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March 29, 2017

New Antidumping and Countervailing Duty Petitions on Carbon and Alloy Steel Wire Rod from 10 Countries

By Douglas J. Heffner and Richard P. Ferrin

Antidumping (AD) petitions were filed with the U.S. Department of Commerce (DOC) and U.S. International Trade Commission (ITC) on March 28, 2017, regarding carbon and alloy steel wire rod from Belarus, Italy, Korea, Russia, South Africa, Spain, Turkey, Ukraine, United Arab Emirates, and the United Kingdom. In addition, countervailing duty (CVD) petitions were filed on carbon and alloy steel wire rod from Italy and Turkey.  The petitioners are Gerdau Ameristeel US Inc., Nucor Corporation, Keystone Consolidated Industries, and Charter Steel.

The U.S. AD law imposes special tariffs to counteract imports that are sold in the United States at less than “normal value.” The U.S. CVD law imposes special tariffs to counteract imports sold in the United States that benefit from unfair foreign government subsidies. For AD and CVD duties to be imposed, the U.S. government must determine not only that dumping and subsidization is occurring, but also that there is “material injury” (or threat thereof) by reason of the dumped imports.  Importers are liable for any potential AD/CVD duties imposed.  In addition, these investigations could impact purchasers, by either increasing prices, and/or decreasing supply of carbon and alloy steel wire rod.


The merchandise covered by these investigations are certain hot-rolled products of carbon steel and alloy steel, in coils, of approximately round cross section, less than 19.00 mm in actual solid cross-sectional diameter. Specifically excluded are steel products possessing the above-noted physical characteristics and meeting the Harmonized Tariff Schedule of the United States (HTSUS) definitions for (a) stainless steel; (b) tool steel; (c) high nickel steel; (d) ball bearing steel; or (e) concrete reinforcing bars and rods. Also excluded are free cutting steel (also known as free machining steel) products (i.e., products that contain by weight one or more of the following elements: 0. 1 percent or more of lead, 0.05 percent or more of bismuth, 0.08 percent or more of sulfur, more than 0.04 percent of phosphorous, more than 0.05 percent of selenium, or more than 0.01 percent of tellurium). All products meeting the physical description of subject merchandise that are not specifically excluded are included in this scope.

The products under investigation are currently classifiable under subheadings 7213.91.3011, 7213.91.3015, 7213.91.3020, 7213.91.3093, 7213.91.4500, 7213.91.6000, 7213.99.0030, 7227.20.0030, 7227.20.0080, 7227.90.6010, 7227.90.6020, 7227.90.6030, and 7227.90.6035 of the HTSUS. Products entered under subheadings 7213 .99.0090 and 7227.90.6090 of the HTSUS also may be included in this scope if they meet the physical description of subject merchandise above. Although the HTSUS subheadings are provided for convenience and customs purposes, the written description of the scope of this proceeding is dispositive.

Alleged Dumping Margins:

  • Belarus – 179.07-304.94%
  • Italy – 26.36%
  • Korea – 41.72-53.09%
  • Russia – 216.50-821.40%
  • South Africa – 159.35-164.08%
  • Spain – 32.64%
  • Turkey – 45.10%
  • Ukraine – 21.64-61.64%
  • UAE – 69.57%
  • UK – 88.25%

The petitions also allege that the governments of Italy and Turkey are providing countervailable subsidies to producers of wire rod.

Estimated Schedule of Investigations:

  • March 28, 2017 – Petitions are filed
  • April 17, 2017 – DOC initiates AD/CVD investigations
  • April 18, 2017 – ITC staff conference
  • May 12, 2017 – Deadline for ITC preliminary injury determination
  • June 21, 2017 – Deadline for DOC preliminary CVD determination, if deadline is not postponed
  • August 25, 2017 – Deadline for DOC preliminary CVD determination, if deadline is fully postponed
  • September 5, 2017 – Deadline for DOC preliminary AD determination, if deadline is not postponed
  • October 24, 2017 – Deadline for DOC preliminary AD determination, if deadline is fully postponed
  • March 8, 2018 – Deadline for DOC final AD and CVD determinations, if both preliminary and final AD determinations are fully postponed and CVD deadline is aligned
  • April 23, 2018 – Deadline for ITC final injury determination, assuming fully postponed DOC deadlines

For further information, contact the authors below, or any other member of the Customs and International Trade Team.

The material contained in this communication is informational, general in nature and does not constitute legal advice. The material contained in this communication should not be relied upon or used without consulting a lawyer to consider your specific circumstances. This communication was published on the date specified and may not include any changes in the topics, laws, rules or regulations covered. Receipt of this communication does not establish an attorney-client relationship. In some jurisdictions, this communication may be considered attorney advertising.

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