January 26, 2018

New Antidumping and Countervailing Duty Petitions on Cast Iron Soil Pipe from China

By Douglas J. Heffner and Richard P. Ferrin

The Cast Iron Soil Pipe Institute (CISPI) and its individual members, on January 26, 2018, filed antidumping (AD) and countervailing duty (CVD) petitions on cast iron soil pipe (CISP) from China. Individual CISPI members associated with the petition are AB&I Foundry, Charlotte Pipe & Foundry and Tyler Pipe. The most recent AD petitions for CISP involved Australia in 1964 and Poland in 1967, resulting in negative and positive determinations of injury, respectively. A separate investigation into cast iron soil pipe fittings from China is currently pending.

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 that are sold in the United States with the benefit of foreign government subsidies. For AD/CVD duties to be imposed, the U.S. government must determine not only that dumping and/or subsidies are occurring, but also that there is “material injury” (or threat thereof) by reason of the dumped and/or subsidized imports. Importers are liable for any potential AD/CVD duties imposed. In addition, these investigations could impact purchasers by increasing prices and/or decreasing supply of CISP.


The merchandise covered by this investigation is cast iron soil pipe, whether finished or unfinished, regardless of industry or proprietary specifications, and regardless of wall thickness, length, diameter, surface finish, end finish, or stenciling. The scope of this investigation includes, but is not limited to, both hubless and hub and spigot cast iron soil pipe. CISP is nonmalleable iron pipe of various designs and sizes. Cast iron soil pipe is generally distinguished from other types of nonmalleable cast iron pipe by the manner in which it is connected to cast iron soil pipe fittings.

CISP is classified into two major types – hubless and hub and spigot. Hubless cast iron soil pipe is manufactured without a hub, generally in compliance with CISPI specification 301 and/or American Society for Testing and Materials (“ASTM”) specification A888. Hub and spigot pipe has one or more hubs into which the spigot (plain end) of a fitting is inserted. All pipe meeting the physical description set forth above is covered by the scope of this investigation, whether or not produced according to a particular standard.

The subject imports are currently classified under HTSUS 7303.00.0030. The HTSUS subheading and specifications are provided for convenience and customs purposes only; the written description of the scope of this investigation is dispositive.

Alleged Dumping Margins

The petitioners allege a dumping margin of 238.13 percent.

Estimated Schedule of Investigations

  • January 26, 2018 – Petition is filed
  • February 15, 2018 – DOC initiates investigation
  • February 16, 2018 – ITC staff conference
  • March 13, 2018 – Deadline for ITC preliminary injury determinations
  • April 23, 2018 – Deadline for DOC preliminary CVD determination, if not postponed
  • June 25, 2018 – Deadline for DOC preliminary CVD determination, if fully postponed
  • July 5, 2018 – Deadline for DOC preliminary AD determination, if not postponed
  • August 24, 2018 – Deadline for DOC preliminary AD determination, if fully postponed
  • January 7, 2019 – Deadline for DOC final AD and CVD determinations, if both preliminary and final AD determination deadlines are fully postponed
  • February 20, 2019 – Deadline for ITC final injury determinations, assuming fully postponed DOC deadlines

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

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