New Antidumping Duty and Countervailing Duty Petitions on Aluminum Lithographic Printing Plates from China and Japan

At a Glance

• Eastman Kodak Company filed AD and CVD petitions on aluminum lithographic printing plates from China and an AD petition on aluminum lithographic printing plates from Japan.
• Investigations related to these petitions could lead to increased prices and/or decreased supply of these printing plates.
• The U.S. Department of Commerce is expected to begin investigations on October 18; however, deadlines are likely to be tolled if there is a government shutdown.

On September 28, 2023, Eastman Kodak Company (Petitioner) filed antidumping duty (AD) petitions on aluminum lithographic printing plates from China and Japan and a countervailing duty (CVD) petition on aluminum lithographic printing plates 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.” 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 subsidization is 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 aluminum lithographic printing plates from China and Japan.

Scope:

Per the Petition:

The merchandise covered by these investigations is aluminum lithographic printing plates. Aluminum lithographic printing plates consist of a flat substrate containing at least 90 percent aluminum. The aluminum-containing substrate is generally treated using a mechanical, electrochemical, or chemical graining process, which is followed by one or more anodizing treatments that form a hydrophilic layer on the aluminum-containing substrate. An image-recording, oleophilic layer that is sensitive to light, including but not limited to ultra-violet, visible, or infrared, is dispersed in a polymeric binder material that is applied on top of the hydrophilic layer, generally on one side of the aluminum lithographic printing plate. The oleophilic light-sensitive layer is capable of capturing an image that is transferred onto the plate by either light or heat. The image applied to an aluminum lithographic printing plate facilitates the plate's use in offset printing processes to produce materials such as newspapers, magazines, books, yearbooks, coupons, packaging, and other printed materials. Aluminum lithographic printing plates within the scope of these investigations include all aluminum lithographic printing plates, irrespective of the dimensions or thickness of the underlying aluminum substrate, whether the plate requires processing after an image is applied to the plate, whether the plate is ready to be mounted to a press and used in printing operations immediately after an image is applied to the plate, or whether the plate has been exposed to light or heat to create an image on the plate or remains unexposed and is free of any image.

Subject merchandise also includes aluminum lithographic printing plates produced from an aluminum sheet coil that has been coated with a light-sensitive image-recording layer in a subject country and that is subsequently unwound and cut to the final dimensions to produce a finished plate in a third country (including the United States), or exposed to light or heat to create an image on the plate in a third country (including the United States).

Excluded from the scope of these investigations are lithographic printing plates manufactured using a substrate produced from a material other than aluminum, such as rubber or plastic.

Aluminum lithographic printing plates are currently classifiable under HTSUS subheadings 3701.30.0000 and 3701.99.6060. Further, merchandise that falls within the scope of these investigations may also be entered into the United States under HTSUS subheadings 3701.99.3000 and 8442.50.1000. Although the HTSUS subheadings are provided for convenience and customs purposes, the written description of the scope of these investigations is dispositive.

Estimated Dumping Margins:

The Petitioner alleges the following dumping margins exist:

• China – 107.64%
• Japan – 23.52%

The Petitioner also alleges significant subsidies with respect to China, although the petition does not quantify the alleged net subsidy margins.

Estimated Schedule of Investigations:

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

• September 28, 2023:Petitions are filed.
• October 18, 2023:DOC initiates investigations.
• October 19, 2023:ITC staff conference (estimated).
• November 12, 2023:Deadline for ITC preliminary injury determination.
• December 22, 2023:Deadline for DOC preliminary CVD determinations, if deadlines are NOT postponed.
• February 25, 2024:Deadline for DOC preliminary CVD determinations, if deadlines are fully postponed.
• March 6, 2024: Deadline for DOC preliminary AD determinations, if deadlines are NOT postponed.
• April 25, 2024: Deadline for DOC preliminary AD determinations, if deadlines are fully postponed.
• September 7, 2024:Deadline for DOC final AD and CVD determinations, if all deadlines are fully postponed.
• October 22, 2024:Deadline for ITC final injury determination, if all DOC deadlines are fully postponed.