Print PDF


Practice Areas

New AD/CV Duties Sought on Hot-Rolled Steel Flat Products

Thursday, August 13, 2015

A petition filed Aug. 11 alleges that imports of hot-rolled steel flat products from Australia, Brazil, Japan, the Netherlands, South Korea, Turkey and the United Kingdom are being sold at less than fair value and that imports of such goods from Brazil, South Korea and Turkey benefit from countervailable subsidies. Hot-rolled steel has a number of uses, including automotive and appliance manufacturing.   The alleged dumping margins are as follows.   - 99.2 percent for Australia - 21.8 percent for Brazil - 19.53-30.90 percent for Japan - 55.21-173.17 percent for the Netherlands - 86.96-158.93 percent for South Korea - 96.44-200.78 percent for Turkey - 50.63-161.75 percent for the United Kingdom   The petitioner states that the scope of this petition (set forth below) is very similar to that accepted in the 2000/2001 investigations and that the modifications reflect certain changes in steelmaking and the types of hot-rolled steel products currently being produced by the domestic industry. Other changes are intended to address certain tactics adopted by foreign producers to evade AD/CV duty orders by making minor adjustments to the chemistry or other characteristics of steel products in ways that are sufficient to circumvent the orders but not affect the suitability of the product for a given application.   The products covered by these investigations are certain hot-rolled steel flat products, with or without patterns in relief, and that are neither clad, plated nor coated with metal but whether or not annealed, painted, varnished or coated with plastics or other non-metallic substances. The products covered include coils that have a width of 12.7 mm or greater, regardless of thickness, and regardless of the form of the coil (e.g., in successively superimposed layers, spirally oscillating, etc.). The products covered also include products not in coils (e.g., in straight lengths) of a thickness of less than 4.75 mm and a width that is 12.7 mm or greater that measures at least 10 times the thickness. The covered products described above may be rectangular, square, circular or other shapes and include products of either rectangular or non-rectangular cross-section where such cross-section is achieved subsequent to the rolling process; i.e., products that have been worked after rolling (e.g., products that have been beveled or rounded at the edges).   The subject goods are provided for in Harmonized Tariff Schedule of the United States subheadings 7208.10.15.00, 7208.10.30.00, 7208.10.60.00, 7208.25.30.00, 7208.25.60.00, 7208.26.00.30, 7208.26.00.60, 7208.27.00.30, 7208.27.00. 60, 7208.36.00.30, 7208.36.00.60, 7208.37.00.30, 7208.37.00. 60, 7208.38.00.15, 7208.38.00.30, 7208.38.00.90, 7208.39.00. 15, 7208.39.00.30, 7208.39.00.90, 7208.40.60.30, 7208.40.60.60, 7208.53.00.00, 7208.54.00.00, 7208.90.00.00, 7210.70.30.00, 7211.14.00.30, 7211.14.00.90, 7211.19.15.00, 7211.19.20.00, 7211.19.30.00, 7211.19.45.00, 7211.19.60.00, 7211.19.75.30, 7211.19.75.60, 7211.19.75.90 and 7211.90.00.00. Certain hot-rolled steel flat products covered by these investigations also enter under the subheadings 7225.11.00. 00, 7225.19.00.00, 7225.30.30.50, 7225.30.70.00, 7225.40.70.00, 7225.99.00.90, 7226.11.10.00, 7226.11.90.30, 7226.11.90.60, 7226.19.10.00, 7226.19.90.00, 7226.91.50.00, 7226.91.70.00 and 7226.91.80.00. They may also enter under subheadings 7210.90.90.00, 7212.40.10.00, 7212.40.50.00, 7212.50.00.00 and 7226.99.01.80.

The International Trade Administration and the International Trade Commission will next determine whether to launch AD and CV duty and injury investigations, respectively, on this product. There are strict statutory deadlines associated with these proceedings, so affected companies that wish to protect their interests should contact trade counsel as soon as possible.   For more information contact Kristen Smith at (202) 730-4965 or Mark Ludwikowski at (202) 730-4967.  

Customs & International Headlines