April 3, 2017

New Antidumping Petition on Carton-Closing Staples from China

By Douglas J. Heffner and Richard P. Ferrin

North American Steel & Wire., Inc./ISM Enterprises has filed an antidumping (AD) petition on imports of carton-closing staples from China.

The U.S. AD law imposes special tariffs to counteract imports that are sold in the United States at less than “normal value.” For AD duties to be imposed, the U.S. government must determine not only that dumping 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 duties imposed. These investigations could also impact purchasers by increasing prices and/or decreasing supply of carton-closing staples.


The petitioner proposes the following scope of investigation:

The scope of this investigation is carton-closing staples. Carton-closing staples are fastening devices used to secure or close the flaps of corrugated and solid paperboard cartons and boxes. Carton-closing staples are manufactured from steel wire, and commonly have a copper coating or a zinc (galvanized) coating. Carton-closing staples manufactured from stainless steel wire are also covered.

Carton-closing staples include stick staple products, often referred to as staple strips, and roll staple products, often referred to as coils. Stick staples are lightly cemented or lacquered together to facilitate handling and loading into stapling machines. Roll staples are taped together along their crowns.

Carton-closing staples vary by the size of the wire, the width of the crown, and the length of the leg. The leg length generally ranges from 0.45 inch to 1.375 inches and the crown width generally ranges from 1.125 inches to 1.375 inches. The size of the wire used in the production of carton-closing staples generally varies from 0.033 to 0.058 inch (thickness) by 0.072 to 0.096 inch (width). Staples that deviate from these dimensions by 10 percent or less in any aspect are covered.

All carton-closing staples meeting the physical descriptions in this scope are covered, regardless of whether they are coated, uncoated, or the type of coating; whether they are produced from steel wire or stainless steel wire; and whether they are imported in stick form or roll form.

Carton-closing staples subject to this investigation are currently classifiable under subheadings 8305.20.00.00 and 7317.00.65.60 of the Harmonized Tariff Schedule of the United States (HTSUS). While HTSUS subheadings are provided for convenience and for customs purposes, the written description of the subject merchandise is dispositive. To the extent that carton-closing staples that meet the scope description are imported under these or other HTS categories not listed above, they are intended to be covered.

Alleged Dumping Margins:

Petitioners allege dumping margins ranging from 15.8 percent to 148.8 percent.

Estimated Schedule of Investigations:

  • March 31, 2017 – Petition is filed
  • April 20, 2017 – DOC initiates AD investigation
  • April 21, 2017 – ITC staff conference (estimated)
  • May 15, 2017 – Deadline for ITC preliminary injury determination
  • September 7, 2017 – Deadline for DOC preliminary AD determination, if deadline is not postponed
  • October 27, 2017 – Deadline for DOC preliminary AD determination, if deadline is fully postponed
  • March 12, 2018 – Deadline for DOC final AD determination, if both preliminary and final AD determinations are fully postponed
  • April 26, 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.

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