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Corrosion-Resistant Steel: New AD/CVD Investigations Deadlines & Scope

The Commerce Department issued Federal Register notices on its recently initiated antidumping and countervailing duty investigations on corrosion-resistant steel products from China (A-570-026/C-570-027), India (A-533-863/C-570-864), Italy (A-475-832/C-475-833), South Korea (A-580-878/C-570-879), and Taiwan (A-583-856/C-570-857).

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The AD period of investigation for China is Oct. 1, 2014, through March 31, 2015. The AD period of investigation for all other investigated countries is April 1, 2014, through March 31, 2015. The CVD period of investigation for all countries is Jan. 1, 2014, through Dec. 31, 2014.

AD/CVD Respondent Selection

For its China AD duty investigation, Commerce will send quantity and value questionnaires to each potential respondent, and will base respondent selection on the responses it receives. Chinese exporters that don't get a quantity and value questionnaire can still submit one. Commerce said it will post a copy of the quantity and value questionnaire on its website (here). Questionnaire responses are due July 7.

For the other AD duty investigations, Commerce said it will pick respondents based on the petitions for the investigations and CBP data. Comments on respondent selection in the AD duty investigations on corrosion-resistant steel products from Italy, India, South Korea and Taiwan are due July 6.

Commerce said it will rely on CBP data to pick the respondents for the CVD investigations. Comments on CVD respondent selection are due by July 7.

Scope of the AD/CVD Investigations

"The products covered by this investigation are certain flat-rolled steel products, either clad, plated, or coated with corrosion-resistant metals such as zinc, aluminum, or zinc-, aluminum-, nickel- or iron-based alloys, whether or not corrugated or painted, varnished, laminated, or coated with plastics or other non-metallic substances in addition to the metallic coating. The products covered include coils that have a width of 12.7 mm or greater, regardless of form of coil (e.g., in successively superimposed layers, spirally oscillating, etc.). The products covered also include 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. The products covered also include 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 which have been "worked after rolling" (e.g., products which have been beveled or rounded at the edges). For purposes of the width and thickness requirements referenced above:

  • (1) where the nominal and actual measurements vary, a product is within the scope if application of either the nominal or actual measurement would place it within the scope based on the definitions set forth above, and
  • (2) where the width and thickness vary for a specific product (e.g., the thickness of certain products with non-rectangular cross-section, the width of certain products with non-rectangular shape, etc.), the measurement at its greatest width or thickness applies.

"Steel products included in the scope of this investigation are products in which: (1) iron predominates, by weight, over each of the other contained elements; (2) the carbon content is 2 percent or less, by weight; and (3) none of the elements listed below exceeds the quantity, by weight, respectively indicated:

  • 2.50 percent of manganese, or
  • 3.30 percent of silicon, or
  • 1.50 percent of copper, or
  • 1.50 percent of aluminum, or
  • 1.25 percent of chromium, or
  • 0.30 percent of cobalt, or
  • 0.40 percent of lead, or
  • 2.00 percent of nickel, or
  • 0.30 percent of tungsten (also called wolfram), or
  • 0.80 percent of molybdenum, or
  • 0.10 percent of niobium (also called columbium), or
  • 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.

"For example, specifically included in this scope are vacuum degassed, fully stabilized (commonly referred to as interstitial-free (IF)) steels and high strength low alloy (HSLA) steels. IF steels are recognized as low carbon steels with micro-alloying levels of elements such as titanium and/or niobium added to stabilize carbon and nitrogen elements. HSLA steels are recognized as steels with micro-alloying levels of elements such as chromium, copper, niobium, titanium, vanadium, and molybdenum.

"Furthermore, this scope also includes Advanced High Strength Steels (AHSS) and Ultra High Strength Steels (UHSS), both of which are considered high tensile strength and high elongation steels.

"All products that meet the written physical description, and in which the chemistry quantities do not exceed any one of the noted element levels listed above, are within the scope of this investigation unless specifically excluded. The following products are outside of and/or specifically excluded from the scope of this investigation:

  • Flat-rolled steel products either plated or coated with tin, lead, chromium, chromium oxides, both tin and lead ("terne plate"), or both chromium and chromium oxides ("tin free steel"), whether or not painted, varnished or coated with plastics or other non-metallic substances in addition to the metallic coating;
  • Clad products in straight lengths of 4.7625 mm or more in composite thickness and of a width which exceeds 150 mm and measures at least twice the thickness; and
  • Certain clad stainless flat-rolled products, which are three-layered corrosionresistant flat-rolled steel products less than 4.75 mm in composite thickness that consist of a flat-rolled steel product clad on both sides with stainless steel in a 20%-60%-20% ratio.

"The products subject to the investigation are currently classified in the Harmonized Tariff Schedule of the United States (HTSUS) under item numbers: 7210.30.0030, 7210.30.0060, 7210.41.0000, 7210.49.0030, 7210.49.0091, 7210.49.0095, 7210.61.0000, 7210.69.0000, 7210.70.6030, 7210.70.6060, 7210.70.6090, 7210.90.6000, 7210.90.9000, 7212.20.0000, 7212.30.1030, 7212.30.1090, 7212.30.3000, 7212.30.5000, 7212.40.1000, 7212.40.5000, 7212.50.0000, and 7212.60.0000.

"The products subject to the investigation may also enter under the following HTSUS item numbers: 7210.90.1000, 7215.90.1000, 7215.90.3000, 7215.90.5000, 7217.20.1500, 7217.30.1530, 7217.30.1560, 7217.90.1000, 7217.90.5030, 7217.90.5060, 7217.90.5090, 7225.91.0000, 7225.92.0000, 7225.99.0090, 7226.99.0110, 7226.99.0130, 7226.99.0180, 7228.60.6000, 7228.60.8000, and 7229.90.1000.

"The HTSUS subheadings above are provided for convenience and customs purposes only. The written description of the scope of the investigation is dispositive."

Comments on Scope Due July 13

Participants in the AD/CVD investigations may submit comments on product coverage under the scope of the investigations. Comments on the scope are due by July 13.

Investigations Timetable

EventAD DutyCV Duty
Petitions filed06/03/1506/03/15
DOC initiation date06/23/1506/23/15
ITC prelim determinations*07/20/1507/20/15
DOC prelim determinations†11/20/1508/27/15
DOC final determinations†01/25/1611/10/15
ITC final determinations‡03/09/1612/28/15
Issuance of orders+03/16/1601/04/16

*If the ITC makes a negative determination of injury, the investigations are terminated.

†These deadlines may be extended under the governing statute.

‡This will take place only in the event of Commerce Department final affirmative determinations.

+This will take place only in the event of Commerce and ITC final affirmative determinations.

(See 1506080026 for summary of the Commerce Department's receipt of the petition underlying the initiation of this investigation.)

The AD duty initiation notice is (here).

The CV duty initiation notice is (here).

The Commerce Department fact sheet on the initiation of these investigations is (here).