Petition Summary: Aluminum Lithographic Printing Plates from China and Japan –Petition for Imposition of Antidumping and Countervailing Duties

Husch Blackwell LLP

On September 28, 2023, Eastman Kodak Company (the “Petitioner”) filed a petition for the imposition of antidumping duties on Aluminum Lithographic Printing Plates from China and Japan, as well as the imposition of countervailing duties on Aluminum Lithographic Printing Plates from China.

The following language describes the imported merchandise that Petitioner intends to be included in the scope of these investigations:
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 imagerecording, 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.

Eastman Kodak Company
343 State Street
Rochester, NY 14650
Phone: (800) 356-3259
Fax: (585) 724-1089
Contact: Paul Smith, Corporate Compliance Manager

3050 K Street, N.W., Suite 400
Washington, D.C. 20007
(202) 342-8400

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

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


Event Earliest Date
Petition Filed September 28, 2023
DOC Initiation October 18, 2023
ITC Preliminary Investigation:  
Questionnaires Due October 12, 2023
Request to appear at hearing October 17, 2023
Hearing October 19, 2023
Briefs October 24, 2023
ITC Vote November 12, 2023
DOC Investigation Schedule:  
DOC Preliminary Antidumping Determination March 6, 2024
DOC Final Antidumping Determination May 20, 2024
DOC Preliminary Countervailing Determination December 22, 2023
DOC Final Countervailing Determination March 6, 2024
ITC Final Investigation:  
ITC Final AD Determination July 4, 2024
ITC Final CVD Determination April 20, 2024

China: 107.64%
Japan: 23.52 %

Above de minimis

For a list of subsidies alleged by the Petitioner, please see Attachment III.


  2020 2021 2022 Jan-Jun-2022 Jan-June- 2023
Quantity(Square Meters) 82,234 697,424 5,249,631 1,678,902 4,071,640
Value ($) 408,846 2,605,157 17,471,668 5,075,476 13,449,995
AUV ($/M2) 4.97 3.74 3.33 3.02 3.30
Quantity(Square Meters) 5,054,546 5,451,299 14,721,850 6,328,029 7,935,304
Value ($) 27,268,544 47,140,860 87,932,578 39,729,043 38,678,354
AUV ($/M2) 5.39 8.65 5.97 6.28 4.87

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Husch Blackwell LLP

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