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Initiation of AD/CVD Investigations: Tubing and Alloy Steel

Trade Policy Updates

On May 9, 2017, the Department of Commerce (Commerce) initiated its less-than-fair-value duty investigations on “Certain Cold-Drawn Mechanical Tubing of Carbon and Alloy Steel from the Federal Republic of Germany, India, Italy, the Republic of Korea, the People’s Republic of China, and Switzerland” (Initiation Notice). These investigations have been assigned the following case numbers: A-428-845 (the Federal Republic of Germany), A-533-873 (India), A-475-838 (Italy), A-580-892 (Republic of Korea), A-570-058 (the People’s Republic of China) and A-441-801 (Switzerland). Also on May 9, 2017, Commerce initiated Countervailing Duty Investigations on “Certain Cold-Drawn Mechanical Tubing of Carbon and Alloy Steel from India and the People’s Republic of China.” These investigations have been assigned the following case numbers: C-533-874 (India) and C-570-059 (the People’s Republic of China).

The Scope of Merchandise covered by these investigations reads as follows:

The scope of these investigations covers cold-drawn mechanical tubing of carbon and alloy steel (cold-drawn mechanical tubing) of circular cross-section, in actual outside diameters less than 331 mm, and regardless of wall thickness, surface finish, end finish or industry specification. The subject cold-drawn mechanical tubing is a tubular product with a circular cross-sectional shape that has been cold-drawn or otherwise cold-finished after the initial tube formation in a manner that involves a change in the diameter or wall thickness of the tubing, or both. The subject cold-drawn mechanical tubing may be produced from either welded (e.g., electric resistance welded, continuous welded, etc.) or seamless (e.g., pierced, pilgered or extruded, etc.) carbon or alloy steel tubular products. It may also be heat treated after cold working. Such heat treatments may include, but are not limited to, annealing, normalizing, quenching and tempering, stress relieving or finish annealing. Typical cold-drawing methods for subject merchandise include, but are not limited to, drawing over mandrel, rod drawing, plug drawing, sink drawing and similar processes that involve reducing the outside diameter of the tubing with a die or similar device, whether or not controlling the inside diameter of the tubing with an internal support device such as a mandrel, rod, plug or similar device.

Subject cold-drawn mechanical tubing is typically certified to meet industry specifications for cold-drawn tubing including but not limited to:

(1) American Society for Testing and Materials (ASTM) or American Society of Mechanical Engineers (ASME) specifications ASTM A-512, ASTM A-513 Type 3 (ASME SA513 Type 3), ASTM A-513 Type 4 (ASME SA513 Type 4), ASTM A-513 Type 5 (ASME SA513 Type 5), ASTM A-513 Type 6 (ASME SA513 Type 6), ASTM A-519 (cold-finished);

(2) SAE International (Society of Automotive Engineers) specifications SAE J524, SAE J525, SAE J2833, SAE J2614, SAE J2467, SAE J2435, SAE J2613;

(3) Aerospace Material Specification (AMS) AMS T-6736 (AMS 6736), AMS 6371, AMS 5050, AMS 5075, AMS 5062, AMS 6360, AMS 6361, AMS 6362, AMS 6371, AMS 6372, AMS 6374, AMS 6381, AMS 6415;

(4) United States Military Standards (MIL) MIL-T-5066 and MIL-T-6736;

(5) foreign standards equivalent to one of the previously listed ASTM, ASME, SAE, AMS or MIL specifications including but not limited to:

(a) German Institute for Standardization (DIN) specifications DIN 2391-2, DIN 2393-2, DIN 2394-2);

(b) European Standards (EN) EN 10305-1, EN 10305-2, EN 10305-4, EN 10305-6 and European national variations on those standards (e.g., British Standard (BS EN), Irish Standard (IS EN) and German Standard (DIN EN) variations, etc.);

(c) Japanese Industrial Standard (JIS) JIS G 3441 and JIS G 3445; and

(6) proprietary standards that are based on one of the above-listed standards.

The subject cold-drawn mechanical tubing may also be dual or multiple certified to more than one standard. Pipe that is multiple certified as cold-drawn mechanical tubing and to other specifications not covered by this scope, is also covered by the scope of these investigations when it meets the physical description set forth above.

Steel products included in the scope of these investigations are products in which: (1) iron predominates, by weight, over each of the other contained elements; and (2) the carbon content is 2 percent or less by weight.

For purposes of this scope, the place of cold-drawing determines the country of origin of the subject merchandise. Subject merchandise that is subject to minor working in a third country that occurs after drawing in one of the subject countries including, but not limited to, heat treatment, cutting to length, straightening, nondestruction testing, deburring or chamfering, remains within the scope of the investigations.

All products that meet the written physical description are within the scope of these investigations unless specifically excluded or covered by the scope of an existing order. Merchandise that meets the physical description of cold-drawn mechanical tubing above is within the scope of the investigations even if it is also dual or multiple certified to an otherwise excluded specification listed below. The following products are outside of, and/or specifically excluded from, the scope of these investigations:

(1) cold-drawn stainless steel tubing, containing 10.5 percent or more of chromium by weight and not more than 1.2 percent of carbon by weight;

(2) products certified to one or more of the ASTM, ASME or American Petroleum Institute (API) specifications listed below:

• ASTM A-53; • ASTM A-106; • ASTM A-179 (ASME SA 179); • ASTM A-192 (ASME SA 192); • ASTM A-209 (ASME SA 209); • ASTM A-210 (ASME SA 210); • ASTM A-213 (ASME SA 213); • ASTM A-334 (ASME SA 334); • ASTM A-423 (ASME SA 423); • ASTM A-498; • ASTM A-496 (ASME SA 496); • ASTM A-199; • ASTM A-500; • ASTM A-556; • ASTM A-565; • API 5L; and • API 5CT

except that any cold-drawn tubing product certified to one of the above excluded specifications will not be excluded from the scope if it is also dual- or multiple-certified to any other specification that otherwise would fall within the scope of these investigations.

The products subject to the investigations are currently classified in the Harmonized Tariff Schedule of the United States (HTSUS) under item numbers: 7304.31.3000, 7304.31.6050, 7304.51.1000, 7304.51.5005, 7304.51.5060, 7306.30.5015, 7306.30.5020, 7306.50.5030. Subject merchandise may also enter under numbers 7306.30.1000 and 7306.50.1000. The HTSUS subheadings above are provided for convenience and customs purposes only. The written description of the scope of the investigations is dispositive.

Requirements For Submitting Comments On The Scope Of The Investigations: Please be sure to comply with all three requirements established below.

Deadline for Submitting Comments:

As announced in the Initiation Notices, Commerce is setting aside a period for interested parties to raise issues regarding product coverage (scope). The period for scope comments is intended to provide Commerce with ample opportunity to consider all comments and to consult with parties prior to the issuance of the preliminary determinations, as appropriate. If scope comments include factual information (see 19 CFR 351.102(b)(21)), all such factual information should be limited to public information. Commerce requests that all such comments be filed by 5:00 p.m. Eastern Time (ET) on Tuesday, May 30, 2017, which is 20 calendar days from the signature date of the Initiation Notice. Any rebuttal comments, which may include factual information, must be filed by 5:00 p.m. ET on Friday, June 9, 2017, which is 10 calendar days after the initial comments deadline. Commerce requests that any factual information the parties consider relevant to the scope of the investigations be submitted during this time period. However, if a party subsequently finds that additional factual information pertaining to the scope of the investigations may be relevant, the party may contact Commerce and request permission to submit the additional information. All such comments must be filed on the records of each of the concurrent AD and CVD investigations.

Required Entry of Appearance:

Parties wishing to participate in this segment and be included on the public service list must file a letter of appearance. Section 351.103(d)(1) of Commerce’s regulations states that “with the exception of a petitioner filing a petition in an investigation, to be included on the public service list for a particular segment, each interested party must file a letter of appearance.” The letter of appearance must be filed separately from any other document (with the exception of an application for APO access). Note, the letter of appearance must state how the party qualifies as an interested party (e.g., an exporter, producer, importer of the subject merchandise) and must include a point of contact, including address, telephone/fax number and email address.

All submissions to Commerce must be filed electronically using Enforcement and Compliance’s Antidumping and Countervailing Duty Centralized Electronic Service System (ACCESS). An electronically-filed document must be received successfully in its entirety by the time, typically 5 p.m., and date when it is due. Documents excepted from the electronic submission requirements must be filed manually (i.e., in paper form) with Enforcement and Compliance’s APO/Dockets Unit, Room 18022, U.S. Department of Commerce, 14th Street and Constitution Avenue NW., Washington, DC 20230, and stamped with the date and time of receipt by the applicable deadlines.

For your convenience, Commerce has the following resources available online to assist you in complying with these electronic filing procedures:

ACCESS: Help Link

ACCESS: External User Guide

ACCESS: Handbook on Electronic Filing Procedures

Federal Register notice: Antidumping and Countervailing Duty Proceedings: Electronic Filing Procedures; Administrative Protective Order Procedures, 76 FR 39263 (July 6, 2011)

Enforcement and Compliance: Change of Electronic Filing System Name, 79 FR 69046 (November 20, 2014)

Enforcement and Compliance: General Filing Requirements

Required Certifications:

Please note that the following certification requirements are in effect for company / government officials as well as their representatives. In all segments of antidumping duty or countervailing duty proceedings initiated on or after August 16, 2013, parties submitting factual information must use the formats for the certifications provided at the end of the Final Rule. See Certification of Factual Information to Import Administration During Antidumping and Countervailing Duty Proceedings, 78 FR 42678 (July 17, 2013) (Final Rule). See also the frequently asked questions regarding the Final Rule, available at

For Further Information Contact:

AD/CVD Operations, Enforcement and Compliance, U.S. Department of Commerce, 1401 Constitution Avenue, NW, Washington, DC 20230:

Frances Veith at (202) 482-4295 (Federal Republic of Germany) (AD);

Shanah Lee at (202) 482-6386 (Federal Republic of Germany) (AD);

Omar Qureshi at (202) 482-5307 (India) (AD);

Laurel LaCivita at (202) 482-4243 (Italy) (AD);

Annathea Cook at (202) 482-0250 (Republic of Korea) (AD);

Paul Stolz at (202) 482-4474 (People’s Republic of China) (AD);

Amanda Brings at (202) 482-3927 (Switzerland) (AD);

Elfie Blum at (202) 482-0197 (India) (CVD); Yasmin Bordas at (202) 482-3813 (the People’s Republic of China) (CVD).

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