A petition filed Jan. 8 alleges that wood moldings and millwork products from Brazil and China are being sold at less than fair value in the U.S. market and that such items from China are benefitting from countervailable subsidies. The alleged average dumping margins are 268.74 percent for Brazil and 289.70 to 361.83 percent for China.

The items subject to this petition are wood moldings and millwork products made of wood (regardless of wood species), laminated veneer lumber, or wood and composite materials (where the composite materials make up less than 50 percent of the total good) that are woodwork or building materials that are produced in a mill or otherwise undergo remanufacturing. Covered products include interior and exterior door frames or jambs, frame or jamb kits, packaged door frame trim or casing sets, mullions, mull posts, moldings stops, sashes, base moldings, casing, trim, panel strips, shelf cleats, chamfer strips, inside corners, window stools, sills, door stiles, thresholds/saddles, decorative wood moldings, rosettes, plinth blocks, interior siding that is LVL or finger jointed and/or coated with any surface coating, and finger-jointed or edge-glued molding or millwork blanks.

These products may be solid wood, laminated, finger-jointed, edge-glued, or otherwise joined in the production or remanufacturing process. They are covered whether imported raw, coated, primed, painted, stained, wrapped, or treated; regardless of whether or not any surface coating(s) or covers obscure the grain, textures, or markings of the wood; whether or not they are ready for use or require final machining or packaging; and whether or not they are trimmed, cut-to-size, notched, punched, or drilled or have undergone other forms of minor processing.

Subject goods also include wood moldings and millwork products that have been further processed in a third country, including trimming, cutting, notching, punching, drilling, coating, or any other processing that would not otherwise remove the goods from the scope if performed in the country of manufacture of the in-scope product.

Imports of wood moldings and millwork products are primarily entered under HTSUS subheadings 4409.10.4010, 4409.10.4090, 4409.10.4500, 4409.10.5000, 4409.22.4000, 4409.22.5000, 4409.29.4000, 4409.29.4100, 4409.29.5000, and 4409.29.5100 and may also enter under HTSUS subheadings 4409.10.6000, 4409.10.6500, 4409.22.6000, 4409.22.6500, 4409.29.6100,4409.29.6600,4418.99.9095 and 4421.99.9780.

Excluded from the scope of the petition are (1) exterior fencing, exterior decking and exterior siding products, finished and unfinished doors, flooring, and parts of stair steps and (2) all products covered by the scope of the antidumping and countervailing duty orders on hardwood plywood and multilayered wood flooring from China.

The Department of Commerce and the International Trade Commission will next determine whether to launch AD and/or CV duty and injury investigations, respectively, on these products. There are strict statutory deadlines associated with these proceedings, so affected companies that wish to protect their interests should contact Sandler, Travis & Rosenberg as soon as possible.

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

Copyright © 2023 Sandler, Travis & Rosenberg, P.A.; WorldTrade Interactive, Inc. All rights reserved.


Kristen S. Smith
Partner, Advisory Committee; Trade Remedies Practice Group Leader

ST&R: International Trade Law & Policy

Since 1977, we have set the standard for international trade lawyers and consultants, providing comprehensive and effective customs, import and export services to clients worldwide.

View Our Services


Cookie Consent

We have updated our Privacy Policy relating to our use of cookies on our website and the sharing of information. By continuing to use our website or subscribe to our publications, you agree to the Privacy Policy and Terms & Conditions.