On September 28, 2023, Eastman Kodak Company filed antidumping duty (AD) petitions on Aluminum Lithographic Printing Plates from China and Japan, and a countervailing duty (CVD) petition on the same product from China.

Eastman alleges that imports of printing plates from these countries are injuring the US domestic industry because they are sold in the United States for less than “normal value” and unfairly subsidized.

Eastman requests the imposition of significant AD/CVD duties, between 23.52% and 107.64%. AD/CVD duties will be imposed if the US Department of Commerce (DOC) determines that such alleged dumping and subsidization is occurring and if the US International Trade Commission (ITC) determines that there is “material injury” (or the threat thereof) by reason of the dumped and/or subsidized imports.

If the investigations are affirmative, importers of printing plates from China and Japan will be liable for any potential AD and/or CVD duties imposed.

Scope of Investigations

Per the petition, these investigations cover aluminum lithographic printing plates, which consist of a flat substrate containing at least 90% 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 Harmonized Tariff Schedule of the United States (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.

Aluminum lithographic printing plates may — depending on physical characteristics — also be referred to as digital printing plates, offset printing plates, photosensitive printing plates, or thermal printing plates. These plates are image carriers used in offset printing processes. Aluminum lithographic printing plates are capable of capturing an image that is transferred onto the plate by either light or heat, and then reproducing this image on a suitable receiving material (e.g., cloth, paper, or plastic) using various fountain solutions and inks.

These plates are commonly used to produce printed goods such as newspapers, magazines, books, yearbooks, coupons, packaging, and other printed materials. The scope of this petition includes only lithographic printing plates manufactured using an aluminum substrate, and specifically excludes lithographic printing plates manufactured using a substrate produced from other materials (e.g., plastic or rubber).

Alleged AD Margins

• China - 107.64%
• Japan - 23.52%

Estimated Key Dates of Interest to Exporters and Importers

The following are estimated key dates for these investigations, once initiated by the DOC and the ITC:

For further information, please reach out to any of the authors of this alert, or any other member of our team.

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