A petition filed Dec. 27 alleges that plastic decorative ribbon from China is being sold at less than fair value in the U.S. market and benefitting from countervailable subsidies. The alleged dumping margins range from 74.34 percent to 370.04 percent.

The petition covers certain plastic decorative ribbon having a width of less than or equal to four inches in actual measurement, including (1) ribbon wound onto itself, (2) a spool, core, or tube (with or without flanges), (3) ribbon attached to a card or strip, (4) ribbon wound into a keg- or egg-shaped configuration, (5) ribbon made into bows, bow-like items, or other shapes or configurations, and (6) whether or not packaged or labeled for retail sale.

Subject goods include ribbon comprised of one or more layers of substrates made, in whole or in part, of plastics adhered to each other or substrates made of non-plastic materials (including fabric), regardless of the method used to adhere the layers together. Ribbons may be of any color or combination of colors (including those that are transparent, translucent, or opaque) and may or may not bear words or images. Subject goods include ribbons with embellishments and/or treatments, including those that are printed, hot-stamped, coated, laminated, flocked, crimped, die-cut, or embossed as well as ribbons with holographic, metallic, glitter, or iridescent finishes.

Also covered are (1) pull-bows, an assemblage of ribbons connected to one another, folded flat, and equipped with a means to form such ribbons into the shape of a bow by pulling on a length of material affixed to such assemblage, and (2) pre-notched bows, an assemblage of notched ribbon loops arranged one inside the other with the notches in alignment and affixed to each other where notched, and which the user forms into a bow by separating and spreading the loops circularly around the notches, which form the center of the bow.

Subject goods include ribbons packaged with non-subject goods, including ensembles that include ribbons and other products, such as gift wrap, gift bags, gift tags and/or other gift packaging products.

Subject ribbons are currently classified under HTSUS 3920.20.0015 and 3926.40.0010 and may also enter under HTSUS 3920.10.0000, 3920.30.0000, 3920.43.5000, 3920.49.0000, 3920.62.0020, 3920.62.0050, 3920.62.0090, 3920.69.0000, 3921.90.1100, 3921.90.1500, 3921.90.1910, 3921.90.1950, 3921.90.4010, 3921.90.4090, 4926.90.9905, 3926.90.9910, 3926.90.9925, 3926.90.9930, 3926.90.9996, 5404.90.0000 ,9505.90.4000, 4601.99.9000, 4602.90.0000, 5609.00.3000, 5609.00.4000, and 9505.10.2500.

Excluded from the petition are (1) ribbons formed exclusively by weaving plastic threads together, (2) ribbons that have metal wire in, on, or along the entirety of each of the longitudinal edges, (3) ribbons with an adhesive coating covering the entire span between the longitudinal edges for the entire length of the ribbon, (4) ribbon formed into a bow without a tab or other means for attaching the bow to an object using adhesives where the bow has (a) an outer layer that is either flocked or made of fabric and (b) a flexible metal wire at the base that is suitable for attaching the bow to a Christmas tree or other object by twist-tying, (5) elastic ribbons (i.e., those that elongate when stretched and return to their original dimension when the stretching load is removed), (6) ribbons affixed as a decorative detail to non-subject goods such as a gift bag, gift box, gift tin, greeting card, or plush toy or affixed (including by tying) as a decorative detail to packaging containing non-subject goods, (7) ribbons that are (a) affixed to non-subject goods as a working component, such as where the ribbon comprises a book marker, bag cinch, or part of an identity card holder, or (b) affixed (including by tying) to non-subject goods as a working component that holds or packages those goods or attaches packaging or labeling to them (e.g., a belly band around a pair of pajamas, a pair of socks, or a blanket), (8) imitation raffia made of plastics having a thickness not more than one mil when measured in an unfolded/untwisted state, and (9) ribbons in the form of bows having a diameter of less than 7/8 of an inch or more than 16 inches.

The Department of Commerce and the International Trade Commission will next determine whether to launch AD/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 David Craven at (312) 279-2844.

Copyright © 2021 Sandler, Travis & Rosenberg, P.A.; WorldTrade Interactive, Inc. All rights reserved.


Kristen S. Smith
Member, Trade Remedies Practice Group Leader

ST&R: International Trade Law & Policy

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