On April 19, 2017, Petitioners ArcelorMittal Tubular Products, Michigan Seamless Tube, LLC, PTC Alliance Corp., Webco Industries, Inc., and Zekelman Industries, Inc. filed a petition for the imposition of antidumping duties and countervailing duties on imports of Certain Cold-Drawn Mechanical Tubing of Carbon and Alloy Steel from China, Germany, India, Italy, Korea, and Switzerland.

SCOPE OF THE INVESTIGATION

The scope of this investigation covers cold-drawn mechanical tubing of carbon and alloy steel (“cold-drawn mechanical tubing”) of circular cross-section, in actual diameters less than 13 inches (less than 331 mm), and regardless of wall thickness, surface finish, end finish or industry specification. The subject cold-drawn mechanical tubing is a tubular product with a circular cross-sectional shape that has been cold-drawn or otherwise cold-finished after the initial tube formation in a manner that involves a change in the diameter or wall thickness of the tubing, or both. The subject cold-drawn mechanical tubing may be produced from either welded (i.e., electric resistance welded, continuous welded, etc.) or seamless (e.g., pierced, pilgered or extruded, etc.) carbon or alloy steel tubular products. It may also be heat treated after cold working (annealed, normalized, quenched and tempered, stress relieved or finish annealed). Typical cold drawing methods for subject merchandise include, but are not limited to, drawing over mandrel, rod drawing, and sink drawing.

Subject cold-drawn mechanical tubing is typically certified to meet industry specifications for cold-drawn tubing including but not limited to:

  1. American Society for Testing and Materials (ASTM) or American Society of Mechanical Engineers (ASME) specifications ASTM A-512, ASTM A-513 Type 3 (ASME SA513 Type 3), ASTM A-513 Type 4 (ASME SA513 Type 4), ASTM A-513 Type 5 (ASME SA513 Type 5), ASTM A- 513 Type 6 (ASME SA513 Type 6), ASTM A-519 (cold finished);
  2. SAE International (Society of Automotive Engineers) specifications SAE J524, SAE J525, SAE J2833, SAE J2614, SAE J2467, SAE J2435, SAE J2613;
  3. Aerospace Material Specification (AMS) AMS T-6736 (AMS 6736), AMS 6371, AMS 5050, AMS 5075, AMS 5062, AMS 6360, AMS 6361, AMS 6362, AMS 6371, AMS 6372, AMS 6374, AMS 6381, AMS 6415;
  4. United States Military Standards (MIL) MIL -T-5066 and MIL-T-6736;
  5. foreign standards equivalent to one of the previously listed ASTM, ASME, SAE, AMS or MIL specifications including but not limited to:
    1. German Institute for Standardization (DIN) specifications DIN 2391-2, DIN 2393-2, DIN 2394-2;
    2. European Standards (EN) EN 10305-1, EN 10305-2, EN 10305-4, EN 10305-6 and European national variations on those standards (e.g., British Standard (BS EN), Irish Standard (IS EN) and German Standard (DIN EN) variations, etc.);
    3. Japanese Industrial Standard (JIS) JIS G 3441 and JIS G 3445; and
  6. proprietary standards that are based on one of the abovelisted standards.

The subject cold-drawn mechanical tubing may also be dual or multiple certified to more than one standard.

Steel products included in the scope of this investigation are products in which: (1) iron predominates, by weight, over each of the other contained elements; and (2) the carbon content is 2 percent or less by weight.

For purposes of this scope, the place of cold-drawing determines the country of origin of the subject merchandise. Subject merchandise that is subject to minor working in a third country that occurs after drawing in one of the subject countries including, but not limited to, heat treatment, cutting to length, straightening, nondestruction testing, deburring or chamfering, remains within the scope of the investigation.

All products that meet the written physical description are within the scope of this investigation unless specifically excluded or covered by the scope of an existing order. Merchandise that meets the physical description of cold-drawn mechanical tubing above is within the scope of the investigation even if it is also dual or multiple certified to an otherwise excluded specification listed below. The following products are outside of, and/or specifically excluded from, the scope of this investigation:

  1. cold-drawn stainless steel tubing, containing 10.5 percent or more of chromium by weight and not more than 1.2 percent of carbon by weight;
  2. products certified to one or more of the ASTM, ASME or American Petroleum Institute (API) specifications listed below:
  • ASTM A-53;
  • ASTM A-106;
  • ASTM A-179 (ASME SA 179);
  • ASTM A-192 (ASME SA 179);
  • ASTM A-209 (ASME SA 209);
  • ASTM A-210 (ASME SA 210);
  • ASTM A-213 (ASME SA 213);
  • ASTM A-334 (ASME SA 334);
  • ASTM A-423 (ASME SA 423);
  • ASTM A-498;
  • ASTM A-496 (ASME SA 496);
  • ASTM A-199;
  • ASTM A-500;
  • ASTM A-556;
  • ASTM A-565;
  • API 5L; and
  • API 5CT

except that any cold-drawn tubing product certified to one of the above excluded specifications will not be excluded from the scope if it is also dual- or multiple-certified to any other specification that otherwise would fall within the scope of this investigation.

The products subject to the investigation are currently classified in the Harmonized Tariff Schedule of the United States (HTSUS) under item numbers: 7304.31.3000, 7304.31.6050, 7304.51.1000, 7304.51.5005, 7304.51.5060, 7306.30.5015, 7306.30.5020, 7306.50.5030. The HTSUS subheadings above are provided for convenience and customs purposes only. The written description of the scope of the investigation is dispositive.

PETITIONERS

ArcelorMittal Tubular Products 132 West Main Street Shelby, Ohio 44875

Michigan Seamless Tube, LLC 400 McMunn Street South Lyon, Michigan 48178

PTC Alliance Corp. 6051 Wallace Road Ext., Suite 200 Wexford, Pennsylvania 15090

Webco Industries, Inc. 9001 West 21st Street Sand Springs, Oklahoma 74063

Zekelman Industries 100 Martin Luther King Junior Blvd. Farrell, Pennsylvania 16121

COUNSEL FOR PETITIONERS

Alan Luberda

KELLEY DRYE & WARREN LLP 3050 K Street, N.W., Suite 400 Washington, D.C. 20007

ALLEGED DUMPING MARGIN

China: 88.82 – 188.88%

Germany: 70.53 – 148.32%

India: 25.48%

Italy: 37.23 – 69.13%

Korea: 12.14 – 48.61%

Switzerland: 40.53 – 115.2l%

ALLEGED SUBSIDIES MARGIN

Countervailing Duty Petitions issued against China and India. Amounts of additional duties unspecified.

NAMED PRODUCERS/EXPORTERS

For a list of foreign products/exporters alleged by Petitioner, please see Attachment I.

NAMED IMPORTERS

For a list of importers alleged by Petitioner, please see Attachment II.

Imports of Subject Merchandise

2014 2015 2016
India
Volume (Short Tons) 23,351 21,681 24,999
Value (USD) 30,420,154 26,196,056 24,998,287
AUV (USD/ST) 1,303 1,208 1,000
China
Volume 28,673 26,768 23,098
Value (USD) 42,490,567 38,058,961 29,422,194
AUV (USD/ST) 1,482 1,422 1,274
Germany
Volume 13,785 22,092 21,414
Value (USD) 38,255,178 43,544,377 38,801,537
AUV (USD/ST) 2,775 1,971 1,812
Korea
Volume 10,211 10,681 11,102
Value (USD) 24,276,275 18,569,262 21,336,857
AUV (USD/ST) 2,377 1,738 1,922
Switzerland
Volume 9,213 9,821 10,998
Value (USD) 23,867,619 25,720,585 26,179,986
AUV (USD/ST) 2,591 2,619 2,380
Italy
Volume 4,816 9,380 7,152
Value (USD) 12,816,463 20,572,099 11,874,237
AUV (USD/ST) 2,661 2,193 1,660