Background

The Department of Commerce has self-initiated new inquiries to determine whether imports of corrosion-resistant steel products completed in Costa Rica, Guatemala, Malaysia, South Africa, and the United Arab Emirates using Chinese-origin substrate, or imports of CORE completed in Malaysia using Taiwanese-origin substrate, are circumventing the antidumping and countervailing duty orders on CORE from China as well as the AD duty order on CORE from Taiwan.

This is the first time the DOC has self-initiated an anti-circumvention inquiry based on its own monitoring of trade patterns. It is also the first self-initiation of multi-country anti-circumvention inquiries.

If the DOC preliminarily determines that circumvention is occurring, it will instruct U.S. Customs and Border Protection to begin collecting AD/CV cash deposits on imports of subject goods from the countries listed above. Duty liability may be imposed on future imports and on any unliquidated entries since the date of initiation of the anti-circumvention inquiries.

The DOC will next solicit information from producers and exporters of the goods under investigation. There will be strict deadlines associated with these proceedings, so companies that wish to protect their interests should contact Sandler, Travis & Rosenberg as soon as possible.

For more information please contact Kristen Smith at (202) 730-4965.

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Kristen S. Smith
Member, Trade Remedies Practice Group Leader

ST&R: International Trade Law & Policy

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