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

Wednesday, July 29, 2015

A petition filed July 28 alleges that imports of cold-rolled steel flat products from Brazil, China, India, Japan, Korea, the Netherlands, Russia and the United Kingdom are being sold at less than fair value and that imports of such goods from Brazil, China, India, Korea and Russia benefit from countervailable subsidies. The alleged dumping margins are as follows.

The petition also identifies 28 different subsidy programs in Brazil, 46 subsidy programs in China, 47 subsidy programs in India, ­­­45 subsidy programs in South Korea and 14 subsidy programs in Russia.

Cold-rolled steel is primarily used in appliances, automotive products, containers and construction. The proposed scope of this investigation covers certain cold-rolled (cold-reduced), flat-rolled steel products, 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 (1) coils that have a width of 12.7 mm wide or greater, regardless of form of coil (e.g., in successively superimposed layers, spirally oscillating, etc.), (2) products not in coils (e.g., in straight lengths) of a thickness less than 4.75 mm and a width that is 12.7 mm or greater and that measures at least 10 times the thickness, and (3) products not in coils (e.g., in straight lengths) of a thickness of 4.75 mm or more and a width exceeding 150 mm and measuring at least twice the thickness. The products described above may be rectangular, square, circular or other shape 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., beveled or rounded at the edges).

Steel products included in the scope of these investigations are products in which (1) iron predominates, by weight, over each of the other contained elements; (2) the carbon content is two percent or less, by weight; and (3) none of the following elements exceeds the quantity, by weight, respectively indicated: 2.50 percent of manganese, 3.30 percent of silicon, 1.50 percent of copper, 1.25 percent of chromium, 0.40 percent of lead, 2.00 percent of nickel, 0.30 percent of tungsten (also called wolfram), 0.80 percent of molybdenum, 0.l0 percent of niobium (also called columbium), 0.30 percent of vanadium, or 0.30 percent of zirconium. Unless specifically excluded, products are included in this scope regardless of levels of boron and titanium.

The subject goods are provided for in Harmonized Tariff Schedule of the United States subheadings 7209.15.0000, 7209.16.0030, 7209.16.0060, 7209.16.0070, 7209.16.0091, 7209.17.0030, 7209.17.0060, 7209.17.0070, 7209.17.0091, 7209.18.1530, 7209.18.1560, 7209.18.2510, 7209.18.2520, 7209.18.2580, 7209.18.6020, 7209.18.6090, 7209.25.0000, 7209.26.0000, 7209.27.0000, 7209.28.0000, 7209.90.0000, 7210.70.3000, 7211.23.1500, 7211.23.2000, 7211.23.3000, 7211.23.4500, 7211.23.6030, 7211.23.6060, 7211.23.6075, 7211.23.6085, 7211.29.2030, 7211.29.2090, 7211.29.4500, 7211.29.6030, 7211.29.6080, 7211.90.0000, 7212.40.1000, 7212.40.5000, 7225.50.6000, 7225.50.8015, 7225.50.8085, 7225.99.0090, 7226.92.5000, 7226.92.7050 and 7226.92.8050. They may also enter under subheadings 7210.90.9000, 7212.50.0000, 7225.19.0000, 7226.19.1000, 7226.19.900 and 7226.99.0180.

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 products. 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.

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