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Petition for the Imposition of Antidumping Duties on Imports of Boltless Steel Shelving Units Prepackaged for Sale from India, Malaysia, Taiwan, Thailand, and Vietnam

Case Summary

I.  Type of Action: Antidumping Duty (“AD”) Petition – India, Malaysia, Taiwan, Thailand, and Vietnam

II.  Scope of the Investigations:

The following language describes the imported merchandise that Petitioner intends to cover in this investigation:

The scope of this investigation covers boltless steel shelving, with or without decks. The term “prepackaged for sale” means that, at a minimum, the steel vertical supports (i.e., uprights and posts) and steel horizontal supports (i.e., beams, braces) necessary to assemble a completed shelving unit (with or without decks) are packaged together for ultimate purchase by the end-user. The scope also includes add-on kits. Add-on kits include, but are not limited to, kits that allow the end-user to add an extension shelving unit onto an existing boltless steel shelving unit such that the extension and the original unit will share common frame elements (e.g., two posts). The term “boltless” refers to steel shelving in which the vertical and horizontal supports forming the frame are assembled primarily without the use of nuts and bolts, or screws. The vertical and horizontal support members for boltless steel shelving are assembled by methods such as, but not limited to, fitting a rivet, punched or cut tab, or other similar connector on one support into a hole, slot or similar receptacle on another support. The supports lock together to form the frame for the shelving unit, and provide the structural integrity of the shelving unit separate from the inclusion of any decking. The incidental use of nuts and bolts, or screws to add accessories, wall anchors, tie­bars or shelf supports does not remove the product from scope. Boltless steel shelving units may also come packaged as partially assembled, such as when two upright supports are welded together with front-to-back supports, or are otherwise connected, to form an end unit for the frame. The boltless steel shelving covered by this investigation may be commonly described as rivet shelving, welded frame shelving, slot and tab shelving, and punched rivet (quasi-rivet) shelving as well as by other trade names. The term “deck” refers to the shelf that sits on or fits into the horizontal supports (beams or braces) to provide the horizontal storage surface of the shelving unit. The scope includes all boltless steel shelving meeting the description above, regardless of (1) vertical support or post type (including but not limited to open post, closed post and tubing); (2) horizontal support or beam/brace profile (including but not limited to Z-1-5 beam, C-beam, L-beam, step beam and cargo rack); (3) number of supports; (4) surface coating (including but not limited to paint, epoxy, powder coating, zinc and other metallic coating); (5) number of levels; (6) weight capacity; (7) shape (including but not limited to rectangular, square, and comer units); (8) decking material (including but not limited to wire decking, particle board, laminated board or no deck at all); or (9) the boltless method by which vertical and horizontal supports connect (including but not limited to keyhole and rivet, slot and tab, welded frame, punched rivet and clip).

Specifically excluded from the scope are:

  • Wall-mounted shelving, defined as shelving that is hung on the wall and does not stand on, or transfer load to, the floor;
  • Wire shelving units, which consist of shelves made from wire that incorporates both a wire deck and wire horizontal supports (taking the place of the horizontal beams and braces) into a single piece with tubular collars that slide over the posts and onto plastic sleeves snapped on the posts to create the finished shelving unit;
  • Bulk-packed parts or components of boltless steel shelving units; and
  • Made-to-order shelving systems.


III.  HTS classifications: Subject boltless steel shelving enters the United States through Harmonized Tariff Schedule of the United States (“HTSUS”) statistical subheading 9403.20.0075. While the HTSUS subheading is provided for convenience and Customs purposes, the written description of the scope of this investigation is dispositive.

IV.  Date of Filing: April 25, 2023

V.  Petitioner: Edsal Manufacturing Co., Inc

VI.  Foreign Producers/Exporters:

Please contact our office for a list filed with the petition.

VII.  US Importers named:

Please contact our office for a list filed with the petition.

VIII.  Alleged Dumping Margins:

India: 215.77%
Malaysia: 41.29 – 232.94%
Taiwan: 217.66%
Thailand: 177.72 – 188.06%
Vietnam: 85.24 – 205.49%


IX.  Comments:

A.  Projected date of ITC Preliminary Conference: May 16, 2023.

B.  The earliest theoretical date for retroactive suspension of liquidation for the AD is July 4, 2023.

Please contact our office for a complete projected schedule for the AD investigation.

C.  Volume and Value of Imports:

Please contact our office for a summary of the data filed with the petition.

If you have questions regarding how this investigation may impact current and future imports of scope merchandise or whether a particular product is within the scope of the investigation, please contact one of our attorneys.

Type of Action
HTS Classifications
Date of Filing
Foreign Producers and Exporters
US Named Importers
Alleged Dumping Margins
Additional Notes