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PETITIONS FOR THE IMPOSITION OF ANTIDUMPING AND COUNTERVAILING DUTIES: CERTAIN FREIGHT RAIL COUPLER SYSTEMS AND COMPONENTS THEREOF FROM THE PEOPLE’S REPUBLIC OF CHINA

I.  Type of Action: Antidumping Duty (“AD”) and Countervailing Duty (“CVD”): People’s Republic of China

II.  Product: The scope of the imported merchandise that Petitioners intend to cover in this investigation is:

The scope of this investigation covers certain freight rail car coupler systems and components thereof. Subject freight rail car coupler systems are composed of knuckles, coupler bodies, coupler yokes, and follower blocks. Subject coupler systems and components are included within the scope whether finished or unfinished, whether assembled fully or partially or unassembled, whether mounted or unmounted, or if joined with non-subject merchandise, such as other non-subject system parts or a completed rail car. Only the subject coupler system and components are subject to duties if imported with or mounted with other non-subject merchandise. Subject freight rail coupler components imported individually independent from a coupler system are also included within the scope of the investigation.

A coupler system (also known as a “coupling”) is the mechanism used to connect freight rail cars together. The knuckles function as interlocking parts of the couplers that close automatically due to the force of the freight rail cars coming together. The coupler yoke functions as the pocket for the draft gear that connect couplers to the freight car. The follower block is a rectangular shaped block of steel that is interposed between the back end of the coupler and the front working end of the draft gear.

The products covered by the scope of this investigation, when imported into the United States, meet, intend to meet, or exceed the Association of American Railroads (“AAR”) specifications of M211, “Foundry and Product Approval Requirements for the Manufacture of Couplers, Coupler Yokes, Knuckles, Follower Blocks, and Coupler Parts” and/or AAR M215 “Coupling Systems,” or other equivalent domestic or international standards (including any revisions to the standard(s)). Subject merchandise include: (1) E and E/F couplers; (2) F couplers; (3) E yokes; (4) F yokes; (5) E and F knuckles; and (6) and E and F type follower blocks. The inclusion, attachment, joining, or assembly of non-subject components with subject components or systems does not remove the subject components or systems from the scope.

The country of origin for subject coupler systems and components, whether fully assembled, unfinished, semi-finished, or finished, or attached to a rail car, is the country where the subject coupler components were cast and/or forged. Subject merchandise includes coupler components as defined above that have been further processed or further assembled, creating a more complex assembly in a third country, including those coupler components attached to a rail car in third countries. Only the value of the subject merchandise if entered attached to other non-subject products including the rail car will be subject to duties.

III.  HTS classifications: The merchandise subject to this investigation is currently classifiable in the Harmonized Tariff Schedule of the United States (“HTSUS”) statistical reporting numbers 8607.30.1000. Subject merchandise attached to finished rail cars may also enter under HTSUS heading 8606 or under subheading 980300 if imported as an Instrument of International Traffic.

IV.  Date of Filing: September 29, 2021.

V.  Petitioners: The Coalition of Freight Coupler Producers (“CFCP”), comprised of Amsted Rail Company, Inc. (“Amsted”) and McConway & Torley LLC (“M&T”).

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:  142.9%

IX.  Comments:

A.  Projected date of ITC Preliminary Conference: October 20, 2021.

B.  The earliest theoretical date for retroactive suspension of liquidation for the AD is December 8, 2021. The earliest theoretical date for retroactive suspension of liquidation for the CVD is October 19, 2021.

Please contact our office for a complete projected schedule for the AD/CVD investigations.

C.  Volume and Value of Imports:

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

D.  List of Alleged Subsidy Programs:

Please contact our office for a list of alleged subsidy programs.

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

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