, the 2024 Catalogue contemplates necessary industrial structural adjustments to applicable fiscal, taxation, credit, land, import and export, and market supervision policies.^{Footnote 55}

[94] Based on the CBSA’s review of the above evidence presented in the complaint and its own analysis and taking into account the submissions made by CIMC Reefer, the CBSA finds that there through government plans, directives and regulations in the Automobile bodies and Trailers Manufacturing sector, which includes truck bodies, the government of China likely affect the demand and supply balance in the domestic market and therefore the domestic prices in the trucking industry and consequently the domestic prices of truck.

Government ownership and control of major producers

[95] The complainants submitted that the CBSA should find that the Government of China exercises substantial ownership and control over key producers of truck bodies, namely China International Marine Containers (Group) Co., Ltd. (CIMC Group) and Sinotruk Group.

[96] The complainants argued that CIMC Group is the largest manufacturer of truck bodies in China and that the information reasonably available to the complainants suggest that CIMC’s subsidiary CIMC Vehicles is likely the CIMC Group subsidiary producing truck bodies.

[97] The CBSA was unable to verify and confirm that CIMC Group is the largest producer of truck bodies in China since the Government of China did not respond to the section 20 RFI. Additionally, the cooperative exporter, CIMC Reefer (a company wholly owned by CIMC Vehicles), did not provide any market insight or sufficient information about domestic production and market share in China.

[98] However, according to CIMC Vehicles (which is controlled by CIMC Group as a major shareholder with 61.34% interest), they sold over 140,000 vehicles of various types globally in 2025. Based on 2025 global ranking of semi-trailer manufacturers by production volume, released by Global Trailer, CIMC Vehicles ranked first worldwide for the thirteenth consecutive year.^{Footnote 56}

[99] The complainants added that CIMC Group and its subsidiaries are controlled by the Government of China through a complex corporate structure. The complainants argued that CBSA found CIMC Group was a state-owned enterprise in CBSA’s section 20 analysis in Container Chassis, which had previously been publicly indicated by the State-owned Assets Supervision and Administration Commission of the State Council (SASAC), with the Government of China ultimately controlling CIMC Group through SASAC.^{Footnote 57}

[100] The State-Owned Assets Supervision and Administration Commission (SASAC), a body of the State Council, oversees the management, performance, and restructuring of central SOEs, acting both as the government’s representative and as an investor. Its role includes appointing and evaluating enterprise leaders, guiding SOE reforms and mergers, and exercising control through investor rights rather than administrative authority.

[101] The complainants submitted that CIMC’s two largest shareholders are Shenzen Capital Holdings Co. Ltd. (Shenzen Capital) (24.64%) and China Merchants (CIMC) Investment Limited (China Merchants) (24.49%). Shenzen Capital and China Merchants are both ultimately owned by SASAC.^{Footnote 58}

[102] The Government of China did not respond to the section 20 RFI. Moreover, there is limited public information available about Chinese Automobile Bodies and Trailers Manufacturers or truck bodies producers other than the response from the cooperative exporter/producer CIMC Reefer, a subsidiary of the CIMC group. Consequently, the CBSA’s analysis focused on the Government of China’s control of CIMC Reefer.

[103] In its response to section 20 RFI, CIMC Reefer, which is owned by CV Group, states that it is not state-owned nor has state-owned interests.

[104] CIMC Reefer is a Chinese manufacturer and exporter of reefer trailers and truck bodies, owned by CV Group, with 62.24% direct ownership and 37.75% indirect ownership through CV Group’s subsidiary, CIMC Vehicle Investment Holdings Co., Ltd. (CV BVI). CV BVI, a holding company, is wholly owned and controlled by CV Group.

[105] CV Group is a publicly listed company on the Shenzhen Stock Exchange, which is in turn controlled by CIMC Group, with 61.34% interest in CV Group (combined 38.87% direct and 22.26% indirect interests through a fully owned subsidiary, CIMC HK).

[106] None of the other CV Group’s shareholders own more than 5% shareholding interests.^{Footnote 59}

[107] CIMC Group was founded in 1980 as a joint venture, under the leadership of Shenzhen State-owned Assets Supervision and Administration Commission, invested by China Merchants Group and East Asiatic Company (Denmark) in Shenzhen. It came to be publicly listed in Shenzhen Stock Exchange in 1994 and in Hong Kong Stock Exchange in December 2012. Currently, CIMC Group is a publicly listed company (public A+H share listed company), whose main shareholders are Shenzhen Capital and China Merchants Group.^{Footnote 60}

[108] The shareholding structure between CIMC Group and its substantial shareholders, as presented below, was illustrated in CIMC Group’s annual report published on December 31, 2024^{Footnote 61} and on CIMC Group’s website, as of June 30, 2025:^{Footnote 62}

Text version

24.64%: State-owned assets supervision and administration commission of Shenzhen Municipal People's Government
- Shenzhen Capital Holdings Co., Ltd.
- 20.00%:
  - Shenzhen Capital International Company Limited
  - Shenzhen Capital (Hong Kong) Container Investment Co., Ltd.
24.49%: State-owned assets supervision and administration commission of the state council
- China Merchants Group Limited
- China Merchants Steam Navigation Company Limited
- China Merchants Holdings (Hong Kong) Company Limited
- China Merchants Industry Holdings Company Limited
- SOARES LIMITED
- China Merchants (CIMC) Investmant Limited
38.06%: Other A shareholders
12.81%: Other H shareholders

[109] Shenzhen Capital is a state-owned capital operation platform and auxiliary platform established by the Shenzhen State-owned Assets Supervision and Administration Commission to promote the transformation of state-owned asset management from asset management to capital management and to advance the overall capital operation strategy of Shenzhen's state-owned assets. The company provides services focused on managing and growing state-owned assets through mergers and acquisitions, equity investments, industrial fund management, and market value enhancement. Shenzhen Capital is an important entity for expanding the industrial chain of municipal state-owned assets. Its controlled and participating companies cover many fields, including green building, intelligent manufacturing, new energy, securities, insurance, funds, and guarantees, forming an industrial layout mainly based on emerging industries and financial institutions.^{Footnote 63}

[110] China Merchants Group is a large, diversified Chinese state-owned conglomerate with long-standing operations in shipping, ports, logistics, finance, and related infrastructure; it plays an active role in maritime and trade-related sectors and hosts a number of listed subsidiaries and affiliates.^{Footnote 64}

[111] Both entities, China Merchants Group and Shenzhen Capital, are ultimately government-controlled or government-affiliated rather than purely private: China Merchants is a central SOE supervised by the Chinese government, and Shenzhen Capital was established by and remains affiliated with the Shenzhen municipal government, so their ownership and strategic direction are tied to public authorities.

[112] In addition to ownership, the complainants submitted that the evidence suggests that CIMC Group’s governance and management are also controlled by the Government of China. The complainants argued that the ruling Communist Party of China (CPC) forms an integral part of SOEs, and that the CPC places CPC committees at the executive level of SOEs, including SOEs like CIMC Group’s substantial shareholders, Shenzhen and China Merchants.^{Footnote 65}

[113] The role of the CPC committees with respect to SOEs or SIEs may allow the CPC to exercise control and influence over these entities.

[114] In CIMC Group’s case, Zhu Zhiqiang is currently the Vice-chairman and non-executive Director. Zhu Zhiqiang is also the Deputy Secretary of the Party Committee and the general manager and a director of Shenzhen Capital. He has previously held the roles of deputy chief of the enterprises division I, deputy chief and chief of the strategic development of SASAC. Sun Huirong remains a member of the Party while also serving as a Non-Executive Director for CIMC Group and as the Director of the Asset Management Department of Shenzhen Capital. He has previously held the positions of Senior Manager, Deputy Director of the Strategic Research & Mergers and Acquisitions Department, the Deputy Director of the Asset Management Department and the Director of the Audit Department of Shenzhen Capital.

[115] In its response to the section 20 RFI, CIMC Reefer stated that Youhui Shen is the head of the Chinese Communist Party (CCP) representatives of CIMC Reefer. He served in this role throughout the POI while also acting as the Sales director of domestic market and was discharged from the position since July 1, 2025. CIMC Reefer indicated that neither Youhui Shen nor any other CCP representative within the company has any influence on CIMC Reefer’s operations because of their role as CCP representatives.^{Footnote 66}

[116] CIMC Reefer stated that no members of the board of directors or supervisory body are representatives or employees or appointees of the Government, nor were they appointed or recommended by the Government of China.^{Footnote 67}

[117] CIMC Reefer also indicated that none of the members of the board of CV Group, which ultimately owns CIMC Reefer, are representatives, employees or appointees of the Government of China.^{Footnote 68}

[118] It is the CBSA’s opinion that where a government entity holds a majority equity ownership, or alternatively a substantial equity ownership such as a dominant minority block, whether directly or indirectly, this interest in and of itself indicates that the government exercises or has the potential to exercise control over the company’s operations generally. This may include control over, for example, the selection of board members, management and the profit distribution. Therefore, it is the CBSA’s opinion that information on the record reasonably supports the argument that CIMC Reefer, a joint venture company that is ultimately owned by CV Group, which is in turn owned by another publicly listed company CIMC Group, is an SIE that may be controlled by the Government of China through multiple intermediates and ultimately by SASAC.

[119] Based on the CBSA’s review of the above evidence presented in the complaint and its own analysis, the CBSA further finds that the presence of a state-invested enterprise (SIE), namely CIMC Group and its subsidiary CIMC Reefer, in the Automobile Bodies and Manufacturing Trailers sector, which happen to be a major market player that produces truck bodies, suggests that Government of China has substantial ownership which may lead to control over key producers of Automobile Bodies and Trailers, including truck bodies.

Government influence on pricing of key inputs

[120] Since 2007, the CBSA has conducted 15 investigations within the steel sector in China along with five administrative reviews involving non-market economy inquiries on Chinese steel products. In all instances, information available to the CBSA indicated that there was reason to believe that section 20 conditions existed in the listed sectors of the steel industry in China and accordingly, the CBSA was of the opinion that the conditions of section 20 were present in these product segments of the Chinese domestic steel sector.

[121] Similarly, previous findings of distortions in the aluminum sector by other investigative authorities show that Chinese aluminum producers benefit from substantial financial and non-financial support, primarily from SOEs and banks. Major beneficiaries of financial support include SOEs and large private firms such as China Hongqiao Group and China Zhongwang. Preferential financing measures include cheap loans, free credit lines, bonds at low rates, export credit insurance, and government grants for industrial development. Tax exemptions and reductions cover areas such as corporate tax discounts, R&D offsets, VAT exemptions, and import tariff rebates. The government provides land and electricity at below-market rates, further supporting aluminum producers.

Subsidized Steel and Aluminum Distorts the Cost of Production for Chinese Truck Bodies

[122] The complainants submitted that Government of China’s subsidization of the steel and aluminum sectors in China are reflected in the price of finished truck bodies sold into the Chinese market.

[123] The complainants argued that, depending on the model, steel and aluminum accounts for a significant part^{Footnote 69} of the material inputs for truck bodies.

[124] Therefore, the complainants argued that the heavily subsidized steel and aluminum supplied by Chinese steel and aluminum producers to the truck body industry creates a cost base that does not reflect competitive market conditions.^{Footnote 70} The complainants added that the CBSA has consistently found that section 20 conditions exist in relation to both commodity steel and aluminum products themselves and manufactured derivative products, as per the recent Wire Rod investigation.^{Footnote 71}

Government Maintains a Significant Degree of Ownership in the Steel and Aluminum Sectors

[125] The complainants submitted that many of the largest Chinese producers of steel and steel products are SOEs. For instance, China Baowu Steel Group, by far the world’s largest steel-producing company in 2025, is wholly owned by China’s SASAC. Similarly, Ansteel Group, the world’s third largest producer of steel, and Hesteel Group, the world’s fifth largest producer of steel, and Shougang Group, the world’s ninth largest producer of steel, are wholly state-owned.^{Footnote 72}

[126] In the aluminum sector, the complainants submitted that SOEs are estimated to account for approximately 50% of total primary aluminum output in China. The complaints pointed out that of the three Chinese companies that appear among the world’s ten largest producers of aluminum, two – China Power Investment Corporation and Chalco – are wholly state owned.

[127] The Government of China’s extensive ownership and control of the majority of large Chinese steel and aluminum producers means that these companies likely produce and market steel and aluminum according to Government of China’s objectives and policies instead of market conditions. These major steel and aluminum SOEs in China are capable of producing the types of steel and aluminum inputs used for the Automobile Bodies and Trailers production. Consequently, they can sell various steel and aluminum products such as steel plate, beams and aluminum sheets or profiles, directly used by Chinese truck bodies producers, at non-market prices.

Government Policy Measures Distort Domestic Prices for Steel and Aluminum

[128] The complainants submitted that a variety of national, provincial and municipal level policies distort prices for steel and aluminum, and derivative products made from those metals. The complainants argued that both steel and aluminum sectors are expressly targeted by the Government of China’s 14th FYP on Developing Raw Material Industry (Raw Materials FYP). The Raw Materials FYP notes that the Government of China shall “promote the development of industries such as steel” and “explore the establishment of peak production mechanism for industries such as steel”. In its most recent annual report, the Government of China noted that it would “continue to regulate crude steel output and promote restructuring of the steel industry through output reduction.”^{Footnote 73}

[129] The complainants added that, in Aluminum Extrusions, the CBSA found that “while the Government of China does not directly set or control the prices” of the downstream product at issue in that case, it was “clear that the Government of China exerts a substantial degree of influence over the aluminum industry in China through its industrial policy measures.”^{Footnote 74} On that basis of a range of policy measures, regulations controlling productions levels, preferential financing and subsidies, and the control of import and export levels, the CBSA concluded that there was sufficient evidence to conclude that domestic prices of aluminum extrusions were substantially determined by the Government of China.^{Footnote 75}

[130] During its most recent trade policy review of China, the WTO found that the Government of China was engaged in government support for aluminum, which is “likely to have global repercussions.”^{Footnote 76}

[131] The complainants also submitted that the linkage between the raw material-related policy and the automotive and trucking industry is likewise recognized by the Government of China, which has expressly recognized the importance of scaling-up its “development of non-metallic composite materials, high-strength lightweight alloys, high-strength steel and other lightweight materials for the body, parts, and vehicles, and full-function and high-performance vehicle control systems.”^{Footnote 77}

[132] Consequently, the complainants argued that the CBSA’s prior assessment of both steel and aluminum sectors indicate that these sectors are distorted by the Government of China and as a result, prices in China’s domestic market for those commodities are not the same as they would be in a market economy. The complainants submitted that the CBSA should conclude that prices for these two key inputs in the production of truck bodies are unfairly distorted in the Chinese economy.

[133] Based on the CBSA’s review of the above evidence presented in the complaint, the CBSA finds that the degree of subsidization in the steel and aluminum sectors, the significant presence of state-owned and state-controlled enterprises in those sectors, as well as government policies applicable to those sectors likely result in the provision of steel and aluminum inputs to truck bodies producers at distorted prices. This constitutes another form of the significant influence exerted by the Government of China on pricing for Chinese truck bodies.

Summary of government control analysis

[134] As indicated in the previous subsections of this section 20 report, the CBSA has found that the Government of China exerts a pervasive influence in the Automobile Bodies and Trailers Manufacturing sector, which includes the truck bodies industry, likely affecting supply and balance conditions and pricing.

[135] The CBSA analyzed the Government of China’s major macro-economic policies, plans and regulations pertaining to the Automobile Bodies and Trailers Manufacturing sector, which are the 14th Five-Year Plan on National Economic and Social Development, the 14th Five-Year Plan Cold Chain Logistics Development, the 14th Five-Year Plan Clean Energy Infrastructure, the Belt and Road initiative, the Vehicle Industry Investment Regulations, and other incentives policies and financial support.

[136] The Government of China’s policies, plans, and initiatives detailed above indicate the fact that the Government of China is promoting and developing the transportation sector, the Automobile Bodies and Trailers Manufacturing sector industry and the Cold Chain logistics sector with support from related steel and aluminum industries in China.

[137] The Government of China’s influence in the Automobile Bodies and Trailers sector is further evidenced by its role in regulating vehicle investment through the Vehicle Industry Investment Regulations, including controls on production capacity, research and development activities, and access by new market entrants. These measures allow the government to influence production levels and the number of producers in the market.

[138] In addition to the industrial policies and plans, the Government of China may also exert significant influence through Chinese state ownership of the Automobile Bodies and Trailers producers and upstream enterprises involved in the supply of steel and aluminum inputs and indirect subsidization of truck bodies subassemblies through upstream steel and aluminum industries.

[139] No information was presented during the course of the investigation proceedings that contradicts the presence of section 20 conditions in the Automobile Bodies and Trailers Manufacturing sector in China, including truck bodies. Aa a result, and without the response from the Government of China, the CBSA relied on its own evidence, analysis and adverse facts to make its section 20 decision.

[140] The CBSA has concluded that through each of these types of measures it is likely that the Government of China affects the supply and demand conditions and thereby the pricing in the Automobile Bodies and Trailers Manufacturing sector, including the truck bodies industry. When considered together, the CBSA comes to the conclusion that, through all of the above-mentioned measures, the Government of China substantially determines the prices in the Automobile Bodies and Trailers Manufacturing sector, including the truck bodies industry.

Price analysis

[141] Having found that the domestic prices are substantially determined by the Government of China, the CBSA has examined whether domestic prices are not substantially the same as they would be if they were determined in a competitive market. The CBSA conducted a comparative domestic price analysis of truck bodies.

[142] The CBSA was unable to find representative pricing data for truck bodies sold in China from any publicly available sources.

[143] In its price analysis, the CBSA relied on the responses from one producer that provided a domestic sales database, CIMC Reefer.^{Footnote 78} The CBSA analyzed price information contained in the domestic sales database of CIMC Reefer’s submission to further assess whether the domestic price of truck bodies sold by CIMC Reefer is distorted compared to other competitive markets.

[144] The CBSA also relied on the response from one surrogate producer in the U.S., namely Morgan Truck Body, LLC,^{Footnote 79} in its pricing analysis.

[145] The CBSA compared CIMC Reefer’s Chinese domestic truck bodies weighted average net selling prices with those of the U.S. surrogate producer. The CBSA also compared the Chinese domestic truck bodies weighted average net selling prices with those of similar models that closely resemble each other of the surrogate U.S. producer, sold by trade-level type (Distributor and End-user).

[146] Both results showed that prices of truck bodies sold domestically in China during the POI were significantly lower than prices in the United States. This suggests that pricing in the Automobile Bodies and Trailers Manufacturing sector is also not substantially the same as it would be if it were determined in a competitive market.

[147] Thus, based on information on the record, there is sufficient reason to believe that domestic prices of truck bodies in China are not substantially the same as they would be if they were determined in a competitive market.

Results of the section 20 inquiry

[148] In the absence of cooperation from the Government of China, the CBSA relied on the information available, including information from the complainants and from the one exporter from which responses were received. Based on the information on the record and the above analysis, for the purposes of the final determination, the CBSA has formed the opinion that the conditions of paragraph 20(1)(a) of SIMA exist in the Automobile Bodies and Trailers Manufacturing sector in China:

domestic prices in the Automobile Bodies and Trailers Manufacturing sector in China, which includes truck bodies, are substantially determined by the Government of China and
there is sufficient reason to believe that the domestic prices are not substantially the same as they would be in a competitive market

Results of the dumping investigation

Cooperative exporters

[149] As part of the section 20 inquiry, the CBSA identified the United States, and Mexico as reasonable surrogate countries for China, as they produce comparable goods, have globally competitive producers, and operate under market conditions. Surrogate RFIs were sent to 28 potential producers and exporters of truck bodies in the United States and Mexico. The CBSA received a response to the Surrogate Producer RFI from Morgan Truck Body, a producer of truck bodies in the United States.^{Footnote 80} However, there was not sufficient information to determine normal values for like goods pursuant to paragraph 20(1)(c) of SIMA.

[150] As part of the section 20 inquiry, the RFIs sent to importers requested information on re-sales in Canada of truck bodies imported from sources other than China. The CBSA received one response to the importer RFI; however, the importer did not provide information concerning the purchase and/or resale of like goods from non-named countries.

[151] For CIMC Reefer, the only exporter that submitted a substantially complete response to the dumping RFI, normal values were determined pursuant to a ministerial specification in accordance with subsection 29(1) of SIMA. The determination of normal values follows a methodology similar to that of section 20 of SIMA, based on cost of production information available on the record, using the United States as the surrogate country.

[152] During the POI, all of the subject goods exported to Canada by CIMC Reefer were sold to a related importer, Vanguard. Due to the relationship between the parties involved in the export sales, a reliability test was performed by comparing the export prices determined in accordance with section 24 of SIMA, to the export prices determined in accordance with paragraph 25(1)(d) of SIMA. The test revealed that export prices under section 24 were found to be reliable, and therefore, export prices for CIMC Reefer were determined using the methodology of section 24 of SIMA, as described in the Export price section above.

[153] The total normal value compared to the total export price results in a margin of dumping of 119.4% for CIMC Reefer, expressed as a percentage of the export price.

All other exporters

[154] Although no evidence was found that other exporters exported subject goods to Canada during the POI, anti-dumping duty is applicable should new exporters begin selling subject goods to Canada.

[155] In establishing the methodology for determining the normal values and export prices for all other potential exporters, the CBSA considered all of the information on the administrative record, including the complaint filed by the domestic industry, information submitted by parties who responded to the dumping RFI and surrogate producer RFI, and CBSA customs entry documentation.

[156] The CBSA decided that the normal values determined for all other potential exporters of subject goods from China would be determined based on information from the exporter in China that provided a substantially complete RFI response for purposes of the final determination. The CBSA finds this information to be more relevant and reflective of the trading practices of exporters in China than the information provided in the complaint or estimated at initiation.

[157] Based on the facts available, for all other potential exporters that did not provide a substantially complete response to the dumping RFI, normal values of subject goods originating in or exported from China were determined based on the highest amount by which a normal value exceeded the export price (expressed as a percentage of the export price), on an individual transaction basis made by the cooperative exporter during the POI. The transactions were examined to exclude anomalies, such as very low volumes and values, effects of seasonality, or other business factors. This methodology relies on information related to goods that originated in China (for the export price) and from the surrogate country (for the normal value).

[158] The CBSA considered that the information submitted on the CBSA customs entry documentation was the best information on which to determine the export price of the goods as it reflects actual import data.

[159] Using the above methodologies, for the final determination, the margin of dumping for all other potential exporters is 257.1%, expressed as a percentage of the export price.

Summary of final results: Dumping

[160] A summary of the final results of the dumping investigation respecting all subject goods shipped to Canada during the POI are as follows:

Table 2: Summary of final results—Dumping
Period of investigation (July 1, 2024, to June 30, 2025)
Exporter	Margin of dumping (% of export price)	% of total imports (by volume)
Qingdao CIMC Reefer Trailer Co., Ltd.	119.4%	52.4%

[161] In order to make a final determination of dumping, the CBSA must be satisfied that:

the subject goods have been dumped and
that the margin of dumping of a particular exporter is not insignificant

[162] Under paragraph 41(1)(a) of SIMA, the CBSA is required to terminate an investigation in respect of any goods of an exporter if it is satisfied that the goods have not been dumped or the margin of dumping of the goods of that exporter is insignificant, meaning a margin of dumping that is less than 2% of the export price of the goods.

[163] The margin of dumping of truck bodies determined for all exporters of subject goods originating in or exported from China is greater than the threshold of 2% and is therefore not considered insignificant. As a result, the legislative requirements are satisfied for making a final determination of dumping respecting truck bodies originating in or exported from China.

[164] A summary of the results of the dumping investigation respecting the subject goods released into Canada during the POI is presented in Appendix 1.

Subsidy investigation

[165] In accordance with section 2 of SIMA, a subsidy exists where there is a financial contribution by a government of a country other than Canada that confers a benefit on persons engaged in the production, manufacture, growth, processing, purchase, distribution, transportation, sale, export or import of goods. A subsidy also exists in respect of any form of income or price support within the meaning of Article XVI of the General Agreement on Tariffs and Trade, 1994, being part of Annex 1A to the World Trade Organization (WTO) Agreement that confers a benefit.

[166] SIMA defines “government” in subsection 2(1) as, in relation to any country other than Canada, the government of that country and includes:

any provincial, state, municipal or other local or regional government in that country
any person, agency or institution acting for, on behalf of, or under the authority of, or under the authority of any law passed by, the government of that country or that provincial, state, municipal or other local or regional government and
any association of sovereign states of which that country is a member

[167] Pursuant to subsection 2(1.6) of SIMA, a financial contribution exists where:

practices of the government involve the direct transfer of funds or liabilities or the contingent transfer of funds or liabilities
amounts that would otherwise be owing and due to the government are exempted or deducted or amounts that are owing and due to the government are forgiven or not collected
the government provides goods or services, other than general governmental infrastructure, or purchases goods or
the government permits or directs a non-governmental body to do any thing referred to in any of paragraphs (a) to (c) above where the right or obligation to do the thing is normally vested in the government and the manner in which the non-governmental body does the thing does not differ in a meaningful way from the manner in which the government would do it

[168] A state-owned enterprise (SOE) may be considered to constitute “government” for the purposes of subsection 2(1.6) of SIMA if it possesses, exercises, or is vested with, governmental authority. Without limiting the generality of the foregoing, the CBSA may consider the following factors as indicative of whether the SOE meets this standard: 1) the SOE is granted or vested with authority by statute; 2) the SOE is performing a government function; 3) the SOE is meaningfully controlled by the government; or 4) some combination thereof.

[169] If a subsidy is found to exist, it may be subject to countervailing measures if it is specific. A subsidy is considered to be specific when it is limited, in law or in fact, to a particular enterprise or is a prohibited subsidy. An “enterprise” is defined under SIMA as also including a “group of enterprises, an industry and a group of industries.” Any subsidy which is contingent, in whole or in part, on export performance or on the use of goods that are produced or that originate in the country of export is considered to be a prohibited subsidy and is, therefore, specific according to subsection 2(7.2) of SIMA for the purposes of a subsidy investigation.

[170] In accordance with subsection 2(7.3) of SIMA, notwithstanding that a subsidy is not specific in law, a subsidy may also be considered specific in fact, having regard as to whether:

there is exclusive use of the subsidy by a limited number of enterprises
there is predominant use of the subsidy by a particular enterprise
disproportionately large amounts of the subsidy are granted to a limited number of enterprises and
the manner in which discretion is exercised by the granting authority indicates that the subsidy is not generally available

[171] For purposes of a subsidy investigation, the CBSA refers to a subsidy that has been found to be specific as an “actionable subsidy,” meaning that it is countervailable.

Results of the subsidy investigation

[172] At the initiation of the subsidy investigation, the CBSA sent subsidy RFIs to the Government of China, as well as to all known and potential exporters/producers of subject goods.

[173] The Government of China was also requested to forward the subsidy RFI to all subordinate levels of government that had jurisdiction over the exporters. The exporters/producers were requested to forward a portion of the subsidy RFI to their input suppliers, who were asked to respond to questions pertaining to their legal characterization as SOEs.

[174] The Government of China and the exporters/producers were also notified that failure to submit all required information and documentation, including non-confidential versions, failure to comply with all instructions contained in the subsidy RFI, failure to permit verification of any information or failure to provide documentation requested during the verification visits may result in the amount of subsidy and the assessment of countervailing duties on subject goods being based on facts available to the CBSA. Further, they were notified that a determination on the basis of facts available could be less favourable than if complete, verifiable information was made available.

Government of China

[175] The Government of China provided a response to the Government Subsidy RFI. For the purposes of the final determination, the CBSA is treating the Government of China’s response as partially complete. For programs where complete information was provided by the Government of China, the CBSA used this information in its determination of specificity. For programs where the Government of China’s response was incomplete or contradictory to other evidence obtained by the CBSA, the CBSA relied on the best information available.

[176] At the initiation of the subsidy investigation, the CBSA requested information on 26 potential subsidy programs that could confer benefits to producers/exporters of truck bodies in China. At the preliminary determination, the CBSA found 31 potential subsidy programs that could confer benefits to producers/exporters of truck bodies in China.

[177] For the final determination, the CBSA removed four subsidy programs that were found to be countervailable at the preliminary determination. The CBSA determined that one of these programs was not specific within the meaning of SIMA and therefore did not constitute a countervailable subsidy. The CBSA further found that three other programs shared sufficiently similar characteristics with other programs examined in this investigation and were therefore consolidated with those programs for the purposes of the subsidy analysis and the calculation of the amount of subsidy. For the final determination, the CBSA found 27 subsidy programs that potentially confer benefits to producers/exporters of truck bodies in China. A summary of the findings for the subsidy programs can be found in Appendix 3 of this document.

[178] The Government of China’s response regarding the determination of specificity for the 27 subsidy programs fell into one of the three following categories:

Confirmation of specificity of certain programs
Failure to provide sufficient information to determine specificity of certain programs or
Provision of information contradicted by other compelling evidence on the record

[179] For programs in category ii), due to the lack of information provided by the Government of China with respect to these programs, there is insufficient information on the record to determine whether these programs are specific pursuant to subsection 2(7.2) or subsection 2(7.3) of SIMA; nor is there sufficient information to indicate that the subsidy is not specific pursuant to the criteria set out in subsection 2(7.1) of SIMA. Based on facts available, the CBSA found the programs in category ii) to be specific for the purposes of the final determination.

[180] For programs in category iii), the CBSA weighed the evidence available on the administrative record from both the cooperative exporter and from the Government of China. The evidence provided by the cooperative exporter, which includes information on programs that they received during the POI, contradicted the information provided by the Government of China in its response. In instances where the Government of China stated that a subsidy program did not exist, the CBSA found compelling evidence to the contrary from the exporter. On the basis of the information available, programs in category iii) were considered to be specific for the purposes of the final determination.

[181] For the final determination, the CBSA determined all 27 subsidy programs to be specific, and therefore actionable, as detailed in Appendix 3.

Qingdao CIMC Reefer Trailer Co., Ltd. (CIMC Reefer)

[182] CIMC Reefer is a producer and exporter of subject goods located in Qingdao City, Guangdong Province. CIMC Reefer provided a response to the subsidy RFI and supplemental subsidy RFI. For purposes of the final determination, CIMC Reefer was found to have received countervailable benefits from 4 subsidy programs.

Program 6: Export development and performance Grants
Program 17: Preferential Tax Treatment of Additional Calculation and Deduction of Research and Development Expenses
Program 19: Accelerated depreciation of fixed assets
Program 31: Reduction on Land Usage Tax

[183] Further to its analysis of the information on the administrative record, the CBSA considers that financial contributions conferring a subsidy were provided to the exporter pursuant to the above subsidy programs. The CBSA also considers these programs as specific and therefore actionable.

[184] For purposes of the final determination, the amount of subsidy for CIMC Reefer is 0.9%, expressed as a percentage of the export price. This amount is insignificant, and as such, the subsidy investigation in respect of the goods of this exporter was terminated pursuant to paragraph 41(1)(a) of SIMA.

All exporters: China

[185] Based on the information on the record, no other exporters shipped subject goods to Canada during the POI. As an insignificant amount of subsidy was determined for the cooperative exporter of subject goods, no “all other exporters” amount of subsidy for China has been determined for purposes of the final determination.

Summary of final results: Subsidy

[186] A summary of the final results of the subsidy investigation respecting all subject goods shipped to Canada during the POI follows:

Table 3: Summary of final results—Subsidy
Period of investigation (July 1, 2024, to June 30, 2025)
Exporter	Amount of subsidy (% of export price)	% of total imports (by volume)
Qingdao CIMC Reefer Trailer Co., Ltd.	0.9%	52.4%

[187] In order to make a final determination of subsidizing, the CBSA must be satisfied that:

the subject goods have been subsidized and that
the amount of subsidy of a particular exporter is not insignificant

[188] Under paragraph 41(1)(a) of SIMA, the CBSA is required to terminate an investigation in respect of any goods of an exporter if the CBSA is satisfied that the goods have not been subsidized or the amount of subsidy on the goods of that exporter is insignificant.

[189] Pursuant to subsection 2(1) of SIMA, an amount of subsidy of less than 1% of the export price of the goods, for a developed country, is defined as insignificant.

[190] The amount of subsidy determined for Qingdao CIMC Reefer Trailer Co., Ltd. is below 1% of the export price and is, therefore, determined to be insignificant. As a result, the CBSA terminated the subsidy investigation respecting truck bodies exported to Canada from China by Qingdao CIMC Reefer Trailer Co., Ltd.

[191] A summary of the results of the subsidy investigation respecting the subject goods shipped to Canada during the subsidy POI are presented in Appendix 1.

Decisions

[192] On June 4, 2026, pursuant to paragraph 41(1)(a) of SIMA, the CBSA terminated the subsidy investigation with respect to truck bodies originating in or exported from China by Qingdao CIMC Reefer Trailer Co., Ltd.

[193] On the same day, pursuant to paragraph 41(1)(b) of SIMA, the CBSA made a final determination respecting the dumping of truck bodies originating in or exported from China.

Future action

[194] The provisional period began on March 6, 2026, and will end on the date the CITT issues its finding. The CITT is expected to issue its decision by July 3, 2026. Provisional anti-dumping duty will continue to be imposed on the subject goods from China until the CITT renders its decision. For further details on the application of provisional duty, refer to the Statement of Reasons issued for the preliminary determinations.

[195] If the CITT finds that the dumped and subsidized goods have not caused injury and do not threaten to cause injury, all proceedings will be terminated. In this situation, all provisional duty paid or security posted by importers will be returned.

[196] If the CITT finds that the dumped goods have caused injury, the anti-dumping duty payable on subject goods released by the CBSA during the provisional period will be finalized pursuant to section 55 of SIMA. Imports released by the CBSA after the date of the CITT’s finding will be subject to anti-dumping duty equal to the margin of dumping.

[197] The importer in Canada shall pay all applicable duties. Importers must properly describe the goods that they are importing, whether the information is submitted in paper or electronic format. Customs Memorandum D17-1-1: Documentation requirements for commercial shipments explains the normal customs requirements. However, these requirements are often not enough for SIMA purposes. Consult the "Information Required on Customs Documents" section on the Measures in Force for specific information required for each SIMA measure, as well as Memorandum D14-1-7: Assessment and payment of duties are required under the Special Import Measures Act (SIMA) for more general information.

[198] The CBSA’s Assessment and Revenue Management (CARM) system will generally assign the SIMA code on Commercial Accounting Declarations (CADs). However, when populating pre-CARM entries into CARM, or when accounting for CLVS goods on a Type F CAD, you may be required to self-declare the SIMA code on the CAD. If the importers of such goods do not indicate the required SIMA code or do not correctly describe the goods in the customs documents, an administrative monetary penalty could be imposed. The provisions of the Customs Act apply with respect to the payment, collection or refund of any duty collected under SIMA. As a result, failure to pay duty within the prescribed time will result in the application of interest.

Retroactive duty on massive importations

[199] Under certain circumstances, anti-dumping and/or countervailing duty can be imposed retroactively on subject goods imported into Canada. When the CITT conducts its inquiry on material injury to the Canadian industry, it may consider if dumped and/or subsidized goods that were imported close to or after the initiation of the investigations constitute massive importations over a relatively short period of time and have caused injury to the Canadian industry. Should the CITT issue a finding that there were recent massive importations of dumped and/or subsidized goods that caused injury, imports of subject goods released by the CBSA in the 90 days preceding the day of the preliminary determinations could be subject to anti-dumping and/or countervailing duty.

[200] In respect of importations of subsidized goods that have caused injury, this provision is only applicable where the CBSA has determined that the whole or any part of the subsidy on the goods is a prohibited subsidy. In such a case, the amount of countervailing duty applied on a retroactive basis will equal the amount of subsidy on the goods that is a prohibited subsidy. An export subsidy is a prohibited subsidy according to subsection 2(1) of SIMA.

Publication

[201] A notice of these final decisions of dumping and subsidizing will be published in the Canada Gazette pursuant to paragraphs 41(3)(a) and 41(4)(a) of SIMA.

Contact us

[202] For further information, please contact the email address identified below:

Email: trade_remedies_registry-registre_recours_commerciaux@cbsa-asfc.gc.ca

Sean Borg
A/Executive Director
Trade Remedies Investigations Division

Appendix 1: Summary of margins of dumping and amounts of subsidy

Exporter	Margin of dumping (% of export price)	Amount of subsidy (% of export price)
Qingdao CIMC Reefer Trailer Co., Ltd.	119.4%	0.9%¹
All other exporters	257.1%	N/A
¹An amount of subsidy of less than 1% of the export price of the goods is insignificant for a developed country. Note The margins of dumping reported in the table above are the margins determined by the CBSA for the purposes of the final determination of dumping. These margins do not reflect the anti-dumping duty to be levied on future importations of dumped goods. In the event of an injury finding by the CITT, normal values have been provided to the exporters which provided sufficient information for future shipments to Canada and these normal values would come into effect the day after the injury finding. Information regarding normal values of the subject goods should be obtained from the exporter. Imports of subject goods from exporters/producers that did not provide sufficient information to the CBSA during the dumping investigation and that are not listed in the table above will be subject to the All Other Exporters anti-dumping duty rate pursuant to a ministerial specification. Normally, normal values will not be applied retroactively. However, normal values may be applied retroactively in cases where the exporter does not adjust export prices to account for increases in prices and/or costs. Therefore, where substantial changes occur in prices, market conditions, costs associated with production and sales of the goods, the onus is on the concerned parties to increase the export price accordingly to ensure that any sale made to Canada is not only above the normal value but at or above selling prices and full costs and profit of the goods. Please consult the SIMA Self-Assessment Guide for more detailed information explaining how to determine the amount of SIMA duties owing.

Exporter

Margin of dumping
(% of export price)

Amount of subsidy
(% of export price)

Qingdao CIMC Reefer Trailer Co., Ltd.

119.4%

0.9%¹

All other exporters

257.1%

N/A

¹An amount of subsidy of less than 1% of the export price of the goods is insignificant for a developed country.

Note The margins of dumping reported in the table above are the margins determined by the CBSA for the purposes of the final determination of dumping. These margins do not reflect the anti-dumping duty to be levied on future importations of dumped goods. In the event of an injury finding by the CITT, normal values have been provided to the exporters which provided sufficient information for future shipments to Canada and these normal values would come into effect the day after the injury finding. Information regarding normal values of the subject goods should be obtained from the exporter. Imports of subject goods from exporters/producers that did not provide sufficient information to the CBSA during the dumping investigation and that are not listed in the table above will be subject to the All Other Exporters anti-dumping duty rate pursuant to a ministerial specification.

Normally, normal values will not be applied retroactively. However, normal values may be applied retroactively in cases where the exporter does not adjust export prices to account for increases in prices and/or costs. Therefore, where substantial changes occur in prices, market conditions, costs associated with production and sales of the goods, the onus is on the concerned parties to increase the export price accordingly to ensure that any sale made to Canada is not only above the normal value but at or above selling prices and full costs and profit of the goods.

Please consult the SIMA Self-Assessment Guide for more detailed information explaining how to determine the amount of SIMA duties owing.

Appendix 2: Dumping and subsidy representations

During the investigations, representations were received on behalf of the complainants.^{Footnote 81}

Following the closing of the record on April 14, 2026, case arguments and reply submissions were received on behalf of the following parties:

The complainants^{Footnote 82}
Qingdao CIMC Reefer Trailer Co., Ltd.^{Footnote 83} and
The Ministry of Commerce of the People’s Republic of China^{Footnote 84}

Certain details provided in case briefs and reply submissions were designated as confidential information by the submitting counsel. This has restricted the ability of the CBSA to discuss all issues raised in these submissions. The material issues raised by the parties are summarized as follows:

Dumping representations

Allegations of section 20 conditions in China

Case brief

Counsel for the complainants submitted that the President should maintain its opinion from the preliminary determinations that section 20 conditions exist in China’s Automobile Bodies and Trailers Manufacturing sector. Counsel argued that no new information has been submitted that contradicts the opinion from the preliminary determination, and the evidence available indicates the Government of China has material control over the sector, and prices of truck bodies in China are not substantially the same as they would be in a competitive market. As such, counsel submitted that the CBSA should determine normal values pursuant to section 20 of the Special Import Measures Act (SIMA).

CBSA’s response

The CBSA has considered the case brief provided by the complainants’ counsel, as well as any representations filed during the investigation before the close of record. After careful consideration, the CBSA has formed an opinion that section 20 conditions exist in the Automobile Bodies and Trailers Manufacturing sector in China. Please refer to the Analysis of section 20 conditions section of this document for more detailed information.

Surrogate country and producer selection

Case briefs

Counsel for the exporter argued that the U.S. is not a proper surrogate country for the purposes of calculating section 20 normal values, stating that the cost structure, market conditions and production economics are significantly and materially different in the U.S. compared to China. Counsel submitted differences in various economic indicators, as well as labour costs, and trade measures indicate that the U.S. is not a proper surrogate country. In addition, counsel submitted that Morgan Truck Body LLC (Morgan Truck Body) is not a proper surrogate producer, as Morgan Truck Body’s information reflects the production conditions, distorted input costs, higher labour costs and broader commercial realities of the U.S., which makes the U.S. not a reasonably comparable market. Counsel further submitted that Thailand presents a more reasonable surrogate country as it is more comparable to China, and specifically argued that the exporter’s related producer in Thailand, Dee Siam Manufacturing Co., Ltd. (Dee Siam) is the most appropriate available surrogate information for purposes of determining normal values under section 20 of SIMA. Counsel stated that Dee Siam and its related suppliers provided complete responses, and even though the responses were submitted after the original deadline, it should not exclude the information from being considered. Counsel further stated that should the CBSA have concerns about the response provided, the CBSA should reopen the administrative record and request additional information.

Counsel for the complainants submitted that the response from Dee Siam should not be used for purposes of determining normal values. Counsel stated that the response was submitted more than two months after the deadline, depriving the CBSA of the opportunity to verify the data. Counsel submitted that there is no procedural unfairness in rejecting information received late, where counsel had knowledge of the deadlines, referring to WTO panels which have held that investigating authorities may rely on reasonable, pre-established deadlines. Further, counsel argued that besides the lateness of the submission, the information is unreliable and unusable, citing various concerns with using the information to determine normal values under 20(1)(c)(i) or (ii) of SIMA. Additionally, counsel submitted that Dee Siam and CIMC Reefer are under the ownership and control of the same Chinese SOE, and argued that using information from an entity subject to the same government control that the surrogate methodology is designed to mitigate is not appropriate. Further, counsel argued that the U.S. is a suitable surrogate country, stating that truck bodies produced in the U.S. are comparable to those produced in China, U.S. truck body producers are globally competitive, both China and the U.S. are some of the largest markets for truck bodies, and the U.S. truck bodies market operates under market conditions free from government interference. Counsel further stated that verified information submitted by Morgan Truck Body is the only reliable surrogate information available, stating that Morgan Truck Body submitted extensive sales and costing information, in accordance with the CBSA’s deadlines.

Reply submissions

In response to the complainants’ case brief, counsel for the exporter reiterated their previous arguments concerning the use of Dee Siam’s information, and further argued that even though unverified, the information can still be used, and that regardless of the use of imported inputs, Dee Siam still qualifies as a producer for purposes of paragraph 20(1)(c). With respect to the use of Morgan Truck Body’s information, counsel for the exporter maintained their position, disagreeing with the complainants’ claims of the information being suitable, and the comparability of the U.S. truck bodies to subject goods.

In response to the exporter’s case brief, counsel for the complainants reiterated their position, and stated that the CBSA is not required to request additional information regarding information received, and reopening the record would be irregular and would raise concerns about procedural fairness. Further, with respect to surrogate country selection, counsel for the complainants maintained their position, stating differences in macroeconomic indicators do not undermine the viability of the U.S. as a surrogate, and reiterated some of their arguments from their case brief. Further, counsel submitted that Thailand is an unsuitable surrogate, noting the road networks and trucking industries in China and Thailand are not similar. With respect to the exporter’s comments regarding trade measures, counsel for the complainants argued that tariffs imposed in the U.S. did not distort steel and aluminum pricing during the period of investigation (POI).

CBSA’s response

The CBSA considered the case arguments and reply submissions provided by counsel, as well as any representations filed during the investigation before the close of record.

At the initiation of the section 20 inquiry of China’s Automobile Bodies and Trailers Manufacturing sector, the CBSA identified the U.S. and Mexico as reasonable surrogate countries for China. These countries were selected as they produce comparable goods, have globally competitive producers, and operate under market conditions.

The CBSA received a response to the surrogate producer RFI from a producer in the U.S., Morgan Truck Body. The CBSA did not receive any responses to the surrogate producer RFI from producers or exporters of truck bodies in Mexico.

Morgan Truck Body submitted responses to the surrogate producer RFI and subsequent SRFIs, providing insight into the U.S. truck bodies market in terms of domestic sales and production costs. The CBSA conducted on-site verification at Morgan Truck Body’s facilities in March 2026.

As detailed in the Surrogates section above, the CBSA finds that Dee Siam is not an appropriate surrogate for purposes of determining normal values, due to the lateness of the submission, which resulted in insufficient time to thoroughly examine and verify the information, as well as the company’s purchases of inputs from China, where the CBSA has initiated an inquiry into whether the conditions of section 20 exist.

As part of the section 20 inquiry, the RFIs sent to importers requested information on resales in Canada of truck bodies imported from sources other than China. The CBSA received one response to the importer RFI. However, the importer did not provide information concerning the purchase and/or resale of like goods from the non-named country.

For the purposes of the final determination of dumping, the CBSA determined that the verified information submitted by the U.S. producer was deemed appropriate as surrogate data in order to determine normal values for the exporter of subject goods from China.

Determination of normal values

Case briefs

Counsel for the exporter argued that for the purposes of calculating normal values under section 20, adjustments are required to reflect the differences between the exports of subject goods and the surrogate goods, including the differences between the surrogate country and the country under investigation. Counsel indicated this should include adjustments to raw material, labour, overhead, and any other adjustments necessary.

Reply submissions

Counsel for the complainants addressed the comments submitted by the exporter regarding adjustments, agreeing with one proposed adjustment, however stating there is no basis for the adjustments to raw material costs, or to account for differences between China and the U.S. Counsel noted that tariffs had no material impact on U.S. steel and aluminum prices during the POI.

CBSA’s response

The CBSA considered the case arguments and reply submissions provided by counsel regarding this issue. The CBSA reviewed the exporter’s sales to Canada and the surrogate costing information and made adjustments, where necessary, to account for differences between the goods sold, in order to ensure the comparability of the goods.

Subsidy representations

Determination of an amount for subsidy

Case briefs

In their case briefs, counsel on behalf of the Government of China submitted that the some of the subsidy programs the CBSA initiated on were too vague or broad in nature, which prevented the Government of China from being able to respond. The Government of China further submitted that the CBSA should not investigate or ask questions about programs, on the basis of being found in China’s subsidy notification to the World Trade Organization (“WTO”).

Counsel for the complainants made arguments regarding the determination of the amount of subsidy, submitting that evidence on the record confirms that Chinese truck body producers received countervailable subsidies during the POI, and specifying additional programs they allege are countervailable and should be considered.

Reply submissions

Counsel for the complainants responded to the arguments presented in the case brief filed on behalf of the Government of China, submitting that sufficient evidence was available to initiate the subsidy investigation and identify programs, and the CBSA is entitled to assess new programs during the investigation.

In the reply submission filed on behalf of the Government of China, counsel disputed the complainants' arguments, stating the additional programs identified are not countervailable, and should not be considered. Counsel further submitted that the Government of China has fully cooperated in on-site verification.

Counsel for CIMC Reefer disputed the complainants' arguments, submitting that an amount for subsidy should be determined based on the verified information provided by CIMC Reefer, which represents the best information available.

CBSA’s response

The CBSA reviewed the information contained in the supporting documents submitted in the complaint, as well as other publicly available reference material to determine whether the programs could constitute financial contributions in accordance with subsections 2(1) and 2(1.6) of SIMA. The programs were further examined to establish whether they could also be considered specific under subsections 2(7.2) or 2(7.3) of SIMA. At the time of initiation, the CBSA found sufficient evidence to support an investigation into all of the programs mentioned in the Initiation Statement of Reasons.

As a result, the CBSA determined an amount for subsidy based on the information available on the record, including the verified responses from CIMC Reefer and the Government of China.

Appendix 3: Summary of findings for subsidy programs

For the final determination, the CBSA identified 27 potentially actionable subsidy programs.

As noted in the body of this document, the Government of China provided a response to the subsidy RFI. The CBSA also received a response from the cooperative exporter. As such, the CBSA used the information on the administrative record to determine the specificity of the following 27 programs.

This Appendix consists of descriptions of the subsidy programs which the cooperative exporter benefited from during the course of the POI, as well as other potentially actionable subsidy programs identified in the Government of China’s RFI response and/or found by the CBSA on the basis of information on the administrative record.

Category 1: Preferential loans and loan guarantees

Program 1: Loans from state-owned banks at preferential rates

General information

This program relates to loans from State-owned banks at preferential rates of interest. The benefit provided in this case is a lower rate of interest than would otherwise be available if the enterprises had to obtain at commercial market terms (i.e. the benchmark non-state-owned commercial loan rate).

For the purposes of the final determination, this program is determined to be an export subsidy and is therefore prohibited. Pursuant to paragraph 2(7.2)(b) of SIMA, this program is specific.

Category 2: Grants and grant equivalents

Program 5: Fund for development of international economy and trade

General information

This program aimed at fostering foreign trade and economic growth. The fund provides financial appropriations to local authorities. These resources are used to enhance public services related to foreign trade and promote balanced trade development and international two-way investment. Local governments manage and coordinate the use of these funds to support the strategic development of foreign economic cooperation.

Financial contribution

For the purposes of the final determination, this program constitutes a financial contribution pursuant to paragraph 2(1.6)(a) of SIMA as a direct transfer of funds from the government, and it confers a benefit to the recipient equal to the amount of the grant.

Specificity

Program 6: Export development and performance grants

General information

This program relates to grants provided by the Government of China to assist in the development of export markets and to recognize both export and domestic performance. The benefit provided in this case is financial assistance in the form of grants awarded to enterprises, resulting in a direct financial contribution.

Financial contribution

For the purposes of the final determination, this program provides a financial contribution pursuant to paragraph 2(1.6)(a) of SIMA in the form of a direct transfer of funds from the government, and it confers a benefit to the recipient equal to the amount of the grant.

Specificity

Due to the lack of information provided by the Government of China on this program, there is not sufficient information on the record to determine whether this program is specific pursuant to subsection 2(7.2) or subsection 2(7.3) of SIMA; nor is there sufficient information to indicate that the subsidy is not specific pursuant to the criteria set out in subsection 2(7.1). On the basis of the information available, this program does not appear to be generally available to all enterprises in China and thus the CBSA has determined this program to be specific for the purposes of the final determination.

Program 7: Energy conservation, emission reduction and environmental protection grant

General information

Subsidies under this program are grants given to promote energy conservation, improve energy efficiency, and protect and improve the environment.

Financial contribution

Specificity

For the purposes of the final determination, this program is determined to be specific pursuant to paragraph 2(7.2)(a) of SIMA, as the Government of China has confirmed that this program is de jure specific.

Program 8: Grants for the retirement of capacity

General information

These programs are administered by different levels of government in China and are intended to support broad industrial restructuring and economic development. Through various fiscal measures, authorities provide funding to encourage adjustments to industrial structure, the development of key sectors and the advancement of activities identified in economic planning. Local governments distribute these resources to strengthen industrial capacity, support the retirement of outdated or excess capacity and advance long-term policy objectives related to industrial development.

Financial contribution

Specificity

Program 9: Grant for patent assistance/award

General information

These programs are administered by different levels of government in China and are intended to support patent protection and brand-building activities. Funding helps applicants secure patents and strengthen brand development.

Financial contribution

General information

Subsidies under this program are refunds and incentives related to the handling of employees’ individual income tax withheld and remitted on behalf of the taxation authorities.

Specificity

Evidence on the record demonstrates that this program is generally available to enterprises that act as withholding agents for employees’ individual income tax and comply with the applicable tax administration requirements. The program is administered in a manner consistent with standard tax collection and remittance procedures and is not limited to a particular enterprise, industry, or region. On this basis, the program is considered to be generally available and therefore not specific within the meaning of subsection 2(7.1) of SIMA.

Category 3: Preferential tax programs

Program 13: Preferential tax policies for enterprises established in special economic zones (SEZs) and other designated areas incentives

General information

This program aims to attract foreign investment and accelerate regional development through targeted tax incentives.

Financial contribution

Financial contribution

This program related to the acquisition of input materials and utilities from state owned enterprises (SOE) at below fair market value.

Financial contribution

The Government of China provided information regarding this program. However, the information on the record is insufficient to determine a benchmark for fair market value of the inputs and utilities provided. As a result, the CBSA was unable to determine whether a benefit was conferred or to calculate the amount of any such benefit.

Specificity

The information on the record is insufficient to determine whether this program is specific pursuant to subsection 2(7.2) or subsection 2(7.3) of SIMA. Similarly, there is insufficient information to determine whether the program is not specific under subsection 2(7.1) of SIMA.

Accordingly, the program was identified among the potential subsidy programs examined for the purposes of the final determination.

Program 26: Provision of land for less than adequate remuneration by government

General information

All land in China belongs to the Government of China (i.e., either national or local governments, or through a “collective” at the township or village level), and government land agencies across China control the allocation of land through the granting of land-use rights.

Financial contribution

The Government of China provided information regarding this program. However, the record does not contain sufficient benchmark pricing information to establish the fair market value of the land provided under this program. Based on the information available, no participating exporter benefited from this program. Consequently, the CBSA was unable to determine whether a benefit was conferred or to calculate the amount of any such benefit.

Specificity

Based on the information available, the program continues to be considered specific for the purposes of the final determination.

Program 31: Reduction on land usage tax

General information

This program provides aims promote intensive and efficient land use. The program was established to encourage more effective land utilization by eligible enterprises and benefits are available to enterprises that meet the eligibility conditions set out for participation. The eligible enterprise benefits from reduce land usage tax.

Financial contribution

Specificity

Footnotes

Footnote 1

Exhibits 58 (PRO) & 59 (NC) - Response to section 20 RFI from Qingdao CIMC Reefer Trailer Co., Ltd.; Exhibits 63 (PRO) & 64 (NC) - Response to subsidy RFI from Qingdao CIMC Reefer Trailer Co.; Ltd., Exhibits 65 (PRO) & 66 (NC) - Response to dumping RFI from Qingdao CIMC Reefer Trailer Co., Ltd.; Exhibits 107 (PRO) & 108 (NC) - Response to SRFI #1 from Qingdao CIMC Reefer Trailer Co., Ltd.; Exhibits 111 (PRO) and 112 (NC) - Additional response to SRFI #1 from Qingdao CIMC Reefer Trailer Co., Ltd.; Exhibits 117 (PRO) & 118 (NC) - Response to SRFI #2 from Qingdao CIMC Reefer Trailer Co., Ltd.; Exhibits 156 (PRO) & 157 (NC) - Response to SRFI #2 dumping from Qingdao CIMC Reefer Trailer Co., Ltd.; Exhibits 158 (PRO) & 159 (NC) - Response to SRFI #3 from Qingdao CIMC Reefer Trailer Co., Ltd.

Return to footnote 1 referrer

Footnote 2

Exhibits 46 (PRO) & 47 (NC) - Response to Importer RFI from Vanguard Refrigerated Trailer Co., Ltd.; Exhibits 105 (PRO) & 106 (NC) - Response to SRFI from Vanguard Refrigerated Trailer Co., Ltd.

Return to footnote 2 referrer

Footnote 3

Exhibits 70 (PRO) & 71 (NC) - Response to Surrogate Producer RFI from Morgan Truck Body LLC; Exhibits 101 (PRO) & 102 (NC) - Response to SRFI from Morgan Truck Body LLC; Exhibits 164 (PRO) & 165 (NC) - Response to SRFI #2 from Morgan Truck Body LLC

Return to footnote 3 referrer

Footnote 4

Exhibits 120 (PRO) & 121 (NC) - Response to surrogate producer RFI - from Dee Siam Manufacturing Co., Ltd.

Return to footnote 4 referrer

Footnote 5

Exhibits 125 (PRO) & 126 (NC) - Response to surrogate producer RFI - from Dongguan CIMC Vehicle Co., Ltd.

Return to footnote 5 referrer

Footnote 6

Exhibits 127 (PRO) & 128 (NC) - Response to surrogate producer RFI - from CIMC Vehicle (Jiangmen) Co., Ltd.

Return to footnote 6 referrer

Footnote 7

Exhibits 72 (PRO) & 73 (NC) - Response to government subsidy RFI from Ministry of Commerce of the People's Republic of China; Exhibits 122 (PRO) and 123 (NC) - Response to SRFI#1 from Ministry of Commerce of the People's Republic of China; Exhibit 140 (NC) - Response to SRFI#2 from Ministry of Commerce of the People's Republic of China

Return to footnote 7 referrer

Footnote 8

Exhibits 39 (PRO) & 40 (NC) - Response to RFI - industry profit survey from Morgan Canada Corporation

Return to footnote 8 referrer

Footnote 9

Exhibits 49 (PRO) & 50 (NC) - Response to RFI - industry profit survey from Morgan Transit Corporation

Return to footnote 9 referrer

Footnote 10

Exhibits 32 (PRO) & 33 (NC) - Response to RFI - industry profit survey from Intercontinental Truck Body (B.C.) Inc.

Return to footnote 10 referrer

Footnote 11

Exhibits 36 (PRO) & 37 (NC) - Response to RFI - industry profit survey from Intercontinental Truck Body Ltd.

Return to footnote 11 referrer

Footnote 12

Exhibits 75 (PRO) & 76 (NC) - Response to SRFI from Morgan Canada Corporation; Exhibits 109 (PRO) & 110 (NC) - Response to SRFI #2 from Morgan Canada Corporation; Exhibits 160 (PRO) & 161 (NC) - Response to SRFI #3 from Morgan Canada Corporation

Return to footnote 12 referrer

Footnote 13

Exhibits 78 (PRO) & 79 (NC) - Response to SRFI from Morgan Transit Corporation Exhibits 103 (PRO) & 104 (NC) - Response to SRFI #2 from Morgan Transit Corporation; Exhibits 162 (PRO) & 163 (NC) - Response to SRFI #3 from Morgan Transit Corporation

Return to footnote 13 referrer

Footnote 14

Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, paras. 139-168

Return to footnote 14 referrer

Footnote 15

Canadian International Trade Tribunal; Preliminary Injury Inquiry - Truck Bodies - Statement of Reasons (January, 2026), PI 2025-007, paras. 30-31

Return to footnote 15 referrer

Footnote 16

China is a prescribed country under Section 17.1 of the Special Import Measures Regulations.

Return to footnote 16 referrer

Footnote 17

Exhibits 1 (PRO) & 2 (NC) - Truck Bodies Complaint, paras. 245 - 247

Return to footnote 17 referrer

Footnote 18

Truck Bodies Complaint (NC), para. 258

Return to footnote 18 referrer

Footnote 19

Final determination Statement of Reasons for Container Chassis - February 3, 2022, para 107

Return to footnote 19 referrer

Footnote 20

Truck Bodies Complaint (NC), para.296 (Exhibit VI-5-8 - GOC Distortion Evidence - Outline of the People's Republic of China 14th Five-Year Plan for National Economic and Social Development and Long-Range Objectives for 2035, (March 12, 2021) (PUBLIC)) p. 26

Return to footnote 20 referrer

Footnote 21

Ibid (Exhibit VI-5-8 - GOC Distortion Evidence - Outline of the People's Republic of China 14th Five-Year Plan for National Economic and Social Development and Long-Range Objectives for 2035, (March 12, 2021) (PUBLIC)) p. 19

Return to footnote 21 referrer

Footnote 22

Truck Bodies Complaint (NC), para.297 (Exhibit VI-5-8 - GOC Distortion Evidence - Outline of the People's Republic of China 14th Five-Year Plan for National Economic and Social Development and Long-Range Objectives for 2035, (March 12, 2021) (PUBLIC)).p 28

Return to footnote 22 referrer

Footnote 23

Exhibit 133 - TB 2025 IN PD S20 - Attachment 1 - Notice of the Ministry of Transport and the National Development and Reform Commission on Issuing the Action Plan for Reducing Costs, Improving Quality and Increasing Efficiency in Transportation and Logistics, page 3 and 4

Return to footnote 23 referrer

Footnote 24

TB 2025 IN - Exhibit Response 059 - Response to Section 20 RFI from Qingdao CIMC Reefer Trailer Co., Ltd., Exhibit A1(c) - 14th Five-Year Plan Cold Chain Logistics Development Plan (CN and EN), p.11

Return to footnote 24 referrer

Footnote 25

Cold chain logistics refers to specialized logistics that utilizes temperature control, preservation technologies and processes, and facilities and equipment such as cold storage warehouses, refrigerated trucks, and refrigerated containers to ensure that cold chain products remain at specified temperature conditions throughout the entire process of primary processing, storage, transportation, distribution processing, sales, and delivery.(14th Five-Year Plan Cold Chain Logistics Development Plan (CN and EN), p.2)

Return to footnote 25 referrer

Footnote 26

TB 2025 IN - Exhibit Response 059 - Response to Section 20 RFI from Qingdao CIMC Reefer Trailer Co., Ltd., Exhibit A1(c) -, 14th Five-Year Plan Cold Chain Logistics Development Plan (CN and EN), p.5

Return to footnote 26 referrer

Footnote 27

Ibid, 14th Five-Year Plan Cold Chain Logistics Development Plan (CN and EN), p.15

Return to footnote 27 referrer

Footnote 28

Truck Bodies Complaint (NC), para.298 (Exhibit VI-5-28 - GOC Distortion Evidence - General Office of the State Council "14th Five-Year Plan Cold Chain Logistics Development Plan" (November 26, 2021) (PUBLIC), p.12.

Return to footnote 28 referrer

Footnote 29

Return to footnote 29 referrer

Footnote 30

Truck Bodies Complaint (NC), para.299 (Exhibit VI-9-1 - CIMC Articles (PUBLIC) - CIMC Vehicles "Gelonghui: CIMC Vehicles' Market Share Further Increases with Rise in Long-term Value of Investment" (April 27, 2022) (PUBLIC), p. 3.

Return to footnote 30 referrer

Footnote 31

Ibid., p.3.

Return to footnote 31 referrer

Footnote 32

Ibid (Exhibit VI-5-30 - GOC Distortion Evidence - Ministry of Transportation, "Implementation Opinions on Accelerating the High-Quality Development of Cold Chain Logistics Transportation" (April 2022) (PUBLIC))

Return to footnote 32 referrer

Footnote 33

Truck Bodies Complaint (NC), para.301

Return to footnote 33 referrer

Footnote 34

Ibid (Exhibit VI-5-32 - GOC Distortion Evidence - J. Tian, P. Wang, D. Zhu, "Overview of Chinese new energy vehicle industry and policy development" Green Energy and Resources 2024:2, (May 22, 2024) (PUBLIC). )

Return to footnote 34 referrer

Footnote 35

Truck Bodies Complaint (Exhibit VI-5-33 - GOC Distortion Evidence - IIFIIR - China's Cold Chain Growth (February 6, 2025) (PUBLIC).)

Return to footnote 35 referrer

Footnote 36

Exhibit 133 - TB 2025 IN PD S20 - Attachment 2 - Action plan to improve the quality and efficiency of freight transportation and logistics in China, page 4

Return to footnote 36 referrer

Footnote 37

Exhibit 133 - TB 2025 IN PD S20 - Attachment 3 - China-scrappage policy-update, page 2 and 3

Return to footnote 37 referrer

Footnote 38

Exhibit 133 - TB 2025 IN PD S20 - Attachment 4 - China's expanded incentives for scrapping and replacing transportation equipment, page 2

Return to footnote 38 referrer

Footnote 39

Truck Bodies Complaint (NC), para. 300, Public Exhibit VI-5-31 - GOC Distortion Evidence - Netherlands Ministry of Foreign Affairs "A quick Scan of Cold Chain Logistics Sectors in China's Greater Bay Area" (2020) at 21

Return to footnote 39 referrer

Footnote 40

Truck Bodies Complaint (NC), Public Exhibit VI-5-31 - GOC Distortion Evidence - Netherlands Ministry of Foreign Affairs "A quick Scan of Cold Chain Logistics Sectors in China's Greater Bay Area" (2020) at 17

Return to footnote 40 referrer

Footnote 41

Exhibit 133 - TB 2025 IN PD S20 - Attachment 7 - Notice by the People's Bank of China, the Ministry of Transport and the China Banking and Insurance Regulatory Commission of Further Providing Effective Financial Support and Services in the Fields of Transportation and Logistics

Return to footnote 41 referrer

Footnote 42

Exhibit 133 - TB 2025 IN PD S20 - Attachment 8 - Special refinancing for transportation and logistics

Return to footnote 42 referrer

Footnote 43

Initiative offers road map for peace, prosperity

Return to footnote 43 referrer

Footnote 44

TB 2025 IN - Exhibit Response 059 - Public Exhibit A1(a)_TB 2025 IN_QCTC (S20) 14th FYP, Chapter 41, page 158

Return to footnote 44 referrer

Footnote 45

Certain Container Chassis from China (February 3, 2022), CC 2021 IN, Statement of Reasons - Final Determination (CBSA) at para 89.

Return to footnote 45 referrer

Footnote 46

Certain Container Chassis from China (February 3, 2022), CC 2021 IN, Statement of Reasons - Final Determination (CBSA) at para 92.

Return to footnote 46 referrer

Footnote 47

Exhibit 58 PRO - QCTC's Response to Section 20 RFI - Public Exhibit A1(c) - 14th Five-Year Plan Cold Chain Logistics Development Plan (CN and EN)

Return to footnote 47 referrer

Footnote 48

Truck Bodies Complaint (NC), para.304 (Exhibit VI-5-17 - GOC Distortion Evidence - Translated Administrative Regulation on the Investment Management in the Automotive Industry (PUBLIC), p. 2.)

Return to footnote 48 referrer

Footnote 49

Truck Bodies Complaint (NC), para.305 (Exhibit VI-5-17 - GOC Distortion Evidence - Translated Administrative Regulations on the Investment Management of the Automobile Industry (PUBLIC), p. 6.)

Return to footnote 49 referrer

Footnote 50

TB 2025 IN - Exhibit 58 PRO - QCTC's Response to Section 20 RFI, page 4.

Return to footnote 50 referrer

Footnote 51

TB 2025 IN - Exhibit 59 NC - Response to request for information (RFI) - section 20 from Qingdao CIMC Reefer Trailer Co., Ltd. ("QCTC") (Public Exhibit A1(k)_TB 2025 IN_QCTC (S20)_2025-12-04; p. 23, Article 28.2.)

Return to footnote 51 referrer

Footnote 52

Truck Bodies Complaint, para.307 (Exhibit VI-5-26 - GOC Distortion Evidence - Translated Catalogue on Industrial Structure Adjustment Guidance, 2024 (PUBLIC), pp. 2, 22, 59.)

Return to footnote 52 referrer

Footnote 53

Truck Bodies Complaint (NC), para.307 (Exhibit VI-5-26 - GOC Distortion Evidence - Translated Catalogue on Industrial Structure Adjustment Guidance, 2024 (PUBLIC), p. 53.

Return to footnote 53 referrer

Footnote 54

Ibid (Exhibit VI-5-26 - GOC Distortion Evidence - Translated Catalogue on Industrial Structure Adjustment Guidance, 2024 (PUBLIC), p. 59.)

Return to footnote 54 referrer

Footnote 55

Ibid (Exhibit VI-5-26 - GOC Distortion Evidence - Translated Catalogue on Industrial Structure Adjustment Guidance, 2024 (PUBLIC), p. 4.)

Return to footnote 55 referrer

Footnote 56

CIMC Vehicles Company Profile

Return to footnote 56 referrer

Footnote 57

Certain Container Chassis from China (February 3, 2022), CC 2021 IN, Statement of Reasons - Final Determination (CBSA) at paras 105-106.

Return to footnote 57 referrer

Footnote 58

Truck Bodies Complaint (NC), para. 278

Return to footnote 58 referrer

Footnote 59

Exhibit 58 PRO - Response to request for information (RFI) - section 20 from Qingdao CIMC Reefer Trailer Co., Ltd. ("QCTC")

Return to footnote 59 referrer

Footnote 60

CIMC Company Profile

Return to footnote 60 referrer

Footnote 61

Exhibit 133 - TB 2025 IN PD S20 - Attachment 5 -CIMC 2024 Annual report p. 213

Return to footnote 61 referrer

Footnote 62

Exhibit 133 - TB 2025 IN PD S20 - Attachment 6 - Equity Structure Chart

Return to footnote 62 referrer

Footnote 63

Shenzhen Capital Holdings (available in Chinese only)

Return to footnote 63 referrer

Footnote 64

About Us - About Us - China Merchants Group

Return to footnote 64 referrer

Footnote 65

Truck Bodies Complaint (NC), para. 285

Return to footnote 65 referrer

Footnote 66

Exhibit 058 - Response to (RFI) - section 20 from Qingdao CIMC Reefer Trailer Co., Ltd. ("QCTC") Confidential Narrative_TB 2025 IN_QCTC (S20) p.19

Return to footnote 66 referrer

Footnote 67

Ibid, p. 12

Return to footnote 67 referrer

Footnote 68

Ibid, p. 13

Return to footnote 68 referrer

Footnote 69

Truck Bodies Complaint (PRO), para. 260, Confidential Joint Declaration of Joel Chandonnet & Rick Rovito at Table 1

Return to footnote 69 referrer

Footnote 70

Truck Bodies Complaint (PRO), para. 260, Confidential Joint Declaration of Joel Chandonnet & Rick Rovito at Table 1

Return to footnote 70 referrer

Footnote 71

Truck Bodies Complaint (NC), para. 261

Return to footnote 71 referrer

Footnote 72

Truck Bodies Complaint (NC), para. 264

Return to footnote 72 referrer

Footnote 73

Truck Bodies Complaint (PRO), para. 268

Return to footnote 73 referrer

Footnote 74

Truck Bodies Complaint (NC), para 263, Certain Aluminum Extrusions (3 March 2009) 4214-22 AD/1379, 4218-26 CV/124, Statement of Reasons - Final Determination (CBSA) at Appendix 3

Return to footnote 74 referrer

Footnote 75

Certain Aluminum Extrusions (3 March 2009) 4214-22 AD/1379, 4218-26 CV/124, Statement of Reasons - Final Determination (CBSA) at Appendix 3

Return to footnote 75 referrer

Footnote 76

Truck Bodies Complaint (NC), Exhibit VI-5-15 - GOC Distortion Evidence - WTO, China Trade Policy Review WT/TPR/S/458/Rev.1 (November 19, 2024) (PUBLIC), p. 69.

Return to footnote 76 referrer

Footnote 77

Truck Bodies Complaint (NC), Exhibit VI-5-17 - GOC Distortion Evidence - Translated Administrative Regulation on Investment Management in the Automotive Industry (PUBLIC), p. 2.

Return to footnote 77 referrer

Footnote 78

Exhibits 65 (PRO) & 66 (NC) - Response to dumping RFI - Qingdao CIMC Reefer Trailer Co., Ltd.

Return to footnote 78 referrer

Footnote 79

Exhibits 70 (PRO) & 71 (NC) - Response to Surrogate Producer RFI - Morgan Truck Body, LLC.

Return to footnote 79 referrer

Footnote 80

Exhibits 70 (PRO) & 71 (NC) - Response to Surrogate Producer RFI from Morgan Truck Body LLC

Return to footnote 80 referrer

Footnote 81

Exhibits 129 (PRO) and 130 (NC) - Comments submitted by counsel for Morgan Canada Corporation and Morgan Transit Corporation regarding the responses to the requests for information (RFI) and responses to the SRFI from Qingdao CIMC Reefer Trailer Co., Vanguard Refrigerated Trailer Co., Ltd., Government of China, Dee Siam Manufacturing; Exhibits 131 (PRO) and 132 (NC) - Comments submitted by counsel for Morgan Canada Corporation and Morgan Transit Corporation regarding the responses to the requests for information (RFI) from Dongguan CIMC Vehicle Co., Ltd. and CIMC Vehicle (Jiangmen) Co., Ltd.

Return to footnote 81 referrer

Footnote 82

Exhibits 194 (PRO) and 195 (NC) - Case brief filed on behalf of Morgan Canada Corporation and Morgan Transit Corporation; Exhibits 199 (PRO) and 200 (NC) - Reply submission filed on behalf of Morgan Canada Corporation and Morgan Transit Corporation

Return to footnote 82 referrer

Footnote 83

Exhibits 192 (PRO) and 193 (NC) - Case brief filed on behalf of Morgan Canada Corporation and Morgan Transit Corporation; Exhibits 197 (PRO) and 198 (NC) - Reply submission filed on behalf of Qingdao CIMC Reefer Trailer Co., Ltd.

Return to footnote 83 referrer

Footnote 84

Exhibit 196 (NC) - Case brief filed on behalf of Ministry of Commerce of the People's Republic of China; Exhibit 201 (NC) - Reply submission filed on behalf of Ministry of Commerce of the People's Republic of China

Return to footnote 84 referrer

Page details

Date modified:: 2026-06-19

Decision

On this page

Summary

Period of investigation

Profitability analysis period

Interested parties

Exporters

Importers

Surrogates

Government

Canadian producers

Product information

Definition

Like goods and class of goodsFootnote 14

Imports into Canada

Investigations process

Dumping investigation

Normal value

Export price

Margin of dumping

Background of section 20 inquiries

Analysis of section 20 conditions

Government control analysis

Industrial plans, directives, regulations and other policy mandates

National & Provincial 14th Five-Year Plans

14th Five-Year Plan Cold Chain Logistics Development

14th Five-Year Plan Clean Energy Infrastructure

Other incentive measures and financial support

Special refinancing for transportation and logistics

Belt and Road Initiative and Made-in-China 2025 Initiative

Vehicle industry investment regulations

Government ownership and control of major producers

Text version

Government influence on pricing of key inputs

Subsidized Steel and Aluminum Distorts the Cost of Production for Chinese Truck Bodies

Government Maintains a Significant Degree of Ownership in the Steel and Aluminum Sectors

Government Policy Measures Distort Domestic Prices for Steel and Aluminum

Summary of government control analysis

Price analysis

Results of the section 20 inquiry

Results of the dumping investigation

Cooperative exporters

All other exporters

Summary of final results: Dumping

Subsidy investigation

Results of the subsidy investigation

Government of China

Qingdao CIMC Reefer Trailer Co., Ltd. (CIMC Reefer)

All exporters: China

Summary of final results: Subsidy

Decisions

Future action

Retroactive duty on massive importations

Publication

Contact us

Appendix 1: Summary of margins of dumping and amounts of subsidy

Appendix 2: Dumping and subsidy representations

Dumping representations

Allegations of section 20 conditions in China

Case brief

CBSA’s response

Surrogate country and producer selection

Case briefs

Reply submissions

CBSA’s response

Determination of normal values

Case briefs

Reply submissions

CBSA’s response

Subsidy representations

Determination of an amount for subsidy

Case briefs

Reply submissions

CBSA’s response

Appendix 3: Summary of findings for subsidy programs

Category 1: Preferential loans and loan guarantees

Program 1: Loans from state-owned banks at preferential rates

General information

Financial contribution

Specificity

Like goods and class of goods^{Footnote 14}