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

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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.

Scope

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

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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