July 09, 2020

New Antidumping, Countervailing Duty Petitions on Seamless Carbon and Alloy Steel Standard, Line, and Pressure Pipe Filed

On July 8, 2020, Vallourec Star, LP filed antidumping (AD) petitions on seamless carbon and alloy steel standard, line and pressure pipe (SSLPP) from the Czech Republic, Korea, Russia and Ukraine, as well as a countervailing duty (CVD) petition on SSLPP from Korea and Russia. In addition to Petitioner Vallourec Star, the petitions are also supported by United States Steel Corporation.

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 SSLPP.


Per the petition:

The merchandise covered by the scope of these investigations is seamless carbon and alloy steel (other than stainless steel) pipes and redraw hollows, less than or equal to 16 inches (406.4 mm) in outside diameter, regardless of wall-thickness, manufacturing process (e.g., hotfinished or cold-drawn), end finish (e.g., plain end, beveled end, upset end, threaded, or threaded and coupled), or surface finish (e.g., bare, lacquered or coated). Redraw hollows are any unfinished carbon or alloy steel (other than stainless steel) pipe or “hollow profiles” suitable for cold finishing operations, such as cold drawing, to meet the American Society for Testing and Materials (“ASTM”) or American Petroleum Institute (“API”) specifications referenced below, or comparable specifications. Specifically included within the scope are seamless carbon and alloy steel (other than stainless steel) standard, line, and pressure pipes produced to the ASTM A-53, ASTM A-106, ASTM A-333, ASTM A-334, ASTM A-589, ASTM A-795, ASTM A-1024, and the API 5L specifications, or comparable specifications, and meeting the physical parameters described above, regardless of application, with the exception of the exclusions discussed below.

Specifically excluded from the scope of the investigations are: (1) all pipes meeting aerospace, hydraulic, and bearing tubing specifications; (2) all pipes meeting the chemical requirements of ASTM A-335, whether finished or unfinished; and (3) unattached couplings. Also excluded from the scope of the investigation are all mechanical, boiler, condenser and heat exchange tubing, except when such products conform to the dimensional requirements, i.e., outside diameter and wall thickness, of ASTM A-53, ASTM A-106 or API 5L specifications.

Subject seamless standard, line, and pressure pipe are normally entered under HTSUS 7304.19.1020, 7304.19.1030, 7304.19.1045, 7304.19.1060, 7304.19.5020, 7304.19.5050, 7304.31.6050, 7304.39.0016, 7304.39.0020, 7304.39.0024, 7304.39.0028, 7304.39.0032, 7304.39.0036, 7304.39.0040, 7304.39.0044, 7304.39.0048, 7304.39.0052, 7304.39.0056, 7304.39.0062, 7304.39.0068, 7304.39.0072, 7304.51.5005, 7304.51.5060, 7304.59.6000, 7304.59.8010, 7304.59.8015, 7304.59.8020, 7304.59.8025, 7304.59.8030, 7304.59.8035, 7304.59.8040, 7304.59.8045, 7304.59.8050, 7304.59.8055, 7304.59.8060, 7304.59.8065, 7304.59.8070. The HTSUS subheadings and specifications are provided for convenience and customs purposes; the written description of the scope is dispositive.

Estimated Dumping Margins

  • Czech Republic: 48.18% to 49.24%
  • Korea: 119.07% to 132.16%
  • Russia: 30.31% to 246.31%
  • Ukraine: 40.28% to 40.44%

Estimated Schedule of Investigation

The following is an estimated schedule of investigations by the U.S. Department of Commerce (DOC) and the U.S. International Trade Commission (ITC):

  • July 8, 2020  Petition is filed
  • July 28, 2020   DOC initiates investigation
  • July 29, 2020  ITC staff conference (estimated)
  • August 24, 2020  Deadline for ITC preliminary injury determination
  • October 1, 2020  Deadline for DOC preliminary CVD determinations, if deadlines are NOT postponed
  • December 7, 2020 Deadline for DOC preliminary CVD determinations, if deadlines are fully postponed
  • December 15, 2020 Deadline for DOC preliminary AD determinations, if deadlines are NOT postponed
  • February 3, 2021  Deadline for DOC preliminary AD determinations, if deadlines are fully postponed
  • June 18, 2021   Deadline for DOC final AD and CVD determinations, if all deadlines are fully postponed
  • August 2, 2021 Deadline for ITC final injury determination, if all DOC deadlines are fully postponed

For further information, contact Douglas J. Heffner, Richard P. Ferrin or any other member of the Customs and International Trade Team.

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