GDLSK: Grunfeld Desiderio Lebowitz Silverman & Klestadt LLP
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By Simon Speed - Own work, Public Domain,
By Simon Speed - Own work, Public Domain,

Petitions for the Imposition of Antidumping and Countervailing Duties on Certain Chassis and Subassemblies Thereof from the People’s Republic of China

Case Summary

I. Type of Action: Antidumping Duty (“AD”): China ; Countervailing Duty (“CVD”): China

II. Product: The merchandise covered by this investigation are chassis and subassemblies thereof, whether finished or unfinished, whether assembled or unassembled, whether coated or uncoated, regardless of the number of axles, designed primarily for use in the carriage of containers, or other payloads (including self-supporting payloads) that can be attached by twistlocks, slide pins or similar attachment devices, for road, marine roll-on/roll-off (RORO) and/or rail transport. Chassis are typically, but are not limited to, rectangular framed trailers with a suspension and axle system, wheels and tires, brakes, a lighting and electrical system, a coupling for towing behind a truck tractor, and a locking system or systems to secure the shipping container or containers attached to the chassis.

Subject merchandise includes, but is not limited to, the following subassemblies:

  • Chassis frames, or sections of chassis frames, including kingpins or kingpin assemblies, bolsters consisting of transverse beams with locking or support mechanisms, goosenecks, drop assemblies, extension mechanisms and/or rear impact guards;
  • Running gear assemblies or axle assemblies for connection to the chassis frame, whether fixed in nature or capable of sliding fore and aft or lifting up and lowering down, which may or may not include suspension(s) (mechanical or pneumatic), wheel end components, slack adjusters, axles, brake chambers, locking pins, and tires and wheels;
  • Landing gear (legs) or landing gear assemblies, for connection to the chassis frame, capable of supporting the chassis when it is not engaged to a tractor; and
  • Assemblies and/or components that connect to the chassis frame or a section of the chassis frame, such as, but not limited to, pintle hooks or B-trains (which include a fifth wheel), which are capable of connecting a chassis to a converter dolly or another chassis.

Importation of any of these subassemblies, whether assembled or unassembled, constitutes an unfinished chassis for purposes of this investigation.

Subject merchandise also includes chassis, whether finished or unfinished, entered with or for further assembly with components such as, but not limited to: hub and drum assemblies, brake assemblies (either drum or disc), axles, brake chambers, suspensions and suspension components, wheel end components, landing gear legs, spoke or disc wheels, tires, brake control systems, electrical harnesses and lighting systems.

Processing of finished and unfinished chassis and components such as trimming, cutting, grinding, notching, punching, drilling, painting, coating, staining, finishing, assembly, or any other processing either in the country of manufacture of the in-scope product or in a third-country does not remove the product from the scope. Inclusion of other components not identified as comprising the finished or unfinished chassis does not remove the product from the scope.

This scope excludes dry van trailers, refrigerated trailers and flatbed trailers.

III. HTS classifications: 8716.39.0090 or 8716.90.5060.

IV. Date of Filing: July 30, 2020

V. Petitioners: Coalition of American Chassis Manufacturers – Cheetah Chassis Corporation, Hercules Enterprises, LLC, Pitts Enterprises, Inc., Pratt Industries, Inc. and Stoughton Trailers, LLC

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 (No CVD Margins Listed):

China: 211.49%

IX. Comments:

A. Projected date of ITC Preliminary Conference: August 20, 2020.

B. The earliest theoretical date for retroactive suspension of liquidation for the AD is October 8, 2020; CVD is August 19, 2020.

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.


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