China Aluminum Extrusions: Importer's Trade Show Booth Kits Exempt from AD/CV Duties
Trade booth kits imported by Glenmore Industries are not subject to antidumping and countervailing duties on aluminum extrusions from China (A-570-967/C-570-968), said the Commerce Department in a scope ruling issued June 23. The trade show displays meet an exception from the duties for “finished goods kits” because they contain everything necessary to assemble a finished trade show booth in a single shipment, even if it may come in multiple containers, said Commerce. They also meet the requirement to have both aluminum extrusions and non-aluminum extrusions parts, it said.
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The trade booth kits imported by Glenmore are assembled into commercial display spaces for use at trade shows, conventions, fairs and other exhibitions. They include fabric-covered wall panels, fabric-covered aluminum headers, and aluminum posts (columns) and crossbeams. They also include connectors that are riveted onto the parts prior to importation so that all of the parts can be snapped together when they arrive at the trade show. No other parts are needed to assemble a completed trade show booth. Because of the size of the trade booth kits, they may be imported in multiple containers, but they’re listed on the same CBP Form 7501 Entry Summary. Each shipment is specific to a final customer.
The AD/CV duty orders on aluminum extrusions from China exempt “finished goods kits,” which are defined as "a packaged combination of parts that contains, at the time of importation, all of the necessary parts to fully assemble a final finished good and requires no further finishing or fabrication, such as cutting or punching, and is assembled 'as is' into a finished product." Commerce has ruled in previous scope rulings that, in order to qualify for the exemption, the kit cannot consist only of aluminum extrusions and fasteners.
Commerce found that Glenmore’s trade booths fit the bill as “finished goods kits.” The kits as imported contain all of the parts necessary to assemble a finished trade booth, and all of the pieces are shipped to the customer on a single entry without having to be repackaged. Also, the kits are imported with non-aluminum extrusions components because they come with fabric-covered wall panels and aluminum headers, as well as a portable carrying case.
Commerce dismissed an argument from a U.S. company that Glenmore shouldn’t be allowed to request the scope ruling because it hadn’t yet imported the product before it filed its request. Under agency rules on scope rulings, a "product need not be imported into the United States so long as the requestor can show evidence that the product is in production," which was the case with Glenmore’s trade booth kits.
Email ITTNews@warren-news.com for a copy of the scope ruling.